RU EN
www.
Technical audit · 31.05.2026

hpra.ie

HPRA — Health Products Regulatory Authority of Ireland
IE

Policy changed — see what exactly · 2026-09-23 →

HPRA — Ireland's regulator for medicinal products, medical devices, and veterinary medicines. 39 requests, 10 domains. GTM loads 109 ms ahead of the banner. Monotype fonts and the jQuery CDN load prior to consent. browser-update.org is an undocumented script. The policy is detailed for regulatory data and empty for web data.

Request timeline

+244 ms · before the banner
cookie-cdn.cookiepro.com/otSDKStub.js — the CookiePro SDK begins loading.
+245 ms · before the banner
code.jquery.com — jQuery Migrate 3.5.2 and jQuery UI 1.13.2 from the external jQuery Foundation CDN.
+246 ms · before the banner
customer.cludo.com — Cludo search (search-script.min.js, cludo-search-results.js). A Danish platform.
+266 ms · before the banner
www.googletagmanager.com (GTM-WZ6M8HK3) — the GTM container loads.
+271 ms · before the banner
fast.fonts.net/t/1.css — the Monotype font service. projectid=a3cc82a1. The user's IP address is transmitted to Monotype's servers in the USA.
+375 ms · banner
cookie-cdn.cookiepro.com/otBannerSdk.js — the CookiePro banner is displayed. GTM has already been running for 109 ms.
+582 ms · prior to consent
api.cludo.com/api/v3/3499/15036/websites/publicsettings — the Cludo API requests configuration (two calls). browser-update.org/update.min.js — the outdated-browser alert script.

Declared versus actual

+ Google Tag Manager (GTM-WZ6M8HK3) — not mentioned — not declared
+ Monotype / fast.fonts.net — not mentioned — not declared
+ Cludo (customer.cludo.com, api.cludo.com) — not mentioned — not declared
+ browser-update.org — not mentioned — not declared
+ jQuery CDN (code.jquery.com) — not mentioned — not declared

Transfer timings

+245 ms code.jquery.com

jQuery Migrate 3.5.2 + jQuery UI 1.13.2. jQuery Foundation. USA.

+246 ms customer.cludo.com

Cludo search JS. Denmark.

+266 ms www.googletagmanager.com

GTM-WZ6M8HK3. USA.

+271 ms fast.fonts.net

Monotype fonts. projectid=a3cc82a1. USA.

+375 ms cookie-cdn.cookiepro.com

CookiePro otBannerSdk.js. UUID 01926cc0.

+582 ms api.cludo.com

Cludo API publicsettings. x2.

+582 ms browser-update.org

update.min.js. Outdated-browser script.

Detected trackers

Indicators of GDPR non-compliance

Context

HPRA (the Health Products Regulatory Authority) is Ireland’s regulator for medicinal products, medical devices, veterinary medicines, and cosmetics. It participates in the European network of medicines regulators (the HMA). Sensitivity: high — visitors to the site may include healthcare professionals, patients, or individuals reporting adverse drug reactions. HAR: 39 requests, 10 domains.

GTM 109 ms ahead of the banner

GTM-WZ6M8HK3 loads at +266 ms. The CookiePro banner loads at +375 ms. The pattern is identical to that at tcd.ie, oireachtas.ie, and other sites in the series: a CMP is present, but GTM initializes before the banner has finished rendering. What the GTM container activates within these 109 ms cannot be determined from the HAR without auditing the container’s contents, but the window exists.

Monotype — a corporate font service

fast.fonts.net is the Monotype Fonts platform, a corporate alternative to Google Fonts. Unlike Google Fonts, Monotype is a paid subscription service used primarily by organizations with corporate licenses. Every request to fast.fonts.net/t/1.css?apiType=css&projectid=a3cc82a1-363c-45d7-bdf2-43868f698a3a transmits the visitor’s IP address to Monotype’s American servers. It loads at +271 ms — prior to consent, with no mention in the policy.

browser-update.org — a low-risk but undocumented script

browser-update.org/update.min.js is an open-source tool that alerts users to outdated browsers. The project is non-commercial and of German origin, with no explicit advertising or tracking function. Nevertheless, every request transmits the IP address and user agent to an external server. The script returns a 304 (Not Modified) status, indicating a cached version is present — meaning the visitor’s browser has contacted this server before. It is not mentioned in the privacy policy.

The jQuery CDN — a fixable dependency

jQuery Migrate 3.5.2 and jQuery UI 1.13.2 load from code.jquery.com (+245 ms). A local copy of jQuery 3.7.1 is already hosted at www.hpra.ie/ResourcePackages/HPRA/assets/dist/hpra/css/jquery.min.js. Individual jQuery plugins (Migrate, UI) load from an external CDN, while the core library is hosted locally. This is an inconsistent setup: moving jQuery Migrate and UI to local hosting is a trivial task.

The policy: detailed for regulatory data, empty for the web

The privacy policy describes the processing of data in a regulatory context in detail and correctly: legal bases under Art. 6(1)(a)(c)(e), special categories under Art. 9(1)(i), data sharing with European regulatory partners, and retention. There is not a single word about web technical tools. GTM, Monotype, Cludo, browser-update.org, and the jQuery CDN are all unmentioned.

Set-Cookie — zero

None of the 39 requests sets a cookie via Set-Cookie.

Conclusion

hpra.ie reproduces the standard pattern seen throughout the Irish series: a CMP is present, and GTM outpaces the banner. What sets it apart is an unusual set of external dependencies: Monotype instead of Google Fonts, browser-update.org, and Cludo. None of these tools is documented in a policy focused exclusively on regulatory data. For a body regulating products that affect citizens’ health, complete documentation of website visitor data is no less important than the accuracy of its regulatory records.

Evidence

How to verify: download the file and compute its checksum — sha256sum file.har (Linux, macOS) or certutil -hashfile file.har SHA256 (Windows); it must match the one shown. The conclusions apply to the scope of this measurement — see the limitations of the method.

Original (audit)
HAR file: ie/hpra-ie-2026-05-31.har
SHA-256: 09f01c7a7bff94416475dd809875a223682f0ff8b9668d228c5470b375284fda
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
Want a response from the company about this audit? → Open the tool

Fill in once — it will be inserted into every letter below:

All fields are required to print the document — this is a formal requirement of the letter itself (the particulars of an official submission), not data collection: nothing is sent or saved anywhere, it all stays in your browser and disappears when you close the page. See the methodology for details.

Step 1. Data access request (GDPR Art. 15)

Send this letter directly to the company first — before contacting the regulator it has the right to respond (GDPR Art. 12(3) — 30 days).

Subject: Data access request (GDPR Art. 15) — hpra.ie

To: [insert the company's address — DPO / support / legal department]
From: [Your name], [contact email]

I request access to my personal data processed in connection with the website hpra.ie.

1. Categories of data and purposes of processing (Art. 15(1)(a)-(c))
Based on an independent technical analysis of the site, I request confirmation and detailed disclosure of the following categories of processing:

1) GTM (GTM-WZ6M8HK3) loads at +266 ms. The CookiePro banner (otBannerSdk.js) appears at +375 ms. Gap: 109 ms. Monotype fonts (fast.fonts.net) load at +271 ms without consent, transmitting the user's IP address to Monotype's servers in the USA. browser-update.org/update.min.js loads at +582 ms without consent. The jQuery CDN (code.jquery.com) fires two requests at +245 ms without consent. Cludo (+246 ms) and the Cludo API (+582 ms) fire both before and after the banner.

2) browser-update.org is an open-source project that alerts users to outdated browsers. The update.min.js script loads on every page and transmits data about the user's browser to browser-update.org's servers (a German non-profit project, but nevertheless an external recipient of the IP address). It is not mentioned in the privacy policy.

3) HPRA's privacy policy describes the processing of regulatory data (medicinal products, medical devices, professional data) in detail, but contains no mention whatsoever of web technical tools: GTM, Monotype, Cludo, browser-update.org, and the jQuery CDN are not named as recipients of visitors' website data.


2. Recipients, retention periods, and transfers outside the EEA (Art. 15(1)(c)-(d), 46)
I also request the full list of third-party recipients, the applicable retention period for each category, and the legal basis for any transfer of data outside the EEA. The full technical audit with evidence (saved network log, SHA-256 checksum) is published at: https://gdpru.eu/en/audits/ie-hpra-ie/

3. Automated processing and profiling (Art. 15(1)(h))
Please state whether I am subject to automated decision-making or profiling, and if so, disclose the logic involved.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]
IMPORTANT: before filing a complaint with the regulator, first contact the company directly and give it 30 days to respond. Without this step the regulator may reject the complaint. Details and a template letter to the company are in the Methodology.
Ready-to-send complaint letter

Where to file: Data Protection Commission (DPC) — dataprotection.ie

The regulator reviews complaints in its national language. There is an officially translated template from the European Data Protection Board (EDPB) — you can use it instead of or alongside this letter: Official EDPB complaint form (PDF, your language)

Subject: Complaint regarding personal data processing — hpra.ie

1. Subject of the complaint
I am filing a complaint regarding the processing of my personal data by the website hpra.ie.

2. Circumstances
I visited the website hpra.ie and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 31 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) GTM (GTM-WZ6M8HK3) loads at +266 ms. The CookiePro banner (otBannerSdk.js) appears at +375 ms. Gap: 109 ms. Monotype fonts (fast.fonts.net) load at +271 ms without consent, transmitting the user's IP address to Monotype's servers in the USA. browser-update.org/update.min.js loads at +582 ms without consent. The jQuery CDN (code.jquery.com) fires two requests at +245 ms without consent. Cludo (+246 ms) and the Cludo API (+582 ms) fire both before and after the banner.

2) browser-update.org is an open-source project that alerts users to outdated browsers. The update.min.js script loads on every page and transmits data about the user's browser to browser-update.org's servers (a German non-profit project, but nevertheless an external recipient of the IP address). It is not mentioned in the privacy policy.

3) HPRA's privacy policy describes the processing of regulatory data (medicinal products, medical devices, professional data) in detail, but contains no mention whatsoever of web technical tools: GTM, Monotype, Cludo, browser-update.org, and the jQuery CDN are not named as recipients of visitors' website data.

Full technical documentation is published at: https://gdpru.eu/en/audits/ie-hpra-ie/

3. GDPR provisions I ask you to examine
GDPR Art. 6(1), Art. 7; ePrivacy Regulations (SI 336/2011); GDPR Art. 6(1) — browser-update.org as an undocumented external domain; GDPR Art. 13(1)(e)

4. Request
I request that you examine the circumstances described and, if non-compliance is confirmed, apply the measures provided for in Article 58(2) GDPR.

5. Attachments
The full evidence base — the HAR file, its SHA-256 checksum and the quotation from the site's privacy policy documenting the stated contradiction — is published and verifiable at the link in point 2 above.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]