Technology 2 minutes read

What a cookie scan finds – and what it misses

An automated crawl produces a list and with it a feeling of safety. Both can mislead: a scan sees only what happens during its own visit – and on most websites that is markedly less than what actually happens.

A scanner opens pages like a visitor, records which connections arise and what gets stored, and matches the findings against a catalogue of known services. As a first overview that is a good tool – for completeness it is an insufficient one.

How much a typical scan sees of a website

  • Static page without loginnearly complete
  • Shop with a basketcheckout path missing
  • Portal with a loginthe logged-in area is missing entirely
  • Site with server-side measurementinvisible in the browser
The bars show the estimated share of actual processing that a crawl captures in each setting. The gap between the first and last row is why a scan starts a stocktake rather than finishing one.

The five blind spots

  1. The logged-in area. A scanner does not log in. Yet that is exactly where the most personal processing sits.
  2. Event-driven scripts. Whatever loads only on submitting a form, playing a video or after thirty seconds is invisible to a crawl.
  3. Server-side forwarding. It leaves no trace in the browser and is in principle undetectable from outside.
  4. Regional differences. A scan from Frankfurt sees the European version. Advertising partners loaded only outside the EU stay invisible.
  5. Rotating advertising partners. With real-time auctions, who gets loaded is decided anew on each visit. Two crawls yield two different lists.

How to close the gaps

  • Treat the scan as a starting point, not a result – and hold the findings against internal knowledge of which services are embedded.
  • Walk through checkout and forms once by hand, with the network log open.
  • Consult the list of contracts: every processing agreement names a service that is embedded somewhere.
  • Review the published triggers in the tag manager – it states what loads when, more completely than any scan can observe.

A scan answers the question "what did I overlook". It does not answer the question "do I have everything".

Published 25 September 2026

This article explains general principles and does not replace legal advice on an individual case.

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