The GDPR Analytics Compliance Checklist for Indie Hackers

Choosing a cookie-free analytics tool is one implementation decision. A useful privacy review also asks what you collect, why you need it, who receives it, and how long it remains available.

Use this checklist to prepare that review and identify decisions that need advice for your jurisdiction. Completing it does not certify a deployment or establish a consent exemption.

1. Write down the purpose and the data flow

• Name the questions the analytics must answer, such as whether visitors finish onboarding.
• List the event names and allowed properties needed for those questions.
• Include the browser, API, database, proxy logs, exports, backups, and any external analysis provider in the data flow.
• Identify the controller and the organizations processing data on its behalf.

Keep an example payload beside this record. “Anonymous analytics” is too vague to describe a timestamp, URL, network-derived identifier, and arbitrary custom properties. GDPR purpose limitation and data minimization require a more concrete assessment. GDPR Articles 4 and 5.

2. Assess GDPR and device-access rules separately

Document the applicable lawful basis for personal-data processing. If you rely on legitimate interests, record the purpose, necessity, balancing assessment, and relevant safeguards; the label alone does not justify collection.

Separately assess whether the tracking operation needs consent under the applicable ePrivacy rules. Those rules concern more than cookies. The EDPB’s technical-scope guidance on Article 5(3) is a useful starting point. National audience-measurement exemptions can have detailed conditions; do not infer eligibility from a vendor’s “cookie-free” label.

Your review should produce a specific collection decision and the facts supporting it, rather than a generic promise of “GDPR compliance.”

3. Test the collection controls

If collection requires permission, test the first visit before permission, acceptance, refusal, and withdrawal. Inspect network requests in every case. A hidden banner is not evidence that tracking stopped.

For OwlEye page analytics, delayed initialization looks like this:

import { useAnalytics } from "@owleye/analytics";

const analytics = useAnalytics("owl_your_tracking_id", {
  autoStart: false,
});

// Call only after your applicable collection decision permits tracking.
function enableAnalytics() {
  analytics.start();
}

function disableAnalytics() {
  analytics.stop();
}

Wire those functions into your actual permission lifecycle. Do not initialize optional rules or performance trackers before the same decision, and stop active optional trackers on withdrawal. Review explicit event calls too. Stopping collection does not itself erase historical data.

OwlEye’s SDK respects Global Privacy Control by default. The ingestion API does not independently reject events merely because a DNT or GPC header is present; integrations must enforce their collection policy. See the SDK privacy controls.

4. Remove unnecessary identifying content

Review URL paths as well as query strings. Look for email addresses, search terms, private document IDs, reset tokens, and free text. Check referrers, rule selectors, global properties, and export destinations too.

OwlEye excludes query strings and fragments by default and does not write raw IPs to analytics facts. Its server-derived identifiers are pseudonymous, however, and the server still handles a network address. A hashing secret and daily reporting identifier do not by themselves establish anonymous data. Review infrastructure logs separately.

Prefer report_exported with { format: "csv" } over a filename containing a customer name. Retain only the detail required for the documented purpose.

5. Review providers, contracts, and transfers

Check the processor terms, subprocessors, hosting locations, access arrangements, and any international transfers. Review the applicable transfer mechanism where required. Adding an AI analysis provider, export destination, or backup service can change this assessment. Relevant GDPR provisions include Article 28 and Chapter V. GDPR text.

Include the cloud host, backup provider, edge delivery, and other recipients in the data flow. Changing who operates a component does not automatically remove those recipients or their responsibilities.

6. Set retention and rehearse the response

Choose a retention period based on the purpose, including logs and backups. Verify the actual deletion behaviour and document what happens to exported copies. Provide a clear privacy notice and a workable route for applicable access, objection, withdrawal, or deletion requests.

Keep access restricted, protect secrets and backups, and define an incident response process. Assess whether the processing needs a data protection impact assessment; not every small analytics installation automatically does. GDPR Articles 12–22, 25, 32, and 35 provide the relevant framework. GDPR text.

The useful output is a short evidence pack: purpose and data map, lawful-basis and device-access decisions, reviewed payloads, control tests, provider review, retention settings, and a named owner. Revisit it when instrumentation or providers change. Our cookie-free privacy note explains why the review extends beyond browser storage.

When your collection decision is ready, start free, add supported dashboard events, and build a funnel toward a confirmed signup. Review what each step measures before interpreting the drop-off.