UK PECR penalties jumped 35x under the Data (Use and Access) Act 2025 — up to £17.5M. The ICO is auditing the top 1,000 UK websites. Are you ready? ↓

GDPR Compliance Evidence — For What You Don’t Control

GDPR Compliance Evidence when your vendor changes their terms without telling you

You control your own CMS. You don’t control theirs. ProofSnap gives you the proof.

Your processor updated their privacy policy. Your SaaS vendor quietly changed their DPA. Your sub-processor added a new data transfer clause. A client’s cookie banner broke after your agency handed it over. You need proof of what their website showed before the change — but you have no access to their version history.

ProofSnap captures any website with a cryptographic timestamp — creating tamper-proof evidence of what a third party’s website showed on any date. The accountability layer for everything you don’t control.

7-day free trial, cancel anytime. From $4.99/month.

10 seconds per capture · Capture any website — yours or third-party · No IT department required

Art. 28
processor monitoring required
Art. 5(2)
burden of proof is on you
10s
per capture
€7.1B+
GDPR fines since 2018

What is GDPR compliance evidence?

GDPR compliance evidence is tamper-proof documentation of what a website, privacy policy, cookie banner or data processing agreement showed on a specific date. Under GDPR Article 5(2) (accountability) and Article 28 (processor monitoring), data controllers must demonstrate compliance — including for third-party processors and sub-processors they cannot control. ProofSnap creates this evidence by capturing any web page with a cryptographic timestamp, SHA-256 hash, and chain of custody in 10 seconds.

You control your own website.
You don’t control theirs.

Your CMS has version history. Your CMP has consent logs. But when a vendor, processor, or client changes their website — you have no record of what it said before.

What you already have covered

For your own website, you have tools:

  • CMS version history (your privacy policy)
  • CMP consent logs (your cookie banner)
  • Git/deployment logs (your code changes)

What you have NO record of

For third-party websites, you have nothing:

  • Processor’s privacy policy — changed without notice
  • Vendor’s DPA / terms — quietly updated
  • Sub-processor list — new entity added silently
  • Client’s cookie banner — broke after you delivered it

ProofSnap fills the gap: evidence for what you don’t control

Capture any website

Open your processor’s privacy policy, vendor’s DPA, or client’s cookie banner. Click ProofSnap. 10 seconds — full-page screenshot, HTML source, metadata, forensic log, chain of custody, cryptographic timestamp.

Tamper-proof record

SHA-256 hash, RSA-4096 digital signature, blockchain timestamp (Professional) or eIDAS qualified timestamp with legal presumption (Enterprise). The third party cannot claim “we never said that.”

Monthly monitoring

5 captures/month covers your critical vendors. When something changes, you have proof of what it said before — and when it changed. Art. 28 processor monitoring, done.

What is the fine for GDPR cookie consent violations?

CNIL alone has issued over €935M in cookie-specific fines. GDPR penalties for the most serious violations (Art. 83(5)) reach up to €20M or 4% of annual global turnover, whichever is higher. UK PECR penalties now reach £17.5M under the Data (Use and Access) Act 2025.

€325M

Google (CNIL, Sep 2025)

Gmail ads inserted between emails without consent. Cookies placed during Google account creation without valid consent of millions of French users. Split €200M Google LLC + €125M Google Ireland.

€150M

SHEIN (CNIL, Sep 2025)

10 types of advertising cookies placed before consent. “Reject All” didn’t work. 12 million French visitors/month affected.

€150M

Google (CNIL, Jan 2022)

Accept = 1 click. Refuse = multiple screens. No equal “Refuse All” button on google.fr and youtube.com.

€60M

Meta/Facebook (CNIL, Jan 2022)

Same dark pattern as Google — accept was 1 click, refuse required navigating multiple pages on facebook.com.

€60M

Microsoft/Bing (CNIL, Dec 2022)

Accepting cookies = 1 click. Refusing = 2 clicks. Dark pattern in cookie consent on Bing search engine.

€40M

Criteo (CNIL, Jun 2023)

Failed to verify partner websites obtained valid consent before placing Criteo tracking cookies. 370M user identifiers across the EU.

Additional cookie fines: Apple €8M (2022) · TikTok €5M (2022, no reject button) · American Express €1.5M (2025, cookies despite refusal) · Condé Nast €750K (2025) · noyb has filed 700+ formal GDPR complaints across multiple waves against non-compliant cookie banners.

What changed in 2025–2026: the enforcement landscape just shifted

UK: £500K → £17.5M

PECR penalties jumped 35x

Under the Data (Use and Access) Act 2025, UK cookie consent penalties now match UK GDPR levels — up to £17.5M or 4% of global turnover. The ICO launched a cookie compliance sweep of the top 1,000 UK websites in January 2025.

EU: Digital Omnibus (proposal)

Cookie rules moving into GDPR

The EU Commission’s Digital Omnibus package (19 November 2025) proposes integrating cookie rules directly into GDPR, single-click refusal requirements and machine-readable preference signals. Moves through the EU legislative process during 2026.

Ireland: €530M TikTok

DPC doubled down in 2025

The Irish DPC fined TikTok €530M in May 2025 for transferring EEA user data to China (now under appeal — the Irish High Court stayed the decision in November 2025). CNIL’s average sanction grew sharply between 2024 and 2025. Cumulative GDPR fines now exceed €7.1B. DPAs are not slowing down.

Who needs GDPR compliance evidence?

Four roles with one common problem: proving what a third party’s website showed on a specific date. Web agencies, DPOs, privacy lawyers, and anyone filing a DPA complaint.

Web Agencies & Developers

Your client gets fined: “You built our website. You set up the cookie banner. The DPA says it wasn’t compliant. This is your liability.” After handover, you lose access to their CMS. You can’t prove the banner was correctly configured when you delivered it — or that the client broke it afterwards.

With ProofSnap: capture every client website at deployment and after every cookie banner update. Timestamped proof that the consent mechanism was correctly configured when you delivered it. If the client breaks it later — that’s on them, and you have the evidence.

Handover proof Client liability shield Deployment evidence

DPOs & Compliance Officers

Your processor changed their terms: Art. 28 GDPR requires you to monitor processors. Your analytics provider quietly added a new sub-processor. Your cloud vendor updated their DPA to allow data transfers to a new jurisdiction. You received no notification — and now the DPA is asking about your oversight.

With ProofSnap: monthly captures of every processor’s privacy policy, DPA, and sub-processor list. When they change something, you have timestamped proof of what it said before — and when it changed. Art. 28 monitoring, done in 10 seconds per vendor.

Art. 28 processor monitoring Sub-processor tracking DPA versioning

Privacy Lawyers & Legal Departments

The vendor says “we never said that”: Your SaaS vendor promised GDPR-compliant data processing in their DPA. Now there’s a breach, and their current DPA has different terms. They claim the clause you relied on never existed. Without evidence, it’s your word against theirs.

With ProofSnap: forensic evidence package with chain of custody and cryptographic timestamp. Prove what their DPA stated on the date you relied on it. eIDAS qualified timestamp = legal presumption in 27 EU member states.

Vendor disputes eIDAS Art. 41(2) DPA evidence

Filing GDPR Complaints

You found a violation: A competitor’s cookie banner has no reject button. A website processes your data without consent. You want to file a complaint with the DPA — but by the time they investigate, the website will have changed. The violation will be gone.

With ProofSnap: capture the violation with a cryptographic timestamp before they fix it. Submit the evidence package with your DPA complaint. noyb’s model: capture first, complain second. More than 700 formal complaints filed across multiple waves.

DPA complaints Competitor violations Evidence before it disappears

“Our analytics processor changed their sub-processor list without notification. During the DPA inquiry, we showed 6 months of ProofSnap captures proving the original list and the exact date of the change. The DPA focused their investigation on the processor, not on us.”

DPO, fintech company — Typical scenario

“A client blamed us for their cookie banner fine. We pulled ProofSnap captures from the deployment date — the banner was correct. Then we showed captures from 3 months later — they had modified it themselves. Case closed.”

Web agency founder — Typical scenario

How to prove GDPR compliance in 5 steps

Under the GDPR Art. 5(2) accountability principle, you must demonstrate compliance — not just claim it. Here’s how to build an audit-ready evidence trail.

  1. 1

    Identify your data processors and sub-processors

    List every third party processing personal data on your behalf: cloud hosts, analytics, CRM, email providers, payment processors, marketing tools. Art. 28(1) GDPR requires you to use only processors providing sufficient guarantees.

  2. 2

    Capture each processor’s privacy policy and DPA

    Use ProofSnap to create a timestamped snapshot of each processor’s privacy policy, data processing agreement, and sub-processor list. This is your baseline evidence — what they promised on the date you engaged them.

  3. 3

    Set up monthly monitoring captures

    Repeat the captures monthly. When a processor silently changes their DPA or adds a sub-processor, you’ll have timestamped proof of both the old and new versions — exactly what Art. 28(2) sub-processor notification requires.

  4. 4

    Document your own compliance artefacts

    Capture your own cookie banner, privacy policy, and consent journey at deployment and after every change. For agencies: this is your handover proof. For DPOs: this complements your CMS version history with independent, cryptographically verified evidence.

  5. 5

    Store evidence with chain of custody

    Each ProofSnap capture includes a forensic log, SHA-256 hash, RSA-4096 digital signature, blockchain timestamp, and (on Enterprise) an eIDAS qualified timestamp with legal presumption in 27 EU member states. Store the ZIP packages in a secure archive. During a DPA audit, present 12–24 months of unbroken evidence.

What is a GDPR processor monitoring checklist?

Under GDPR Article 28, data controllers must monitor processors and sub-processors. Capture these 5 pages per vendor every month — 10 seconds each — and you have 12 months of audit-ready Art. 28 compliance evidence.

1

Processor’s Privacy Policy

Their data handling practices, retention periods, legal basis

2

Vendor’s DPA / Terms

Data processing agreement, transfer clauses, SCC references

3

Sub-Processor List

Which entities process data on their behalf, jurisdictions

4

Client’s Cookie Banner

For agencies: post-handover monitoring

5

Competitor Violations

Non-compliant banners, dark patterns, missing policies

The legal foundation: why you must monitor

GDPR Art. 28(1)

“The controller shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures.” You must verify — not just trust.

GDPR Art. 28(2)

The processor shall not engage another processor without prior specific or general written authorisation. Sub-processor changes require your awareness.

GDPR Art. 5(2)

“The controller shall be responsible for, and be able to demonstrate compliance.” The burden of proof is on you — including for processor oversight.

Monitor your processors for less than a coffee a month

5 captures per vendor, per month. Full forensic evidence package. 7-day free trial.

Essential

$4.99/month

or $49.99/year

10 captures/month

  • Full evidence package
  • SHA-256 hash + digital signature
  • Enough for 2 websites/month
7-day free trial

For: solo DPOs, freelancers, small websites

Professional

$16.99/month

or $169.99/year

200 captures/month + blockchain timestamps

  • Everything in Essential
  • Blockchain timestamp (OpenTimestamps)
  • 200 captures = 40 websites/month
7-day free trial

For: agencies, multi-site compliance

Recommended for EU compliance

Enterprise

$28.99/month

or $280/year (20% savings)

Unlimited captures + eIDAS qualified timestamps

  • Everything in Professional
  • eIDAS qualified timestamp — legal presumption in 27 EU states
  • File certification — 50/month
Start monitoring — 7-day free trial

For: DPOs, legal departments, compliance teams

The alternatives cost 10–100x more

Pagefreezer $500+/mo

Enterprise web archiving. Multi-year contracts. Sales process required.

MirrorWeb (custom)

Banks and government only. Not published pricing. Requires implementation.

OneTrust $10K+/year

Enterprise CMP. Consent logs only — no website captures.

ProofSnap from $4.99/mo

Self-service. 10 seconds. Full evidence package with cryptographic timestamps.

Need team accounts? Company plan from $18.99/licence/month — centralised billing, admin dashboard, 2–10,000 licences.

Works for every major privacy regulation

One evidence package — GDPR, UK GDPR, CCPA, PIPEDA, Australian Privacy Act and more. Capture once, comply everywhere.

EU GDPR (27 member states)

€7.1B+ in cumulative fines. Art. 5(2) accountability, Art. 7 consent proof, Art. 24 controller responsibility, Art. 28 processor monitoring.

Top DPAs: Irish DPC (€4B+ total, TikTok €530M May 2025 — under appeal), CNIL (17,772 complaints/yr, €935M+ cookie fines), Spanish AEPD (932 fines)

UK GDPR / ICO

42,315 complaints in 2024/25. Average fine jumped from £150K to £2.8M. PECR penalties now £17.5M (35x increase). Data Protection Act 2018 + Data (Use and Access) Act 2025.

Notable: British Airways £20M, Marriott £18.4M, Capita £14M, Clearview AI £7.5M

USA: CCPA + 19 State Privacy Laws

20 states with active laws (CA CCPA, VA VCDPA, CO CPA, CT CTDPA, TX TDPSA). Up to $7,988/intentional violation (CA, 2025 inflation-adjusted). Texas TDPSA: up to $7,500/violation after 30-day cure. Must honour Global Privacy Control signals.

Notable: Meta’s $1.4B biometric settlement with Texas (2024), Google $1.375B Texas settlement (2025), Disney $2.75M CCPA settlement (largest to date), Tractor Supply $1.35M (largest CPPA administrative fine).

Australia (OAIC)

OAIC activity is increasing under the 2024 reform package. New statutory tort for serious privacy invasions. ADM (automated decision-making) disclosure requirements from December 2026. Shift from declarative to evidentiary compliance.

Privacy Act 1988 + Privacy and Other Legislation Amendment Act 2024. Max penalties for serious interferences: AUD 50M, 3x benefit obtained, or 30% of adjusted turnover during the breach period — whichever is highest.

Canada (PIPEDA)

1,200+ complaints/year to the Office of the Privacy Commissioner (OPC). PIPEDA remains in force after Bill C-27 lapsed when Parliament was prorogued in January 2025. Quebec’s Law 25 imposes stricter GDPR-style obligations with penalties up to CAD 25M or 4% of turnover; Alberta and BC PIPA add provincial layers.

Nordics & Netherlands

Dutch AP: €290M Uber fine (2024), 37,839 breach notifications, one of the most active EU regulators. Sweden IMY: reprimands for pre-selected cookie categories (April 2025). Denmark Datatilsynet: cookie enforcement priority for 2026.

How does ProofSnap capture GDPR compliance evidence?

No API, no IT department, no enterprise contract. Self-service Chrome extension. 10 seconds per capture. Full forensic evidence package.

1

Install ProofSnap

Add the Chrome extension. Start your 7-day free trial. No credit card for browsing — credit card required to start the trial.

2

Open your compliance page

Navigate to your cookie banner, privacy policy, consent preferences, or terms of service page.

3

Capture the evidence

Click ProofSnap. In 10 seconds: full-page screenshot, HTML, metadata, forensic log, chain of custody, SHA-256 hash, digital signature, and cryptographic timestamp.

4

Present during audit

12 months of timestamped captures. Unbroken compliance archive. The auditor has no further questions about accountability documentation.

Frequently Asked Questions

Start monitoring vendors in 10 seconds

GDPR Art. 28 processor monitoring + Art. 5(2) accountability evidence — without waiting for IT, sales calls, or enterprise contracts. Capture any website with a cryptographic timestamp. From $4.99/month.

Start monitoring — 7-day free trial

From $4.99/month. eIDAS qualified timestamps from $28.99/month.

Start monitoring vendors — 10 seconds