EU ePrivacy Compliance
The EU ePrivacy Directive governs the confidentiality and security of electronic communications.
Learn how ImmuniWeb helps you meet its security obligations alongside the GDPR.
EU ePrivacy Directive Compliance
What Is the EU ePrivacy Directive?
The ePrivacy Directive is lex specialis to the GDPR for electronic communications. It protects the confidentiality of communications, regulates the use of cookies and similar technologies (requiring consent for non-essential cookies), governs electronic direct marketing, and requires providers to safeguard the security of their services.
Because it is a directive, its precise rules and penalties apply through each member state's national implementation. The withdrawal of the proposed ePrivacy Regulation in February 2025 means the Directive and its national laws continue to apply.
See how ImmuniWeb helps you secure the services and apps covered by ePrivacy and GDPR - testing them for vulnerabilities.Request a demo· or run a free Community Edition test.
Who Must Comply with ePrivacy?
ePrivacy obligations apply to:
- Providers of electronic communications servicesoperating in the EU.
- Website and app operators using cookies, tracking technologies or electronic direct marketing.
- Organizations processing personal data in the electronic communications context, alongside the GDPR.
The websites, apps and services in scope must be kept secure - which means testing them for vulnerabilities.
Key ePrivacy Requirements for Application Security
The application-security hook is the security obligation, which overlaps with the GDPR:
- Article 4 - Security of services:providers of publicly available electronic communications services must take appropriate technical and organisational measures to safeguard the security of their services.
- GDPR Article 32 (overlapping):appropriate technical and organisational measures, including regular testing, for the personal data processed.
- Confidentiality & cookies (Articles 5/5(3)):protect the confidentiality of communications and obtain consent for non-essential cookies.
ePrivacy Security Requirements in Depth
Article 4 - Security of Services
Article 4 requires providers of electronic communications services to safeguard the security of their services with appropriate technical and organisational measures. Penetration testing and vulnerability scanning of the web and mobile applications, services and infrastructure involved are practical ways to meet this obligation.
Working with GDPR Article 32
Where personal data is processed, the GDPR's Article 32 security-of-processing duty applies in parallel - including a process for regularly testing the effectiveness of security measures. The same application testing supports both ePrivacy and the GDPR.
Common Web & Mobile Application Risks to Address
The vulnerabilities that undermine the security of in-scope services and apps map closely to the OWASP Top 10:
- Broken Access Control —users reaching data or actions they should not.
- Cryptographic Failures — weak or missing encryption exposing sensitive data.
- Injection — SQL, command or other injection via unvalidated input.
- Insecure Design — missing security controls by design, not just by bug.
- Security Misconfiguration —default, incomplete or unsafe configuration.
- Vulnerable & Outdated Components — unpatched libraries and frameworks.
- Identification & Authentication Failures — weak login, session or credential handling.
- Software & Data Integrity Failures — untrusted updates, insecure CI/CD pipelines.
- Security Logging & Monitoring Failures — attacks going undetected.
- Server-Side Request Forgery (SSRF) — the server tricked into making malicious requests.
For mobile apps, the OWASP Mobile Top 10 is the equivalent reference (insecure data storage, insecure communication, weak cryptography, and so on). Reliably finding these issues requires testing the running application, not just a documentation review.
How to Approach ePrivacy Application Security with ImmuniWeb
- Map your services. Inventory in-scope websites, apps and services with ImmuniWeb Discovery.
- Test web applicationswith On-Demand (penetration testing) and Neuron (scanning).
- Test mobile applications with MobileSuite and Neuron Mobile.
- Remediate and retest with actionable, zero-false-positive reports.
- Keep testing continuously with Continuous in CI/CD.
- Monitor exposure with Discovery.
How ImmuniWeb Helps You Achieve ePrivacy Compliance
ImmuniWeb helps you safeguard the security of the services and applications covered by ePrivacy and the GDPR.
| Requirement | What it requires | ImmuniWeb products |
|---|---|---|
| Article 4 / GDPR Art 32 | Safeguard the security of services and personal data. | On-Demand, Neuron, Discovery, Continuous |
| Apps & services | Secure web/mobile apps and services. | On-Demand, Neuron, MobileSuite, Neuron Mobile |
| Exposure | Detect exposed assets and vulnerabilities. | Discovery (ASM / Dark Web) |
ImmuniWeb On-Demand and MobileSuite deliver web and mobile penetration testing; Neuron and Neuron Mobile provide automated scanning; Continuous embeds testing into CI/CD; and Discovery maps your attack surface - supporting the security obligations under ePrivacy and the GDPR.
ePrivacy vs International Frameworks
If you already work to international standards, the same ImmuniWeb testing supports all of them:
| Framework | Application-security angle | How ImmuniWeb maps |
|---|---|---|
| EU ePrivacy Directive | Article 4 security of services | Web/mobile pentest, scanning, ASM |
| EU GDPR | Article 32 security of processing | Same testing supports both |
| UK PECR / UK GDPR | UK equivalents | Same testing supports both |
| ISO/IEC 27001 | Annex A technical controls | Testing as control evidence |
Penetration Testing vs Security Scanning
Both are needed. Automated scanning (DAST) gives broad, frequent coverage and is ideal for continuous testing in CI/CD; manual penetration testing finds business-logic and complex vulnerabilities that scanners miss and produces the depth auditors and regulators expect. Combine continuous scanning with periodic manual penetration testing, and re-test after significant changes.
Compliance Checklist (Application Security)
- In-scope websites, apps and services inventoried
- Web applications tested against the OWASP Top 10
- Mobile applications tested against the OWASP Mobile Top 10
- Security of services safeguarded (Article 4)
- GDPR Article 32 testing evidenced in parallel
- Findings remediated and re-tested; records retained
- Attack-surface monitoring in place
Why ePrivacy Compliance Matters
ePrivacy is enforced through national law, and data protection authorities have fined organizations for cookie and security failures. Its security obligation overlaps with the GDPR's Article 32, so weak application security can create exposure under both regimes.
Because web and mobile applications are a leading breach vector, demonstrably securing and testing them is one of the clearest ways to meet the security obligations under ePrivacy and the GDPR.