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Tag Management Systems were developed in order to support website publishersin installing multiple third-party JavaScript scripts (Tags) on their websites.In 2012, Google developed its own TMS called "Google Tag Manager" (GTM) that iscurrently present on 28 million live websites. In 2020, a new "Server-side" GTMwas introduced, allowing publishers to include Tags directly on the server.However, neither version of GTM has yet been thoroughly evaluated by theacademic research community. In this work, we study, for the first time, thetwo versions of the Google Tag Management (GTM) architectures: Client- andServer-side GTM. By analyzing these systems with 78 Client-side Tags, 8Server-side Tags and two Consent Management Platforms (CMPs) from the inside,we discover multiple hidden data leaks, Tags bypassing GTM permission system toinject scripts, and consent enabled by default. With a legal expert, we performan in-depth legal analysis of GTM and its actors to identify potential legalviolations and their liabilities. We provide recommendations and proposenumerous improvements for GTM to facilitate legal compliance.

Google Tag Manager: Hidden Data Leaks and its Potential Violations under EU Data Protection Law