LG Munich: Google Fonts and GDPR

LG Munich: Google Fonts and GDPR

In January 2022, the Regional Court of Munich (Landgericht Munich) issued a landmark ruling that sent ripples through the web development community. The court found that a website operator violated GDPR by loading Google Fonts directly from Google's servers, which transmitted the visitor's IP address to Google without prior consent. The ruling resulted in a damages award to the affected user and established an important precedent for how European websites handle third-party resources.

What the Court Decided

The court ruled that loading Google Fonts from Google's CDN (content delivery network) constitutes a transfer of personal data (specifically, the user's IP address) to Google in the United States. Since this transfer occurred without the user's consent and without a valid legal basis, it violated GDPR. The court emphasized that the website operator could have hosted the fonts locally, avoiding any data transfer to Google entirely.

The ruling specifically noted that the website operator could not rely on "legitimate interest" as a legal basis for the data transfer, because a less invasive alternative (self-hosting the fonts) was readily available. This reasoning has significant implications because it applies the principle of data minimization: if you can achieve the same result without transferring personal data, you are expected to choose that path.

Why This Matters Beyond Fonts

While the ruling specifically addressed Google Fonts, the underlying principle extends to any third-party resource loaded from external servers. Every time your website makes a request to a third-party server, the user's IP address is transmitted to that server. This means the same logic applies to:

• JavaScript libraries loaded from CDNs (such as jQuery from a Google or Cloudflare CDN).
• Embedded YouTube videos, Google Maps, and other interactive elements.
• Social media widgets and sharing buttons that load scripts from Facebook, Twitter, or LinkedIn servers.
• Analytics scripts loaded directly from third-party servers. The IMY ruling on Google Analytics addressed similar concerns.
• Advertising pixels and tracking scripts from ad networks.
• Icon libraries and other design resources hosted on external servers.

Each of these integrations potentially triggers the same GDPR concerns that the Munich court identified with Google Fonts. The scope of the ruling, when applied broadly, affects the majority of websites operating in Europe.

Implications for Website Operators

The ruling created urgency for website operators across Europe to audit and remediate their use of externally hosted resources. Any website loading Google Fonts or similar external resources from third-party servers may be transferring personal data without consent. Self-hosting fonts and other resources eliminates this risk entirely and is straightforward to implement in most cases.

Following the ruling, a wave of mass-generated demand letters (known as "abmahnungen" in German) targeted website operators who were still loading Google Fonts externally. While the legal standing of these mass demands has been debated, they underscore the practical risks of non-compliance.

What You Should Do

Take the following steps to ensure your website is compliant:

1. Audit your website for externally loaded resources, particularly Google Fonts. Use browser developer tools to inspect network requests and identify any calls to external domains during page load.
2. Switch to self-hosted versions of any fonts your site uses. Google Fonts can be downloaded and hosted on your own server with minimal effort.
3. Review other third-party integrations that load resources from external servers and assess whether they transfer personal data without consent.
4. For third-party resources that cannot be self-hosted, implement a consent mechanism that blocks the resource until the user provides explicit consent. A solid understanding of cookies helps with this process.
5. Document your audit and the changes you have made for compliance records.

The Broader Lesson

This ruling underscores the importance of a privacy-by-design approach to web development, where data minimization is considered from the start rather than as an afterthought. When building or updating your website, ask whether each external resource is truly necessary and whether it can be replaced with a self-hosted alternative. This proactive approach reduces both legal risk and the complexity of your consent management requirements.