Technical audit · 14.08.2026

itk.ee

East Tallinn Central Hospital

The site of East Tallinn Central Hospital — 223 requests, 12 nodes, an 88-second recording. The Cookiebot consent platform is installed on the site, but Hotjar session recording, Google analytics and the legacy Universal Analytics start before the user's choice is recorded: Hotjar switches on at +178 ms, almost together with the consent platform itself. The attached document describes the processing of patient data, but has no section on the site, cookies and web tracking at all — the actual recipients of web data are not disclosed. In the site's favour: Facebook loads only the SDK, no pixel requests were recorded.

Request timeline

+0 ms · loading the home page
The recording begins on www.itk.ee. Served under Apache / ZoneOS. Of the security headers, only the frame-embedding ban SAMEORIGIN is set; there is no strict transport, content-security-policy, referrer policy or permissions policy. The browser was sending the DNT: 1 header.
+166…+178 ms · trackers start together with the banner
Simultaneously with the consent platform, from the markup, Google Tag Manager (GTM-NM8GSJ2), the third-party CDN jsDelivr (the swiper library) and — most importantly — Hotjar session recording (static.hotjar.com/c/hotjar-3178275.js at +178 ms) start. All are initiated by the page itself and precede any choice.
+491 ms · legacy Universal Analytics
www.google-analytics.com/analytics.js — the Universal Analytics library, retired from data processing by Google back in 2023, is still loaded by the site.
+742 ms · Facebook SDK (without the pixel)
connect.facebook.net/en_US/sdk.js — only the Facebook SDK is loaded. No requests to facebook.com/tr (pixel events) were recorded over the whole recording: the Meta pixel transmits no data.
+5693 ms · Google Analytics 4 transmits data
region1.analytics.google.com/g/collect: property G-4YVM3Y21SF, page_view event, the home page URL. The consent-mode marker gcs is absent from the request.
+19751…+87177 ms · navigation and repeated cycles
Navigation to /ru, the public documents and /ru/partnerile. On each navigation Cookiebot goes through a new cycle (uc.js, consentconfig, SDK), and Hotjar, GTM, jsDelivr, Universal Analytics and the Facebook SDK start again.

Declared versus actual

✓ Controller — AS Ida-Tallinna Keskhaigla (East Tallinn Central Hospital), registry code 10822068, Ravi 18, Tallinn; info@itk.ee — declared
✓ The attached 'Data protection terms' document describes the processing of patient data in medical and social services, hiring, participation in events — declared
✓ Legal grounds: provision of medical services, legal obligations, consent (except for statutory exceptions) — declared
✓ The rights of the data subject and the procedure for providing patient data to third parties within treatment are listed — declared
+ A section on the site, cookies and web analytics is absent from the attached document; no separate cookie policy could be found — not declared
+ Hotjar — session recording, not disclosed — not declared
+ Google Analytics 4 and Universal Analytics — not disclosed — not declared
+ Google Tag Manager, Facebook SDK, jsDelivr — not disclosed — not declared
+ Starting session recording and analytics before the choice in the consent banner is recorded — not declared

Transfer timings

+166 ms cdn.jsdelivr.net

Third-party CDN, the swiper library.

+166 ms www.googletagmanager.com

Google Tag Manager GTM-NM8GSJ2.

+178 ms static.hotjar.com

Hotjar, session recording and heatmaps, 11 requests.

+491 ms www.google-analytics.com

Universal Analytics, the legacy analytics.js library.

+742 ms connect.facebook.net

Only the Facebook SDK; no pixel /tr requests were recorded.

+5693 ms region1.analytics.google.com

GA4 G-4YVM3Y21SF, page_view, without the gcs marker.

Detected trackers

Indicators of GDPR non-compliance

Context

www.itk.ee is the site of AS Ida-Tallinna Keskhaigla (East Tallinn Central Hospital), a large Estonian medical institution with seven clinics in Tallinn. The controller is AS Ida-Tallinna Keskhaigla, registry code 10822068, Ravi 18, Tallinn. The site is served under Apache / ZoneOS; the content is in Estonian, Russian and English.

The recording: 223 requests, 12 nodes, a recording length of 88.1 seconds, taken on 14 August 2026. The recording covers the publicly accessible part of the site — the home page, the Russian version, the public-documents section and the partners page; the patient portal with authorisation is not included in the recording. Besides the main domain, the page addresses third-party recipients: the Cookiebot consent platform, Hotjar session recording, Google analytics (GA4, Universal Analytics, Tag Manager), the Facebook SDK, the third-party CDN jsDelivr and Google Fonts.

The processing of patient data is described by the attached ‘Data protection terms’ document. It should be noted separately: this document concerns the processing of personal data in the provision of medical and social services, hiring and participation in events, but has no section on the site, cookies or web analytics. No separate cookie policy for the site could be found.

Who receives data directly

Hotjar, Google (Analytics 4, Universal Analytics, Tag Manager), Facebook (SDK), jsDelivr.

Declared versus actual

A consent platform is installed, but the trackers do not depend on it. Cookiebot runs on the site: uc.js loads at +165 ms, followed by the configuration and the banner SDK. However, Hotjar session recording starts at +178 ms — almost simultaneously with the consent platform itself and earlier than the visitor could make a choice. Google Tag Manager and the third-party CDN jsDelivr go out at +166 ms, the legacy Universal Analytics library at +491 ms, and Google Analytics 4 sends page_view at +5693 ms. The order of events shows: the consent mechanism is present, but it does not block the actual loading of the trackers.

Session recording on a hospital site is the most significant finding. Hotjar records the visitor’s behaviour — cursor movements, clicks, scrolling — and builds heatmaps; 11 requests go to it over the recording. On a medical institution’s site, even the publicly accessible pages (clinic and service sections) are sensitive in a health context: the very fact of interest in them may indirectly indicate the visitor’s condition. Starting such recording before consent requires particular attention.

Facebook loads only the SDK, without the pixel — this should be said in the site’s favour. The domain connect.facebook.net delivers only sdk.js; no requests to facebook.com/tr (Meta pixel events) were recorded over the whole recording. That is, unlike the typical scenario, the Facebook pixel transmits no data about the visitor to Meta — only the SDK is present, probably for a widget or button.

Legacy analytics is still in the code. The site still loads www.google-analytics.com/analytics.js — the Universal Analytics library, which Google retired from data processing back in 2023. It transmits no data to the current analytics, but its presence in the code indicates that the web-analytics setup has long gone unreviewed.

The processing on the site is disclosed nowhere. The attached ‘Data protection terms’ document describes the processing of patient data, but says nothing about the site, cookies and web tracking. No separate cookie policy for the site could be found. Thus the actual recipients of web data — Hotjar, Google Analytics, Google Tag Manager, Facebook, jsDelivr — are named in no available document, although Cookiebot is technically present on the site.

Security headers are almost absent. Only the frame-embedding ban SAMEORIGIN is set. There is no strict transport, no content-security-policy, no referrer policy, no permissions policy. For a hospital site loading third-party session-recording and analytics code, this is an insufficient level of protection of the client side.

Proven: a consent platform is present, but the trackers start before the choice is recorded. Cookiebot loads from +165 ms; Hotjar (+178 ms), GTM and jsDelivr (+166 ms), Universal Analytics (+491 ms) and Google Analytics 4 (+5693 ms) are initiated by the markup and precede the user’s choice.

Proven: Hotjar session recording works from the first milliseconds. The requests to static.hotjar.com and script.hotjar.com are read from the recording from +178 ms; 11 requests in total over the session.

Proven: the Facebook pixel transmits no data. Over the whole recording there is only the loading of sdk.js; there are no requests to facebook.com/tr.

Proven: Google Analytics 4 sends a page_view without a consent marker. In the region1.analytics.google.com/g/collect request the gcs marker is absent, gcd=13l3l3l2l1l1.

Not proven and not asserted: the state of cookies on the device. Cookie headers and response bodies were removed from the published file during sanitisation. All conclusions rest on addresses, initiators, response codes and the composition of requests.

Separately: the browser was sending the DNT: 1 header during capture. This had no effect on the composition and addressing of the requests.

Boundaries of observation

The recording covers the publicly accessible part of the site; the patient portal with authorisation is not included in the recording, and no specific patient’s medical data appears in it. The observation records the browser’s behaviour, not the services’ internal workings: server-side processing, contractual relationships with recipients and settings on their side are not verified by a browser recording. The legal assessment is made by the competent authority — Andmekaitse Inspektsioon.

The absence of a section on the site in the attached document and the absence of a separate cookie policy were checked against the document itself and open sources; the conclusion that the recipients of web data are not disclosed is made on this basis. If the hospital has a separate, undiscovered cookie policy, this conclusion is subject to revision.

The file is published sanitised of personal data: cookie headers in requests and response bodies were removed. The conclusion that the trackers start before consent is recorded rests on the network level — the timings, addresses and initiators of the requests are read from the recording. The absence of Facebook pixel requests is established by the absence of requests to facebook.com/tr over the whole recording.

The identification of services rests on domains and address patterns: Cookiebot — by cookiebot.com and uc.js; Hotjar — by hotjar.com and the identifier hotjar-3178275; Google Analytics 4 — by analytics.google.com/g/collect and the property G-4YVM3Y21SF; Universal Analytics — by www.google-analytics.com/analytics.js; Google Tag Manager — by googletagmanager.com and the container GTM-NM8GSJ2; Facebook — by connect.facebook.net; jsDelivr — by cdn.jsdelivr.net; the serving provider — by the server: Apache / ZoneOS header.

Conclusion

The site of East Tallinn Central Hospital has installed the Cookiebot consent-management platform, but has not tied the actual loading of the trackers to its result: Hotjar session recording switches on at +178 ms, almost simultaneously with the consent platform itself, and Google Tag Manager, the third-party CDN jsDelivr, the legacy Universal Analytics and Google Analytics 4 start in the first seconds of the visit. For a medical institution’s site, starting the recording of visitor behaviour before consent is the most significant part of the picture.

In the site’s favour is that Facebook loads only the SDK: no Meta pixel requests transmitting events were recorded over the whole recording. But the processing on the site is disclosed nowhere — the attached ‘Data protection terms’ concern patients and do not mention cookies, analytics and session recording, and no separate cookie policy could be found. The security headers are almost absent.

Remediation: make the actual loading of Hotjar session recording, Google Analytics and other analytics scripts conditional on the user’s choice in Cookiebot, so that they do not start before consent; publish a cookie policy naming all recipients of web data individually — Hotjar, Google Analytics, Google Tag Manager, Facebook, jsDelivr — with the purposes and, for session recording, a separate basis; remove the legacy Universal Analytics library from the code; host the swiper library on the own infrastructure, eliminating the transmission of the IP address to a third-party CDN; set strict transport, a content-security-policy, a referrer policy and a permissions policy.

Evidence

How to verify: download the file and compute its checksum — sha256sum file.har (Linux, macOS) or certutil -hashfile file.har SHA256 (Windows); it must match the one shown. The conclusions apply to the scope of this measurement — see the limitations of the method.

Original (audit)
HAR file: ee/itk-ee-2026-08-14.har
SHA-256: 38432a493935508f5a2b97204ba5d76071e783533018e1f55a7cf3556154dae6
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.