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Technical audit · 04.05.2026

prokuratuur.ee

The Prosecutor's Office
EE

A prosecution authority handling data on suspects, victims, and witnesses (GDPR Art. 10). The policy states plainly: 'visitor data is not collected.' The HAR records 116 requests to Google in a single session — a record for this series. No previous site in this series has sent Google that much data in one session.

Request timeline

+1253 ms · on load
www.google.com (status 200), followed by maps.googleapis.com and maps.gstatic.com (+1472 ms). The Prosecutor's Office map is embedded via standard Google Maps — no lazy loading, no privacy mode, automatic.
Consent banner
Absent. Zero consent requests, zero Set-Cookie. The transfer to Google occurs automatically on every visit.
116 requests to Google per session
maps.googleapis.com — 77 requests, www.google.com — 29, Google Fonts — 10. IP address, browser, time, behavior on the map — all go to Google. A record for this series.

Declared versus actual

✓ Google Analytics (_ga, _gid, _gat) — absent from the HAR — declared
✓ AddThis (__atuvc, __atuvs) — discontinued by Oracle in 2023, absent from the HAR — declared
✓ 'Visitor data is not collected' — declared
+ Google Maps API — 116 requests to Google per session — not declared
+ Google Fonts — IP address to the USA — not declared

Transfer timings

+1253 ms www.google.com

29 requests per session, status 200

+1472 ms maps.googleapis.com

77 requests. A public API key is visible in the HTML — a paid Maps Platform account

No exact timing

per session fonts.googleapis.com + gstaticGoogle Fonts, 10 requests. IP address to the USA
on load statistika.rik.ee (Matomo)Analytics on RIK's state server — a plus

Detected trackers

Indicators of GDPR non-compliance

Context

Riigiprokuratuur — the Prosecutor’s Office of Estonia, the criminal prosecution authority: it investigates crimes, files charges, and represents the state in court. It handles data on suspects, victims, and witnesses. This falls under GDPR Art. 10 — data on criminal convictions and offenses, a specially sensitive category. HAR: 229 requests, 10 domains.

What is done correctly

Analytics run through Matomo on the state server statistika.rik.ee (5 requests, status 200); data stays within Estonia. Cloudflare Insights and browser-update.org are blocked by the CSP (status 0). But there’s a nuance: statistika.rik.ee is operated by RIK — the same organization whose own site, rik.ee, transmits data to Google via 30 Google Fonts requests per session, and whose policy declares Cloudflare and AddThis, neither of which is present, while saying nothing about Google Fonts, which is. One operator, two standards.

A record for this series — 116 requests to Google

The Prosecutor’s Office map is embedded via standard Google Maps: no lazy loading, no consent, no privacy mode, loading automatically on page open. maps.googleapis.com — 77 requests, www.google.com — 29, Google Fonts — 10. A total of 116 requests to Google in a single session — more than any other site in this series. Google receives the user’s IP address, browser, time, and map interaction behavior on every visit. A public API key is visible in the HTML — this is not a free embed, but a paid Google Maps Platform account, meaning it is a deliberate commercial integration.

Declaration versus fact — three discrepancies

The policy was updated in 2023, is detailed and well-structured — which makes each discrepancy all the more precise. It states plainly: “Information about visitors to the Prosecutor’s Office website is not collected, and their data is not published” — against 116 requests to Google in the HAR. It declares Google Analytics (_ga, _gid, _gat) — not a single request to which appears in the HAR. And it declares AddThis (__atuvc, __atuvs) — a service discontinued by Oracle in May 2023, three months before the policy was updated.

The Oracle trail

AddThis belonged to Oracle, which acquired it in 2016: “share” buttons on millions of sites collected behavioral data and fed it to Oracle Data Cloud — one of the world’s largest data brokers (profiles on billions of people, thousands of attributes per profile). Oracle discontinued AddThis in May 2023, but the data collected through it remained in Oracle Data Cloud profiles, and not a single government site that used AddThis notified users of what became of their data. The danger here lies in invisibility: Google is visible to the user, while Oracle operates in the shadows through partner networks. The same dead AddThis appears in the policies of sotsiaalkindlustusamet.ee and president.ee — a state-wide template, copied without a currency check.

The fix — one replacement

Google Maps can be replaced with OpenStreetMap + Leaflet.js — an open-source European alternative: free, zero transfer to Google, zero API keys, zero of the 116 requests. Used by thousands of European government portals specifically for GDPR compliance.

Conclusion

The Prosecutor’s Office’s policy says: visitor data is not collected. The HAR says: 116 requests to Google in a single session, on every page visit. One sentence against one hundred and sixteen lines of data. On the website of a criminal prosecution authority, in the context of GDPR Art. 10, this is not a formality — it is a question of trust in the body that prosecutes on behalf of the state.

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/prokuratuur-ee-2026-05-04.har
SHA-256: 4ceee195c3550486579ded680d759eb74a00245d6a762eaf5face69768254203
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
Want a response from the company about this audit? → Open the tool

Fill in once — it will be inserted into every letter below:

All fields are required to print the document — this is a formal requirement of the letter itself (the particulars of an official submission), not data collection: nothing is sent or saved anywhere, it all stays in your browser and disappears when you close the page. See the methodology for details.

Step 1. Data access request (GDPR Art. 15)

Send this letter directly to the company first — before contacting the regulator it has the right to respond (GDPR Art. 12(3) — 30 days).

Subject: Data access request (GDPR Art. 15) — prokuratuur.ee

To: [insert the company's address — DPO / support / legal department]
From: [Your name], [contact email]

I request access to my personal data processed in connection with the website prokuratuur.ee.

1. Categories of data and purposes of processing (Art. 15(1)(a)-(c))
Based on an independent technical analysis of the site, I request confirmation and detailed disclosure of the following categories of processing:

1) A direct contradiction. The policy states: 'Information about visitors to the Prosecutor's Office website is not collected.' The HAR: 116 requests to Google in a single session, on every page visit.

2) 116 data transfers to Google with no legal basis. Google Maps is embedded in the standard way, loading automatically on page open, with no consent.

3) There is no consent mechanism. Zero consent requests, zero Set-Cookie.

4) Google Maps is not declared as a recipient. Google Analytics is declared (_ga, _gid, _gat) but absent from the HAR. AddThis is declared, but was discontinued by Oracle in May 2023.

5) No mechanism for transferring data to the USA (Google) is stated. The transfer with no SCC is unlawful.


2. Recipients, retention periods, and transfers outside the EEA (Art. 15(1)(c)-(d), 46)
I also request the full list of third-party recipients, the applicable retention period for each category, and the legal basis for any transfer of data outside the EEA. The full technical audit with evidence (saved network log, SHA-256 checksum) is published at: https://gdpru.eu/en/audits/ee-prokuratuur-ee/

3. Automated processing and profiling (Art. 15(1)(h))
Please state whether I am subject to automated decision-making or profiling, and if so, disclose the logic involved.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]
IMPORTANT: before filing a complaint with the regulator, first contact the company directly and give it 30 days to respond. Without this step the regulator may reject the complaint. Details and a template letter to the company are in the Methodology.
Ready-to-send complaint letter

Where to file: Estonian Data Protection Inspectorate (AKI) — write to info@aki.ee

Important: AKI only handles submissions in Estonian. Translate the letter before sending.

The regulator reviews complaints in its national language. There is an officially translated template from the European Data Protection Board (EDPB) — you can use it instead of or alongside this letter: Official EDPB complaint form (PDF, your language)

Subject: Complaint regarding personal data processing — prokuratuur.ee

1. Subject of the complaint
I am filing a complaint regarding the processing of my personal data by the website prokuratuur.ee.

2. Circumstances
I visited the website prokuratuur.ee and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 4 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) A direct contradiction. The policy states: 'Information about visitors to the Prosecutor's Office website is not collected.' The HAR: 116 requests to Google in a single session, on every page visit.

2) 116 data transfers to Google with no legal basis. Google Maps is embedded in the standard way, loading automatically on page open, with no consent.

3) There is no consent mechanism. Zero consent requests, zero Set-Cookie.

4) Google Maps is not declared as a recipient. Google Analytics is declared (_ga, _gid, _gat) but absent from the HAR. AddThis is declared, but was discontinued by Oracle in May 2023.

5) No mechanism for transferring data to the USA (Google) is stated. The transfer with no SCC is unlawful.

Full technical documentation is published at: https://gdpru.eu/en/audits/ee-prokuratuur-ee/

3. GDPR provisions I ask you to examine
GDPR Art. 5(1)(a); GDPR Art. 6(1); GDPR Art. 7; GDPR Art. 13(1)(e); GDPR Art. 13(1)(f), Chapter V

4. Request
I request that you examine the circumstances described and, if non-compliance is confirmed, apply the measures provided for in Article 58(2) GDPR.

5. Attachments
The full evidence base — the HAR file, its SHA-256 checksum and the quotation from the site's privacy policy documenting the stated contradiction — is published and verifiable at the link in point 2 above.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]