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Technical audit · 02.05.2026

rahvastikuregister.ee

Estonia's Population Register — Addresses, Marital Status, Citizenship
EE

Almost the cleanest audit in this series: 217 requests, all on Estonian state servers, zero Google. One problem — at the most sensitive moment. When a citizen clicks 'Log in with ID card,' Cloudflare (USA) receives data from the authentication session. And this is TARA — the single sign-on gateway to ALL of Estonia's government services.

Request timeline

−3 ms · site load
All resources on www.rahvastikuregister.ee. Analytics on piwik.smit.ee (Matomo, on a Ministry of the Interior IT center server, +5855 ms). No Google, no DoubleClick, no browser-update.org.
Consent banner
Absent. Zero cookies. The site itself is clean — there's almost nothing to ask about.
Logging in via TARA
On clicking 'Log in with ID card,' static.cloudflareinsights.com loads on tara.ria.ee. A POST to /cdn-cgi/rum — 939 bytes to Cloudflare (USA): where the visitor came from, what they started doing (auth/init), a pageloadId, device characteristics.

Declared versus actual

+ Cloudflare Insights on tara.ria.ee — the only one, but at the most critical point — not declared

Transfer timings

+0 ms tara.ria.ee/auth/init

The start of ID-card authentication

+5855 ms piwik.smit.ee

Matomo on SMIT's state server (Estonia) — a plus

No exact timing

on login static.cloudflareinsights.comThe beacon loads on tara.ria.ee — the only external tracker
on login tara.ria.ee/cdn-cgi/rumA 939-byte POST carrying authentication-session data, to the USA

Detected trackers

Indicators of GDPR non-compliance

Context

rahvastikuregister.ee is Estonia’s Population Register: the addresses of every resident, marital status, citizenship, family ties. Authentication runs via ID card through the TARA system. HAR: 217 requests, 5 domains, one external.

What is done correctly — almost everything

All resources on the proprietary domain. Analytics run through Matomo on piwik.smit.ee, a server operated by the Estonian Ministry of the Interior’s IT center (a state server). Authentication runs through TARA and GovSSO, RIA’s state infrastructure. No Google, no DoubleClick, no browser-update.org. This is one of the cleanest results in this series — alongside eesti.ee, rajaleidja.ee, edpb.europa.eu, and europark.ee.

One problem — but at the most sensitive point

static.cloudflareinsights.com loads on tara.ria.ee. That is, at the moment a citizen clicks “Log in with ID card,” Cloudflare (USA) receives data from the authentication session: a POST to tara.ria.ee/cdn-cgi/rum — 939 bytes, with every request carrying where they came from (rahvastikuregister.ee), what they started doing (auth/init), a unique pageloadId, and the device’s technical characteristics.

Why this matters more than a single script

TARA is the single sign-on gateway to ALL of Estonia’s government services: the Population Register, the Tax and Customs Board, digital medical records, all state e-services. Every single time any Estonian citizen logs into any government service via ID card, Cloudflare receives an RUM beacon. The most sensitive moment — the moment of ID-card authentication — is precisely where the American tracker operates. This isn’t a problem specific to rahvastikuregister.ee, but a problem with the shared login infrastructure.

Conclusion

The site itself proves that a government service can be built 99% free of foreign trackers — and Estonia knows how to do it. That leaves 1%, and it’s easily fixed: remove Cloudflare Insights from tara.ria.ee — one script, one change, and the entire authentication chain for Estonian citizens would stay within the country. The fix is simple. The only question is whether it will be made.

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/rahvastikuregister-ee-2026-05-02.har
SHA-256: 011c08ee2c6dcb171b9db8bd16a7cc7a3c8daa48eaeb25ac3677ddcac7aabb52
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) — rahvastikuregister.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 rahvastikuregister.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) Cloudflare Insights loads on tara.ria.ee at the moment of authentication, with no consent. A POST to /cdn-cgi/rum — 939 bytes of session data to the USA.

2) Cloudflare, as a recipient of authentication-session data, is not declared.

3) No mechanism for transferring data to the USA (Cloudflare) is stated — neither SCC nor an adequacy decision.


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-rahvastikuregister-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 — rahvastikuregister.ee

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

2. Circumstances
I visited the website rahvastikuregister.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 2 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) Cloudflare Insights loads on tara.ria.ee at the moment of authentication, with no consent. A POST to /cdn-cgi/rum — 939 bytes of session data to the USA.

2) Cloudflare, as a recipient of authentication-session data, is not declared.

3) No mechanism for transferring data to the USA (Cloudflare) is stated — neither SCC nor an adequacy decision.

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

3. GDPR provisions I ask you to examine
GDPR Art. 6(1), Art. 5(1)(a); 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]