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Technical audit · 2026-08-16

www.ria.ee

Estonian State Information System Authority
EE

The Estonian State Information System Authority, responsible for the state's cybersecurity, — 173 requests, 7 nodes, a 107-second recording. On its own site the authority loads a third-party script from the browser-update.org domain and fonts from the third-party CDN use.fontawesome.com, to which the visitor's IP address and referrer are sent, and includes both domains in its own content-security-policy. Third-party Cloudflare Insights analytics and the own Matomo counter also run. There is no consent mechanism, and none of the third-party recipients is named individually in the cookie policy.

Timeline of the leak

+0 ms · loading the page
The recording begins on www.ria.ee. Served through Cloudflare (cf-ray, server: cloudflare). Set: strict transport with a one-year term, the frame-embedding ban DENY, the content-type-sniffing ban, the referrer policy origin-when-cross-origin and a detailed content-security-policy with an allow-list. There is no permissions policy. The browser was sending the DNT: 1 header.
+180 ms · third-party font CDN
From the page markup, use.fontawesome.com starts — a third-party CDN for Font Awesome fonts and icons. Over the session 24 requests go to it; each transmits the referrer https://www.ria.ee/ and the visitor's IP address.
+200 ms · Matomo
A request to matomo.ria.ee — the own visit counter on RIA infrastructure, cookies _pk_id and _pk_ses.
session state — no consent mechanism
Across 173 requests no request to a consent-management platform, no script bearing the marks of a banner, and no Set-Cookie header was found. The analytics and third-party scripts are initiated by the page markup and start before any user choice.
+341…+479 ms · chatbot
buerokratt.ria.ee (widget_bundle.js) and ruuter.buerokratt.ria.ee are loaded — the own state chatbot Bürokratt.
+592 ms · third-party performance analytics
static.cloudflareinsights.com — a third-party Cloudflare performance counter, five requests.
+607 ms · the third-party browser-update.org script
browser-update.org/update.min.js is loaded — the script of an outdated-browser notification widget. The initiator is the site's own combined script file. The request transmits the referrer https://www.ria.ee/ and the visitor's IP address. The domain is included in the site's content-security-policy script-src. Five requests over the session.

Declared versus actual

✓ Controller — the State Information System Authority (RIA); cookie policy and terms of personal-data processing — заявлен
✓ Strictly necessary cookies are listed; the analytics cookies _pk_id (13 months) and _pk_ses (30 min) collect statistics on site use — заявлен
✓ Marketing cookies are not used on the site (stated outright) — заявлен
✓ Unclassified cookies are not used on the site — заявлен
✓ Third-party sites (for example, Google Maps) may use their own cookies; RIA does not control them; links to the terms of Google, Facebook, LinkedIn are provided — заявлен
✓ When visiting, the following are collected: IP address, page visited, browser and OS, time of visit, device, window size, language, provider, domain, region; the IP address is not linked to identifying information — заявлен
✓ Cloudflare is mentioned in the context of the site's mechanisms — заявлен
+ browser-update.org — third-party widget script carrying the IP address and referrer, not named — не заявлен
+ use.fontawesome.com — third-party CDN for fonts and icons, not named — не заявлен
+ Cloudflare Insights — third-party performance analytics, not named — не заявлен
+ Matomo — the counter is disclosed by cookie name, but the tool itself is not named individually — не заявлен
+ The inclusion of browser-update.org and use.fontawesome.com in the own content-security-policy — не заявлен

Transfer timings

+180 ms use.fontawesome.com

CDN for fonts and icons, the referrer and IP address go out, 24 requests.

+200 ms matomo.ria.ee

Own Matomo counter, cookies _pk_id, _pk_ses.

+592 ms static.cloudflareinsights.com

Cloudflare performance analytics, five requests.

+607 ms browser-update.org

Third-party update.min.js script; the www.ria.ee referrer and IP address go out, five requests.

Detected trackers

Indicators of GDPR non-compliance

Context

www.ria.ee is the site of the Estonian State Information System Authority (Riigi Infosüsteemi Amet, RIA), the state body responsible for the development and protection of the digital-state infrastructure and for the country’s cybersecurity. The site is served through Cloudflare (cf-ray, server: cloudflare); the content is in Estonian and Russian.

The recording: 173 requests, 7 nodes, a recording length of 106.8 seconds, taken on 16 August 2026. Of the seven nodes, some are the own infrastructure: the main domain, Matomo on matomo.ria.ee, the chatbot on buerokratt.ria.ee and ruuter.buerokratt.ria.ee. The third-party recipients outside the ria.ee domain are use.fontawesome.com (font CDN, 24 requests), static.cloudflareinsights.com (analytics, 5 requests) and browser-update.org (third-party script, 5 requests). The session runs across several pages of the electronic-identity section.

The processing is described by the RIA cookie policy together with the terms of personal-data processing: categories of cookies (strictly necessary, analytics, marketing, unclassified), a section on third-party cookies, a section on visiting the site.

Who receives data directly

browser-update.org, use.fontawesome.com, Cloudflare Insights.

Declared versus actual

The state cybersecurity authority loads a third-party script from an advertising domain. The first request to browser-update.org/update.min.js goes out at +607 ms, the initiator being the site’s own combined script file. The request transmits the referrer https://www.ria.ee/ and the visitor’s IP address. This is the same domain that features in a separate analysis as a site deploying an advertising stack on pages with an ad slot. Here the widget delivered only update.min.js, but what is essential is that the browser-update.org domain is entered in the script-src of the site’s own content-security-policy: the authority has, in a trusted manner, allowed an external mutable source to execute code on its page.

Fonts and icons are loaded from a third-party CDN. use.fontawesome.com — a third-party Font Awesome CDN — serves 24 requests over the session, starting first, at +180 ms. Each transmits the referrer https://www.ria.ee/ and the visitor’s IP address. Fonts and icons can be hosted on the own infrastructure; external loading transmits the visitor’s data to a third-party node without necessity.

Analytics is partially disclosed. The cookie policy describes the analytics cookies _pk_id and _pk_ses — this is the Matomo counter — with the source ria.ee and the purpose of collecting statistics. That is, analytics as a function is disclosed, but the tool Matomo itself is not named individually. Marketing cookies are declared by the policy to be unused outright. However, the third-party performance analytics Cloudflare Insights running on the site does not appear in the list.

Not a single third-party recipient is named individually. The section on third-party cookies is worded in general terms: the site may use content from other sites (an example being Google Maps) and redirect to other resources that set their own cookies. But this is about external links and embedded content, not about an actively loaded third-party script and font CDN. Neither browser-update.org, nor use.fontawesome.com, nor Cloudflare Insights is named in the policy.

Security headers are set solidly, but with a caveat. The site sets strict transport, the frame-embedding ban DENY, the content-type-sniffing ban and a detailed content-security-policy. But the allow-list includes not only the own nodes and Matomo, but also browser-update.org, use.fontawesome.com, and — as declared, though not fired in this recording — Google Analytics, Google Tag Manager, DoubleClick, Siteimprove, jsDelivr. There is no permissions policy, and the referrer policy origin-when-cross-origin leaves the source www.ria.ee in the referrer header of third-party requests.

Proven: there is no consent mechanism on the site. Across 173 requests there is not a single request to a consent-management platform, not a single script bearing the marks of a banner, not a single Set-Cookie header.

Proven: the third-party scripts start from the markup, without the user’s choice. The third-party CDN fonts are requested at +180 ms, Matomo at +200 ms, browser-update.org at +607 ms — all initiated by the markup and scripts of the page itself.

Proven: the IP address and referrer go to browser-update.org and use.fontawesome.com. The referrer header in the requests to both contains https://www.ria.ee/; the IP address is transmitted by the very fact of the network request. Both domains are entered in the content-security-policy.

Not proven and not asserted: the deployment of the browser-update.org advertising stack on the ria.ee site. In this recording the widget delivered only update.min.js; no requests to advertising recipients from the ria.ee domain were recorded. What is recorded is the fact of loading the third-party script and transmitting the referrer and IP address to it.

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.

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 several pages of the site. 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.

A number of nodes are entered in the content-security-policy but did not fire in this recording: Google Analytics, Google Tag Manager, DoubleClick, Siteimprove, YouTube. They are recorded as CSP-declared dependencies, but not as actually transmitting data, and do not enter the analysis of violations on the basis of actual transmission. Matomo and Bürokratt are hosted on RIA infrastructure and are not treated as third-party commercial recipients.

The file is published sanitised of personal data: cookie headers in requests and response bodies were removed. The conclusion that there is no consent mechanism rests on the network level — the composition, addresses and initiators of all 173 requests are read from the recording, and among them there is neither a consent platform nor its marks; the loading of the third-party scripts is initiated by the markup and precedes any user choice.

The identification of services rests on domains and address patterns: browser-update.org — by the domain and the update.min.js file included in script-src; use.fontawesome.com — by the domain and the paths releases/v6.4.0/css; Cloudflare Insights — by cloudflareinsights.com; Matomo — by matomo.ria.ee and the cookies _pk_id, _pk_ses; Bürokratt — by buerokratt.ria.ee; the serving provider — by the cf-ray and server: cloudflare headers.

Conclusion

The site of the Estonian authority responsible for the state’s cybersecurity loads on its pages a third-party script from the browser-update.org domain and fonts from the third-party CDN use.fontawesome.com, to which the visitor’s IP address and referrer are sent on every load, and enters both domains in its own content-security-policy. Third-party Cloudflare Insights performance analytics and the own Matomo counter also run.

The cookie policy discloses the Matomo analytics cookies by file name and states outright that marketing cookies are not used, but names neither browser-update.org, nor use.fontawesome.com, nor Cloudflare Insights, nor Matomo itself individually. There is no consent mechanism on the site at all, although analytics cookies, per the regulator’s practice, require prior consent.

Remediation: remove the third-party browser-update.org script and remove that domain from the trusted content-security-policy list; move the Font Awesome fonts and icons to the own infrastructure, eliminating the transmission of the referrer and IP address to a third-party CDN; abandon the third-party Cloudflare Insights analytics in favour of the own Matomo, or disclose it as a recipient; name all actual recipients of web data in the cookie policy individually, including Matomo; introduce a consent mechanism that actually governs the loading of analytics and third-party scripts, with the option to refuse before they start; review the content-security-policy allow-list, excluding external sources not used for their purpose.

Evidence
Original (audit)
HAR file: ee/ria-ee-2026-08-16.har
SHA-256: f274e8569269c67f6ff43d79048244992126e4f3b19c18d0d00362d7d353f9bf
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
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.

To: Estonian Data Protection Inspectorate (AKI)
From: [Your name], [contact email]

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

2. Circumstances
I visited the website www.ria.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 16 August 2026 (open methodology, reproducible measurements) documents the following indications:

1) The authority responsible for the state's cybersecurity loads on its site a third-party script from the browser-update.org domain and fonts from the third-party CDN use.fontawesome.com, as well as the third-party counter Cloudflare Insights. All three receive the IP address and referrer of the www.ria.ee visitor. The cookie policy describes analytics cookies (_pk_id, _pk_ses of the Matomo counter) and mentions third-party sites in general terms, but neither browser-update.org, nor use.fontawesome.com, nor Cloudflare Insights, nor Matomo itself is named individually.

2) There is no consent mechanism on the site: across 173 requests there is not a single request to a consent-management platform, not a single script bearing the marks of a banner, not a single Set-Cookie header. The Matomo counter starts from the markup at +200 ms, the third-party browser-update.org script at +607 ms, the third-party CDN fonts at +180 ms, all before any user choice. The cookie policy describes analytics cookies as set to collect statistics, but provides no mechanism for obtaining consent to them.

3) The site of the state cybersecurity authority includes the domains browser-update.org and use.fontawesome.com in its own content-security-policy and loads executable code and fonts from them. The browser-update.org domain, as a separate analysis shows, deploys an advertising stack on pages with an ad slot; here the widget delivered only update.min.js, but the inclusion of an external mutable source in the trusted list means that the composition of the loaded code is determined by a third party. The fonts and icons, moreover, can be hosted on the own infrastructure, as is done with other resources.

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

3. Provisions violated
GDPR Art. 13(1)(e) — disclosure of recipients; ePrivacy — Directive 2002/58/EC, Art. 5(3) (in conjunction with GDPR Art. 6(1)(a)); GDPR Art. 5(1)(c) — minimisation and control over the supply chain

4. Request
I request that you investigate the violations described and 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.

[Date]                                    [Signature / name]