The website of the body that passes laws — including personal data protection laws. Google Tag Manager fires at +2.7 seconds, while the consent banner only loads at +173 seconds. A 170.5-second gap: throughout that time, Google is already receiving visit data, while the user hasn't even seen the banner yet.
Timeline of the leak
Declared versus actual
Transfer timings
Google reCAPTCHA — 42 + 26 requests per session
GTM-5BFRTZC — 170 sec before the banner. Data to the USA
The banner appears after 173 seconds. Gap with GTM — 170.5 sec
Cloudflare Insights, 6 requests. Absent from the policy
'Share' buttons, 2 requests to the USA. Absent from the policy
Detected trackers
- Google Tag Manager
- Google reCAPTCHA
- Google Analytics
- Cloudflare Insights
- AddToAny
- Google Fonts
Indicators of GDPR non-compliance
- GDPR Art. 7(2), Art. 4(11)The 'Functional cookies' category is enabled by default — the toggle is green with no user action. Pre-checked consent is invalid (CJEU ruling in Planet49, 2019).
- GDPR Art. 6(1), Art. 5(1)(a)Google Tag Manager (GTM-5BFRTZC, +2.7 sec) and reCAPTCHA (+2.6 sec) fire 170 seconds before the consent banner loads.
- GDPR Art. 5(1)(a)A false claim of anonymity: the 'Performance' category (which includes Google Analytics) is described as 'not storing personal data.' GA transmits the IP address and assigns a unique identifier — both of which are personal data.
- GDPR Art. 13(1)(e)GTM, reCAPTCHA, Cloudflare Insights, AddToAny, Google Fonts, and the actual Google cookies (_Secure-1PSID, _Secure-3PSID, SAPISID, NID, HSID, APISID, SID, SSID, SIDCC) are not declared.
- GDPR Art. 13(1)(f), Chapter VNo transfer mechanism to Google or Cloudflare (USA) is stated for either recipient.
- GDPR Art. 9 (potentially)Web eID (ID card, Mobile-ID) is integrated into the site. In the same session where a citizen logs in under their real name, undeclared Google trackers are running. This requires separate legal justification.
Context
riigikogu.ee is the official website of Estonia’s supreme legislative body. HAR: 587 requests per session, 7 unique external domains, 129 third-party requests. This is the website of the body that passes laws — including personal data protection laws.
The consent banner — better, but flawed
The site has “Accept,” “Reject all,” and “Save” buttons — a reject option exists, which is better than mil.ee. But the “Functional cookies” category is enabled by default: the toggle is green with no user action whatsoever. Under Art. 7(2) and Art. 4(11), consent must be an active action, and pre-checked toggles are invalid — directly confirmed by the CJEU’s Planet49 ruling (2019). Additionally, the “Performance” category (which includes Google Analytics) is described as “not storing personal data,” which is legally incorrect: GA transmits the IP address and assigns a unique identifier, both of which are personal data.
A 170-second gap
Google Tag Manager (GTM-5BFRTZC) fires 2.7 seconds after load, reCAPTCHA at +2.6 seconds (42 requests to gstatic.com, 26 to google.com). Meanwhile, the consent banner (the GDPR plugin) only loads at +173 seconds — nearly three minutes in. GTM and reCAPTCHA beat the banner’s appearance by 170.5 seconds. While the user is reading the page, having not yet seen any banner, Google has already received data about their visit. After interacting with the banner, Cloudflare Insights, AddToAny, and Google Fonts (46 requests, each transmitting the IP address to Google) are added — not one of them declared.
Declaration versus fact
The cookie policy declares Cloudflare (_cf_bm, _cfuvid), Google Analytics (_ga, _gid, _gat), and PHPSESSID. Absent: Google Tag Manager, reCAPTCHA, Cloudflare Insights, AddToAny, Google Fonts, and the actual full list of Google cookies (_Secure-1PSID, _Secure-3PSID, SAPISID, NID — 745 bytes, HSID, APISID, SID, SSID, SIDCC) — not one is listed. Under Art. 13(1)(e), the data subject is entitled to know all recipients of their data.
The eID context
Estonian electronic identification is integrated into the Parliament’s website — citizens can authenticate via ID card or Mobile-ID. In the same session where a citizen logs in under their real name, undeclared Google trackers are running, and GTM fires 170 seconds before the consent banner. This requires separate legal justification under GDPR Art. 9.
Conclusion
Estonia teaches the whole world about digital government — other countries come to study its experience, journalists write articles, conferences and awards follow. And on the website of this country’s Parliament, Google receives visitor data 170 seconds before visitors even see the consent banner. GTM at +2.7 sec, the GDPR plugin at +173.2 sec — a 170.5-second gap; it’s simple arithmetic, and that’s the power of a HAR file. A country that exports the model of digital government should be able to configure a consent banner on the website of its own Parliament.
923598723b82f8ca61bff3d879be5f00098f86783e76ad91e1a30f084c0c3effWhere 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 riigikogu.ee. 2. Circumstances I visited the website riigikogu.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 11 April 2026 (open methodology, reproducible measurements) documents the following indications: 1) The 'Functional cookies' category is enabled by default — the toggle is green with no user action. Pre-checked consent is invalid (CJEU ruling in Planet49, 2019). 2) Google Tag Manager (GTM-5BFRTZC, +2.7 sec) and reCAPTCHA (+2.6 sec) fire 170 seconds before the consent banner loads. 3) A false claim of anonymity: the 'Performance' category (which includes Google Analytics) is described as 'not storing personal data.' GA transmits the IP address and assigns a unique identifier — both of which are personal data. 4) GTM, reCAPTCHA, Cloudflare Insights, AddToAny, Google Fonts, and the actual Google cookies (_Secure-1PSID, _Secure-3PSID, SAPISID, NID, HSID, APISID, SID, SSID, SIDCC) are not declared. 5) No transfer mechanism to Google or Cloudflare (USA) is stated for either recipient. 6) Web eID (ID card, Mobile-ID) is integrated into the site. In the same session where a citizen logs in under their real name, undeclared Google trackers are running. This requires separate legal justification. Full technical documentation is published at: https://gdpru.eu/en/audits/ee-riigikogu-ee/ 3. Provisions violated GDPR Art. 7(2), Art. 4(11); GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 5(1)(a); GDPR Art. 13(1)(e); GDPR Art. 13(1)(f), Chapter V; GDPR Art. 9 (potentially) 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]