The supreme financial oversight authority, which audits every government body in the country, copied its privacy policy from the Ministry of Finance and didn't even change the cookie-source name. The body that audits everyone else would fail its own audit.
Timeline of the leak
Declared versus actual
Transfer timings
Google Fonts, 3 requests, status 200. Data to the US
Atkinson Hyperlegible font, 3 requests. IP to Google
No exact timing
Detected trackers
- Google Fonts
- Google Tag Manager (blocked by CSP)
- Cloudflare Insights (blocked by CSP)
- browser-update.org (blocked by CSP)
Indicators of GDPR non-compliance
- GDPR Art. 6(1), Art. 5(1)(a)Google Fonts (fonts.googleapis.com, fonts.gstatic.com — 6 requests) loads with no legal basis, transmitting the user's IP to Google on every page navigation.
- GDPR Art. 13(1)(e)Google Fonts is not disclosed as a recipient. AddThis is disclosed but was shut down by Oracle in 2023. Google Analytics is disclosed but is absent from the HAR.
- GDPR Art. 13(1)(f), Chapter VThe mechanism for transferring data to the US (SCC) is not specified.
- GDPR Art. 12(1)The privacy policy was copied from the Ministry of Finance's site: every cookie in the table lists www.rahandusministeerium.ee as its source. The information does not pertain to the actual controller.
Context
Riigikontroll is Estonia’s supreme financial oversight authority, independent of the government. It reviews the legality and efficiency of public-fund use and audits every government body, including the ministries — essentially, the body that oversees everyone else. HAR: 89 requests, 7 domains.
What’s done right
The CSP works: three of four external services are blocked. Google Tag Manager (G-NZ5VEKEN0D) is written into the code but did not execute — status 0. Cloudflare Insights — status 0, no data went out. browser-update.org — status 0. cdnjs.cloudflare.com returned a 404, but the request still went out, transmitting the user’s IP to Cloudflare.
What isn’t done
Google Fonts remains unblocked: fonts.googleapis.com (+400 ms) and fonts.gstatic.com (+426 ms) — 6 requests, status 200, the Atkinson Hyperlegible font. The user’s IP goes out to Google (US) on every page navigation. There is no consent banner at all — zero consent requests, zero Set-Cookie headers.
Declared versus actual
The policy declares Google Analytics (cookies _ga, _gid, _gat), but there isn’t a single request to it in the HAR — this is now the fourth case in the series where a nonexistent GA has been declared (after sotsiaalkindlustusamet.ee, rik.ee, president.ee). It declares AddThis (__atuvc, __atuvs) — a service shut down by Oracle in May 2023. Meanwhile, Google Fonts, which is actually running, isn’t mentioned in the policy at all, and a separate clause states that no user data is transmitted in connection with Google Search — formally true regarding search, but silent on the fonts that transmit IP to Google on every page load.
The key finding — copy-pasted from the Ministry of Finance
Every cookie in the policy’s table lists www.rahandusministeerium.ee as its source — that’s the Ministry of Finance’s site, not the State Audit Office’s. This isn’t a typo — it’s evidence the policy was copied from the Ministry of Finance’s site and posted on riigikontroll.ee without adaptation — they didn’t even change the cookie-source name. The body that reviews the legality of actions across every government structure, including the Ministry of Finance itself, used that ministry’s own policy as a template, without checking its currency or adapting it to its own site. Under GDPR Art. 12(1), information must be accurate and pertain to the specific controller.
Conclusion
Technically, the site is reasonably well protected — the CSP blocks most trackers. But the privacy policy is disconnected from reality on every count: it declares things that don’t exist (GA, AddThis), stays silent about things that do (Google Fonts), and on top of that was copied from someone else’s site. The body that audits others would fail its own audit.
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 riigikontroll.ee. 2. Circumstances I visited the website riigikontroll.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 12 April 2026 (open methodology, reproducible measurements) documents the following indications: 1) Google Fonts (fonts.googleapis.com, fonts.gstatic.com — 6 requests) loads with no legal basis, transmitting the user's IP to Google on every page navigation. 2) Google Fonts is not disclosed as a recipient. AddThis is disclosed but was shut down by Oracle in 2023. Google Analytics is disclosed but is absent from the HAR. 3) The mechanism for transferring data to the US (SCC) is not specified. 4) The privacy policy was copied from the Ministry of Finance's site: every cookie in the table lists www.rahandusministeerium.ee as its source. The information does not pertain to the actual controller. Full technical documentation is published at: https://gdpru.eu/en/audits/ee-riigikontroll-ee/ 3. Provisions violated GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 13(1)(e); GDPR Art. 13(1)(f), Chapter V; GDPR Art. 12(1) 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]