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Technical audit · 12.04.2026

riigikontroll.ee

Supreme financial oversight authority
EE

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.

Request timeline

+400 ms · on load
Google Fonts (fonts.googleapis.com) — status 200, 3 requests. Followed by fonts.gstatic.com (+426 ms) — the Atkinson Hyperlegible font. The user's IP goes out to Google (US).
Consent banner
Absent. Zero consent requests, zero Set-Cookie headers.
Blocked by CSP
GTM (G-NZ5VEKEN0D), Cloudflare Insights, browser-update.org — all status 0, written into the code, but blocked. cdnjs.cloudflare.com — status 404, but the request still went out (IP to Cloudflare).

Declared versus actual

✓ Google Analytics (_ga, _gid, _gat) — absent from the HAR, not a single request — declared
✓ AddThis (__atuvc, __atuvs) — shut down by Oracle in 2023, absent from the HAR — declared
✓ The cookie table lists www.rahandusministeerium.ee as its source — someone else's site — declared
+ Google Fonts — 6 requests, IP to the US, not mentioned in the policy — not declared

Transfer timings

+400 ms fonts.googleapis.com

Google Fonts, 3 requests, status 200. Data to the US

+426 ms fonts.gstatic.com

Atkinson Hyperlegible font, 3 requests. IP to Google

No exact timing

on load www.googletagmanager.comGTM G-NZ5VEKEN0D — written into the code, blocked by CSP, status 0
on load static.cloudflareinsights.comBlocked by CSP, status 0

Detected trackers

Indicators of GDPR non-compliance

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.

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/riigikontroll-ee-2026-05-24.har
SHA-256: 56906516269043dddb0875d8fd2999728775a09b188d2bd845ff73baabf97648
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) — riigikontroll.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 riigikontroll.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) 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.


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-riigikontroll-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 — riigikontroll.ee

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. 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; GDPR Art. 12(1)

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]