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Technical audit · 12.04.2026

tai.ee

National Institute for Health Development
EE

This institute holds records of who has had cancer, who has been treated for drug dependency, when someone was born, and what their loved ones died of. The policy states 'we do not transfer data to third parties' — yet Google Analytics receives visitor data 0.37 seconds in, before the consent banner has even been acted upon.

Request timeline

+0.22 sec · before consent
Google Tag Manager fires two-tenths of a second after loading. Followed at +0.23 sec by AddToAny ('share' buttons), not mentioned in the policy.
+0.37 sec · before consent
Google Analytics genuinely sends data to region1.analytics.google.com (ID G-5SZ2******). The banner is still on screen, the user has clicked nothing — Google has already received the data.
7 transfers per session
GA sent data at +0.37 / +5.38 / +14.90 / +19.91 / +29.74 / +31.91 / +36.92 sec. Each one an actual request to the USA.

Declared versus actual

✓ Policy: 'we do not transfer cookie-related information to third parties' — declared
✓ 'Cookies for visit analysis' — no names given — declared
+ Google Analytics — G-5SZ2******, 7 transfers per session — not declared
+ Google Tag Manager — not declared
+ AddToAny — attempted to access storage 9 times on the data protection page — not declared
+ Google Translate, Google Fonts — not declared

Transfer timings

+0.22 sec www.googletagmanager.com

Google Tag Manager — before the banner, before consent

+0.23 sec AddToAny

'Share' buttons. Not mentioned in the policy

+0.37 sec region1.analytics.google.com

Google Analytics, ID G-5SZ2******. An actual transfer to the USA

Detected trackers

Indicators of GDPR non-compliance

Context

TAI is Estonia’s National Institute for Health Development, a state institution under the Ministry of Social Affairs. It maintains five national medical registries: cancer, pregnancies, tuberculosis, drug dependency, and causes of death. This isn’t an online store — it’s an organization that holds records of the most difficult episodes in a person’s life.

A direct contradiction

TAI’s official privacy policy states, verbatim: “We do not transfer cookie-related information to third parties.” In reality, Google Tag Manager fires at +0.22 sec, AddToAny at +0.23 sec, and Google Analytics genuinely sends data to region1.analytics.google.com at +0.37 sec. The consent banner is still on screen, the user has clicked nothing — Google has already received the data. Over the session, Google Analytics transmitted data 7 times, each carrying the identifier G-5SZ2******, each time to the USA.

A detail that hits precisely

AddToAny attempted to access browser storage 9 times in a row — and all of this happened on the page titled “Isikuandmete töötlemine ja andmekaitse,” literally the “Personal Data Processing and Data Protection” page. The browser blocked the attempts, but they are recorded in the console.

What isn’t declared

The policy mentions only “cookies for visit analysis” — with not a single name given. Specific names are absent: Google Tag Manager, Google Analytics (G-5SZ2L...), AddToAny, Google Translate, Google Fonts. Under Art. 13(1)(e), the data subject is entitled to know all recipients of their data.

Conclusion

Someone visiting tai.ee in search of information about cancer is identified by Google Analytics 0.37 seconds in — before they’ve clicked anything. This falls under GDPR Art. 9, a special category of health data: the highest level of protection under law, and the crudest level of violation in practice. The policy promises the opposite of what the site actually does.

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/tai-ee-2026-04-12.har
SHA-256: 7c32b29cfcf401cdbbdcbe2e59e5fc85c33ad5e766da8d589d10ea6368a91fcd
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) — tai.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 tai.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) The policy states directly: 'we do not transfer cookie-related information to third parties.' Google Analytics transmits data 7 times per session. A direct contradiction of the declaration.

2) Processing of visitor data on a state health website with no consent. TAI maintains registries for cancer, pregnancies, tuberculosis, drug dependency, and causes of death — a special category of health data.

3) Google Tag Manager, Google Analytics, and AddToAny fire 0.22–0.37 seconds before any user consent.

4) Not a single external vendor is declared by name. Only 'cookies for visit analysis' are mentioned, with no names given.

5) Data transfer to Google (region1.analytics.google.com, USA) with no legal mechanism stated.


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-tai-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 — tai.ee

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

2. Circumstances
I visited the website tai.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) The policy states directly: 'we do not transfer cookie-related information to third parties.' Google Analytics transmits data 7 times per session. A direct contradiction of the declaration.

2) Processing of visitor data on a state health website with no consent. TAI maintains registries for cancer, pregnancies, tuberculosis, drug dependency, and causes of death — a special category of health data.

3) Google Tag Manager, Google Analytics, and AddToAny fire 0.22–0.37 seconds before any user consent.

4) Not a single external vendor is declared by name. Only 'cookies for visit analysis' are mentioned, with no names given.

5) Data transfer to Google (region1.analytics.google.com, USA) with no legal mechanism stated.

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

3. GDPR provisions I ask you to examine
GDPR Art. 5(1)(a); GDPR Art. 9; GDPR Art. 6(1); GDPR Art. 13(1)(e); GDPR 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]