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.
Timeline of the leak
Declared versus actual
Transfer timings
Google Tag Manager — before the banner, before consent
'Share' buttons. Not mentioned in the policy
Google Analytics, ID G-5SZ2******. An actual transfer to the USA
Detected trackers
- Google Analytics
- Google Tag Manager
- AddToAny
- Google Translate
- Google Fonts
Indicators of GDPR non-compliance
- GDPR Art. 5(1)(a)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.
- GDPR Art. 9Processing 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.
- GDPR Art. 6(1)Google Tag Manager, Google Analytics, and AddToAny fire 0.22–0.37 seconds before any user consent.
- GDPR Art. 13(1)(e)Not a single external vendor is declared by name. Only 'cookies for visit analysis' are mentioned, with no names given.
- GDPR Chapter VData transfer to Google (region1.analytics.google.com, USA) with no legal mechanism stated.
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.
7c32b29cfcf401cdbbdcbe2e59e5fc85c33ad5e766da8d589d10ea6368a91fcdWhere 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 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. Provisions violated 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 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]