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Technical audit · 03.05.2026

terviseportaal.ee

National Health Portal
EE

Policy changed — see what exactly · 2026-09-30 →

This is the infrastructure through which every citizen accesses their medical records: diagnoses, prescriptions, test results, visit history, vaccinations. Psychiatric records. Oncological. Gynaecological. All of it. This is a special category of data under GDPR Art. 9 — health data. The highest level of protection the law provides.

Request timeline

+0.3 s · YouTube
Three embedded videos via youtube.com/embed — without privacy mode. 56 requests to YouTube; the health portal visitor's IP is sent to Google.
+1.2 s · DoubleClick
googleads.g.doubleclick.net and static.doubleclick.net — Google's advertising tracker on a medical portal. No consent banner exists.
+2.7 s · Google
YouTube anti-bot identification, www.google.com, gstatic. A person who came to read about oncology has, within 1.2 seconds, disclosed that fact to Google's advertising network. Without a choice.

Declared versus actual

+ DoubleClick (Google Ads) — advertising network on a medical portal — not declared
+ YouTube — 56 requests, without privacy mode — not declared
+ Google Fonts — 8 requests — not declared
+ Google anti-bot (jnn-pa.googleapis.com) — not declared

Transfer timings

+0.3 s youtube.com/embed

YouTube without privacy mode.

+0.5 s fonts.gstatic.com

Google Fonts — IP sent to USA.

+1.2 s googleads.g.doubleclick.net

DoubleClick advertising tracker.

+2.7 s jnn-pa.googleapis.com

YouTube anti-bot user identification.

Detected trackers

Indicators of GDPR non-compliance

What the HAR showed

234 requests per session. 10 external domains — all in the USA. The site opens via a redirect from the old digilugu.ee to www.terviseportaal.ee.

On page load, the following fire automatically:

  • YouTube — three embedded videos via youtube.com/embed, without privacy mode. 56 requests.
  • Google Fonts — 8 requests; the user’s IP sent to Google USA.
  • DoubleClick — googleads.g.doubleclick.net and static.doubleclick.net. An advertising tracker. On a medical portal. 8 requests.
  • Google and gstatic — www.google.com, www.gstatic.com.
  • YouTube anti-bot — jnn-pa.googleapis.com, a user identification system.

No consent banner exists at all — not a single consent request across the entire session. No cookies appear in the log, but that does not mean there is no tracking: JavaScript-based fingerprinting leaves no cookies, yet data transmission to Google and DoubleClick occurs regardless.

YouTube privacy mode is not enabled: youtube.com is used instead of youtube-nocookie.com. The developers had a choice and made it in favour of standard tracking.

Why this is especially serious

A person who came to read about oncology discloses that fact to DoubleClick — Google’s advertising network — within 1.2 seconds. Without consent, without a banner, without a choice. This is a state medical portal connected to the national e-health system.

There are no technical excuses. The country’s main portal, eesti.ee, operates with zero external trackers and a strict CSP — data stays within the country. edpb.europa.eu demonstrates the same. Architecture without external trackers works. This is a question of priorities, not capabilities.

Conclusion

Estonia positions itself as a leader in digital healthcare: personalised medicine, genetic data. The country is building the future of medicine on its citizens’ data. And on the portal where that data lives, Google’s advertising network is running — activated before the user has been asked anything.

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/terviseportaal-ee-2026-05-03.har
SHA-256: 6055b61b5cc490199127482bcec4e29eb26d5a1c08cc725f9ef75e5e674a323a
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) — terviseportaal.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 terviseportaal.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) Processing of health data without a legal basis. On a medical portal, any third-party transmission constitutes a violation involving a special category of data.

2) YouTube, DoubleClick, and Google fire at +0.3–+2.7 s before any consent. No consent banner exists.

3) No consent mechanism exists whatsoever.

4) Data recipients (Google, DoubleClick, YouTube) are not disclosed.

5) The data transfer mechanism to the USA is not stated for any recipient.

6) Data transferred to the USA without a legal basis. No SCCs, no adequacy decision (Privacy Shield was invalidated in 2020).


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-terviseportaal-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 — terviseportaal.ee

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

2. Circumstances
I visited the website terviseportaal.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 3 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) Processing of health data without a legal basis. On a medical portal, any third-party transmission constitutes a violation involving a special category of data.

2) YouTube, DoubleClick, and Google fire at +0.3–+2.7 s before any consent. No consent banner exists.

3) No consent mechanism exists whatsoever.

4) Data recipients (Google, DoubleClick, YouTube) are not disclosed.

5) The data transfer mechanism to the USA is not stated for any recipient.

6) Data transferred to the USA without a legal basis. No SCCs, no adequacy decision (Privacy Shield was invalidated in 2020).

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

3. GDPR provisions I ask you to examine
GDPR Art. 9; GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 7; GDPR Art. 13(1)(e); GDPR Art. 13(1)(f); 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]