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Technical audit · 2026-04-21

siseministeerium.ee

Police, border guard, migration, citizenship
EE

The ministry overseeing the police, border guard, migration, and citizenship. Its cookie policy is a mirror image, reversed: it declares services the site doesn't have (Google Analytics, AddThis, Facebook), and stays silent about the ones that actually run (Matomo, Cloudflare). A document describing a parallel reality.

Timeline of the leak

+0 ms · before consent
Cloudflare RUM (cdn-cgi/rum) — status 204, behavioral analytics, data to the US, 4 requests during the session. Absent from the policy.
+141 s · before consent
piwik.smit.ee/matomo.js (status 200, data transmitted), i.ytimg.com (YouTube thumbnail, IP to Google), static.cloudflareinsights.com (status 200), browser-update.org (+142 s, status 304). None of these is disclosed.
Consent banner
Three buttons, no 'Reject All' button. The browser already has _cf_bm (Cloudflare Bot Management) and cf_clearance set — neither is disclosed. The user knows nothing about them.

Declared versus actual

✓ Google Analytics (_ga, _gid, _gat) — zero requests in the HAR — declared
✓ AddThis (__atuvc, __atuvs) — zero requests — declared
✓ Facebook, LinkedIn, Twitter — zero requests — declared
+ Matomo (piwik.smit.ee) — active, 2 requests — not declared
+ Cloudflare RUM (+0 ms) and Cloudflare Insights — data to the US — not declared
+ browser-update.org, cookies _cf_bm / cf_clearance — not declared

Transfer timings

+0 ms cdn-cgi/rum (Cloudflare RUM)

Behavioral analytics, status 204, 4 requests. Data to the US

+141,622 ms piwik.smit.ee (Matomo)

Matomo on RIA's server. Status 200, data transmitted. Absent from the policy

+141,721 ms static.cloudflareinsights.com

Cloudflare Insights, status 200, data to the US

+142,070 ms browser-update.org

Status 304. The same script found on AKI, epa.ee, emta.ee, transpordiamet.ee

Detected trackers

Indicators of GDPR non-compliance

Context

siseministeerium.ee is the official website of the Estonian Ministry of the Interior, the agency overseeing the police, border guard, internal security, migration, and citizenship. Through this site, citizens interact with the state on matters directly bearing on their legal status. HAR: 45 requests, 6 domains.

What’s declared — and what isn’t

The cookie policy lists: has_js, Google Analytics (_ga, _gid, _gat), AddThis (__atuvc, __atuvs), and, in the third-party section, Google, Facebook, LinkedIn, Twitter. Opening the HAR: Google Analytics — zero requests, AddThis — zero, Facebook/LinkedIn/Twitter — zero. Every declared service is inactive. Meanwhile, services absent from the policy are actually running: Cloudflare RUM (from +0 ms, 4 requests, US), Matomo (piwik.smit.ee, status 200, data transmitted), Cloudflare Insights (status 200, US), browser-update.org (status 304), a YouTube thumbnail (IP to Google). The browser has _cf_bm (Cloudflare Bot Management) and cf_clearance set — also undisclosed.

A mirror image, reversed

Most sites in this series fail to disclose what actually runs — a violation, but an understandable one: something forgotten, not updated. Here it’s different. The policy describes services the site doesn’t have and stays silent about the ones it does. A user reading the document is misled twice: they think Google Analytics collects their data — it doesn’t; they think Matomo doesn’t exist — it does; they think Cloudflare doesn’t set cookies — but _cf_bm is already in their browser. This isn’t a documentation gap — it’s a document describing a parallel reality.

The eID context

The site integrates Web eID (token-signing-page-script.js) — login via ID card or Mobile-ID. In the same session where a citizen potentially logs in under their real name, browser-update.org, Matomo, and Cloudflare Insights all run — all undisclosed. This calls for separate justification under GDPR Art. 9: data is being processed that could link on-site behavior to a real identity.

Conclusion

This is the Ministry of the Interior: police, border service, citizenship, migration. Its cookie policy declares Google Analytics, which doesn’t exist there, fails to mention Matomo, which does, and stays silent about Cloudflare Bot Management, which sets cookies in every visitor’s browser. Under the GDPR, this is a transparency violation — and a two-way one at that: the document misleads both through what it promises and through what it withholds.

Evidence
Original (audit)
HAR file: ee/siseministeerium-ee-2026-04-21.har
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
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.

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 siseministeerium.ee.

2. Circumstances
I visited the website siseministeerium.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 21 April 2026 (open methodology, reproducible measurements) documents the following indications:

1) The policy declares services that don't exist on the site (Google Analytics, AddThis, Facebook, LinkedIn, Twitter — zero requests in the HAR) and stays silent about services that actually run (Matomo, Cloudflare Insights, Cloudflare RUM, browser-update.org). The document doesn't match reality in either direction.

2) Cloudflare RUM (+0 ms), Matomo, Cloudflare Insights, and browser-update.org launch without user consent.

3) There is no 'Reject All' button — three buttons are offered, none of which amounts to an equivalent refusal option. 'Necessary cookies' are blocked, and the vendors are not named.

4) The actual recipients are not disclosed: Matomo (piwik.smit.ee), Cloudflare RUM, Cloudflare Insights, browser-update.org, cookies _cf_bm and cf_clearance (Cloudflare Bot Management).

5) The mechanism for transferring data to the US (Cloudflare) is not specified.

6) Web eID integration (token-signing-page-script.js) is present. In a session where a citizen logs in under their real name, undisclosed trackers run — browser-update.org, Matomo, Cloudflare Insights.

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

3. Provisions violated
GDPR Art. 5(1)(a); GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 7(3), Art. 7(4), Recital 32; GDPR Art. 13(1)(e); GDPR Art. 13(1)(f), Chapter V; GDPR Art. 9 (eID context)

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]