Access to data in the case of a legitimate interest
Natural and legal persons with a legitimate interest may access, by a reasoned request, information on the data entered in the population register regarding another person provided that the person in question has not restricted access to their personal data.
The interest is considered legitimate, first and foremost, in the following cases (the list is not exhaustive):
- for the protection of the applicant’s or other person’s life, health, rights and freedoms;
- for the performance or securing the performance of a contract concluded with the applicant;
- for scientific purposes (on the basis of the conditions established in the Personal Data Protection Act).
The data in the above cases are issued by:
- the local government of a county center, if the applicant requests data of the same nature regarding not more than 20 people at a time in the span of one month
- Ministry of the Interior's IT and Development Centre (SMIT) (Mäealuse 2/2, 12618 Tallinn; e mail: firstname.lastname@example.org, phone: 612 4444) in case data regarding up 100 people are requested;
- the Ministry of the Interior, if access to the data concerning more than 100 people at a time is applied for.
The freely formulated request for access to data in the population register must contain the following information:
- if the applicant is a legal person, the name of the legal person and the given name and surname of the person authorised to receive the data;
- if the applicant is a natural person, the given name and surname and personal identification code;
- the justified purpose, time and manner of using the data;
- the composition and amount of the requested data;
- the method of access requested;
- a confirmation that the data received will only be used for the purpose, during the time and in the manner requested.
Granting access is executed as an administrative act, which is published in the data processing information system of the population register.
The decision is executed as an administrative act, which establishes the following:
- the purpose for which the obtained data will be used, including the transmission of the data to a third party;
- the composition of the data to be processed;
- the timeframe of the processing;
- the procedure, method and techniques of processing (AP, X-Tee, etc.);
- the procedure for providing technical support;
- rights and obligations in data processing;
- general technical and organizational measures for the protection of the data to be processed as well as the procedure for their implementation;
- payment for access to the data;
- conditions of revoking access to the data.
Access to the data may be refused if:
- the applicant does not have a legitimate interest;
- releasing the data may harm the interests of the person whose data is being requested;
- if access (to additional addresses and contact details) is requested for advertising or survey purposes.
If access to the data is refused, the applicant may request that that the authorized administrator ask the person whose data is being requested for consent or that the applicant’s details be forwarded to the person in question. If consent is granted, the requested data shall be released.
If applying for access to the data in the population register in case of a legitimate interest through the data processing information system of the population register is unreasonably complicated for the applicant who is a natural person, the application may be submitted to the authorized employee or administrator with permanent access in a format which can be reproduced in writing.
Data release fees
Releasing data from the population register in the case of a legitimate interest is subject to fees according to Regulation No. 3 of the Minister of the Interior of 14 January 2019 "Authorisation of fees for the release of data from the population register in case of legitimate interest". When releasing up to 10,000 entries, the online or offline data service fee for releasing one entry is 0.20 euros. With a single data service (less than 50 entries, released manually), the fee for releasing one entry is 5 euros.
When a county government issues a certified extract or printout of the data entered in the population register in the case of a legitimate interest, the state fee is 5 euros per data regarding one person. The state fee is to be paid according to the procedure established in the section State fees for issuing documents.