Answer to request

ERAELU KAITSE JA RIIGI LÄBIPAISTVUSE EEST

Tatari tn 39 / 10134 Tallinn / 627 4135 / [email protected] / www.aki.ee

Registrikood 70004235

Bárbara da Rosa Lazarotto

Vrije Universiteit Brussel

[email protected]

Yours: 04.09.2025 Ours: 19.09.2025 nr 2.2.-1/25/36-4

Answer to request Estonian Data Protection Authority has received your questions about DGA. Thank you for the

questions.

We have reviewed the questions and, must unfortunately acknowledge that we currently lack

substantive answers that would fit within the framework of academic research. In Estonia,

discussions around the implementation of the DGA are still ongoing, and many aspects are still

unresolved.

At this stage, we believe your questions would be best addressed to the Ministry of Justice and

Digital Affairs, which is the competent authority leading the national coordination on this matter.

You can contact the ministry at their email address: [email protected].

What we can clarify is that the main obstacle in implementing the DGA has been the lack of human

resources, both at the legislative level and among potential competent authorities. At the moment,

there is no clear understanding of who should act as the competent authority and how. As of today,

we are seeing significant fragmentation across the EU, meaning there is a lack of consistency.

Regarding the gathering of feedback, stakeholders in Estonia have not shown significant interest.

From our perspective, there have only been a few minor questions. Additionally, it is worth noting

that there are currently only three data altruism organizations across the European Union, which

unfortunately reflects rather a generally low level of interest in the topic.

In summary, we kindly encourage you to direct your questions to the Ministry of Justice and Digital

Affairs, where you may receive more comprehensive responses aligned with the needs of your

research. We hope the context and clarifications provided here have been of some assistance. It is

regrettable that we are unable to offer more detailed input at this time.

If the Data Protection Inspectorate gains clarity regarding its role in relation to the DGA regulation

and implementation, we will ensure that updated information is made available on our website:

www.aki.ee.

Respectfully

2 (2)

Liina Kroonberg

lawyer

authorized by Director General