Subject: Acting on behalf of a client in their personal matters - digital solutions, platforms and legislation in Estonia
From: Alén Iida (OM) <[email-masked]>
To: <[email-masked]>, "Justiits- ja Digiministeerium" <[email-masked]>
Cc: "Kemppainen Outi \(OM\)" <[email-masked]>, "Grandell Joanna \(OM\)" <[email-masked]>, "Parkatti Helena \(OM\)" <[email-masked]>
Date: Thu, 13 Nov 2025 17:45:50 +0200

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

To whom it may concern,

My colleagues and I are contacting you from the Ministry of Justice of 
Finland.

We are currently revising the Finnish provisions of our Guardianship Act in 
order to facilitate the guardians and lasting powers of attorneys 
possibilities to operate in various electronic services on behalf of the 
clients/granters that they represent. It is currently possible for the 
guardians and attorneys to operate digitally in their client’s financial 
issues (in tax matters, social benefits etc.). This is possible since the 
representatives have no restrictions on the right of access to the 
information on the client’s financial issues if the mandate covers financial 
issues.

However, we have faced difficulties when the guardian / lasting powers of 
attorney needs to operate digitally and / or on digital platforms and 
e-services on behalf of the client in matters related to his or her person 
(e.g. health services). This is because the right to represent the client is 
more restricted in matters that are personal. Also, the right to information 
is more restricted because of the protection of privacy. Furthermore, it is 
not always clear if a certain matter is purely economic or also related to 
the client’s person. Therefore, as for now guardians and lasting powers of 
attorneys are not able to operate on behalf of their clients in electronic 
services in the client´s personal matters. As you can probably already 
guess, we would be glad to hear if you have been able to solve the 
above-mentioned situations in which representatives need to act on behalf of 
someone else online in these situations.

We are aware that in Estonia you have two types of representation:

1) representation arising from law or when a court has appointed a guardian 
and

2) contractual representation e.g. the relationship between a lawyer and a 
client.

Even though we are especially interested in questions related to 
guardianship, we would be keen to know whether it is possible in Estonia to 
act on behalf of a client in their personal matters (e.g. representation in 
health care) in digital platforms in both cases of representation. For 
example,

*	can a guardian book doctor´s appointments online, use pharmaceutical 
services online, get access to their client’s medical history online etc.?
*	are there matters that cannot be handled through digital platforms? If so, 
what are they? Are there any specific reasons for excluding them? If so, 
what are these reasons?
*	are there differences, and if so what differences, in terms of handling 
financial matters compared to handling personal matters (e.g. representation 
in health care matters) in digital platforms?
*	do representatives have unlimited or limited access to client’s 
information in digital services (e.g access to medical history)?
*	what kind of digital solutions / platforms have you developed for example 
in health care services and what kind of provisions do you have regarding 
the guardian’s right of access to information related to client’s person, 
e.g. health, or medical data?
*	have you had any changes to legislation because of digitalization 
projects?
*	have you implemented safeguards to enhance the right to self-determination 
in a digital context for people under guardianship?

We would be more than grateful if you could provide us with answers 
regarding Estonian legislation and digital solutions to these questions.

Yours faithfully,

Iida Alén

Senior Specialist

Ministry of Justice, Finland

FIN-00023 Government

 <mailto:[email-masked]> [email-masked]

phone +358 295 150 148

 <http://www.oikeusministerio.fi/> www.oikeusministerio.fi

For information on how the Ministry of Justice processes personal data, go 
to  <https://oikeusministerio.fi/en/data-protection> 
https://oikeusministerio.fi/en/data-protection