The Ministry of Finance asked the Ministry of Justice whether, under the Public Information Act, agencies may publish vacation information together with the name of the substitute official. The goal, the ministry said, would be to inform the public about an agency's work arrangements and ensure efficient, low‑bureaucracy communication with state and local authorities. At the same time, any change must respect data‑protection principles and safeguard officials' privacy.  

However, the Ministry of Justice and the Ministry of Digital Affairs concluded that the current Public Information Act does not provide a clear legal basis for publishing vacation periods online. Vacation status is personal data, and active disclosure on a government website constitutes an intrusion into private life. For such processing, lawmakers must define both the purpose and scope of disclosure.  

The ministry noted that agencies may still publish information on whom to contact when the usual official is unavailable. In such cases, the focus is on ensuring continuity of service, not revealing personal details about an official's private life. Many agencies already publish substitute contacts without specifying the reason or duration of the absence. 

If agencies were to systematically publish vacation periods, durations and substitutes, a specific legal basis would need to be added to the law, clearly defining the purpose and timeframe of disclosure. The ministry emphasized that effective communication with the public can often be achieved through less intrusive means — for example, by publishing only substitute contacts or general unit contact details, without indicating vacation dates.  

Another option would be to require officials to designate a substitute during vacation and include that information in automatic email replies. This way, individuals contacting the agency would know whom to approach, but the official's vacation period would not be publicly visible.  

The Ministry of Justice concluded that although it would be possible to legislate the publication of vacation periods, the same goal — improving communication with agencies — can be achieved with less privacy‑intrusive measures. Therefore, amending the Public Information Act is not necessary.

In practice, information on Estonian public officials' vacations and their substitutes can be found in the RTIP public documents registry of the civil service portal.

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