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Security report for lausuntopalvelu.fi

Oikeusministeriö · Government · Finland

High risk. 20 critical or high findings in GDPR outside view, Network security and 2 other checks.

Security score

42/100

Risk levelHigh

0–100, higher is better. How it is calculated

Lausuntopalvelu.fi is an official Finnish government digital platform maintained by the Ministry of Justice (Oikeusministeriö). It facilitates electronic submission and management of public consultation requests, allowing all public authorities to publish consultation requests and enabling organizations and citizens to provide statements. The service is well-positioned as a trusted government resource with a clear target audience of public sector entities and the general public. The website content is professionally presented, bilingual (Finnish and Swedish), and includes user support contact information.

Scanned

NIS2 and GDPR posture

GDPR outside view
33/ 100 · High
Checks completed
7of 7

NIS2 Art. 21(2)

  1. (a) Risk analysis and security policies: Not visible from outside
  2. (b) Incident handling: One indicator
  3. (c) Business continuity, backups and crisis management: Not visible from outside
  4. (d) Supply chain security: Not visible from outside
  5. (e) Secure acquisition, development and maintenance, including vulnerability handling: Partly checked
  6. (f) Assessing the effectiveness of security measures: Not visible from outside
  7. (g) Cyber hygiene and security training: Not visible from outside
  8. (h) Cryptography and encryption: Partly checked
  9. (i) HR security, access control and asset management: One indicator
  10. (j) Multi-factor authentication and secured communications: Not visible from outside

This scan rated NIS2 with an earlier keyword method that is no longer shown; rescan for the per-article view. Risk management, continuity, supply chain, training, MFA, management oversight (Art. 20) and incident reporting (Art. 23) need internal evidence, and Guard cannot tell whether NIS2 applies to this organisation.

GDPR is indicative only, based on publicly visible signals: Articles 7, 12, 13 and 32 of Regulation (EU) 2016/679 and Article 5(3) of the ePrivacy Directive. Not a certification or legal assessment.

Priority findings

20 findings rated critical or high. Fix these first.

  1. GDPR outside view

    These are the privacy signals visitors and data protection authorities look for under GDPR.

    • Critical

      EU business without adequate privacy measures

      EU businesses are subject to strict GDPR requirements

      What to do: Implement comprehensive GDPR compliance including privacy policy, cookie consent, and data protection measures

  2. Network security

    Services reachable from the internet are the first thing attackers probe. Anything open that does not need to be should be closed.

    • Critical

      Critical Service Exposed: Telnet

      Port 23 (Telnet) is publicly accessible - Telnet - Unencrypted remote access

      What to do: Immediately restrict access to Telnet using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection
    • Critical

      Critical Service Exposed: SMB

      Port 445 (SMB) is publicly accessible - SMB - Windows file sharing, high risk

      What to do: Immediately restrict access to SMB using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection
    • Critical

      Critical Service Exposed: MSSQL

      Port 1433 (MSSQL) is publicly accessible - MSSQL - Database server

      What to do: Immediately restrict access to MSSQL using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection
    • Critical

      Critical Service Exposed: Oracle

      Port 1521 (Oracle) is publicly accessible - Oracle - Database server

      What to do: Immediately restrict access to Oracle using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection

Need hands-on remediation? Email guard@offseq.com

Keep watching lausuntopalvelu.fi

This scan found 39 issues across 6 checks. Monitoring re-runs those checks daily, emails you when something material changes and records each fix, so you can show progress.

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Recommended

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  • TLS certificates and expiry
  • DNS records
  • SPF, DKIM and DMARC
  • Security headers
  • GDPR and NIS2 posture
  • Exposed services
  • Third-party trackers
  • Security score drift

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Results by check

Each check with its score, findings and the evidence it collected.

How this score is calculated

The security score runs 0–100, higher is better. It is the plain average of the security checks that completed in this scan, each counted equally. A check that could not run is left out: it counts neither as a pass nor as a fail.

Counted in this score

SSL/TLS
47
Security headers
25
Email security
70
DNS health
75
Network security
0
GDPR outside view
33
Average
42

Not counted

  • NIS2 outside view: Re-weights evidence from the TLS, email, DNS, network and hygiene checks, so counting it would count that evidence twice. Shown on its own.
  • OffSeq Observations: An AI reading of the site, useful context but not reproducible evidence. Shown on its own.

Findings that cap the score at 49

Each of these is serious on its own, so while any is present the site cannot rate better than high risk, however good the other checks are.

  • The certificate is not trusted by browsers
  • The website is not served over HTTPS
  • A database, remote desktop, file-sharing or Telnet service is reachable from the internet · found on this site
  • The page loads a script from a compromised source
  • The domain registration has expired
  • SPF authorises every server to send mail as the domain

Partial scans

When the site blocks Guard or most checks cannot run, the score covers only the checks that ran (usually DNS and email), is capped at 75 and is shown as partial, without a risk level.

Risk levels

  • Critical0–25
  • High26–49
  • Medium50–75
  • Low76–100

Technical appendix

Business context, site observations and technical notes gathered during the scan, and the standards behind each reference.

Business context

Business profile

The platform operates as a government digital service, focusing on transparency and public participation in legislative and administrative processes. It leverages a straightforward business model as a public service without commercial revenue streams. The website shows indicators of a mature service with tens of thousands of users and organizations engaged. The partnership ecosystem is primarily governmental, with no commercial partners evident. The service benefits from official backing, which enhances trust and market position.

Security posture

The website enforces HTTPS and uses Matomo analytics with cookies disabled, reflecting privacy-conscious design. However, it lacks explicit security headers such as Content Security Policy or HSTS, and there is no visible security policy or incident response information. No vulnerabilities or exposed sensitive data were detected in the HTML content. The absence of a cookie consent mechanism and vulnerability disclosure page are areas for improvement. Overall, the security posture is solid but could be enhanced with additional best practices and transparency.

Recommendations

  1. Implement and enforce security headers including CSP, HSTS, and X-Frame-Options to strengthen defense against common web attacks.
  2. Add a cookie consent banner or mechanism to comply fully with EU cookie regulations and enhance user privacy transparency.
  3. Publish a dedicated security policy and incident response contact information to improve trust and preparedness.
  4. Create and maintain a vulnerability disclosure policy or security.txt file to encourage responsible reporting of security issues.
  5. Consider adding explicit phone contact details and physical address information to improve user trust and accessibility.
Site observations

Automated reading of the public site. Ratings are indicative.

Business

Company
Oikeusministeriö
Description
Lausuntopalvelu.fi tarjoaa mahdollisuuden pyytää ja antaa lausuntoja sähköisesti. Kaikki julkishallinnon viranomaiset voivat julkaista lausuntopyyntöjä palvelussa. Lausuntoja saavat antaa kaikki organisaatiot ja kansalaiset.
Key services
Electronic submission and request of statements, Publishing consultation requests, User support and guidance
Content quality
good
Branding
consistent

Technology

Stack
jQuery, Bootstrap, Matomo (Piwik) analytics, Bootstrap-datepicker, Webropol TabulationManager
Frameworks
Bootstrap
Performance
moderate
Mobile
good
Accessibility
good
SEO
basic

Security

Observed score
80/100
Good practices seen
  • HTTPS enforced
  • No cookies tracked by Matomo (disableCookies set)
  • No exposed sensitive data in HTML

Analytics and tracking

Services
Matomo (Piwik)
Tracking level
minimal
Privacy practices
good

Advertising

Tracking pixels
Matomo (Piwik)
Transparency
poor

Site quality

Design
good
User experience
good
Content relevance
good
Navigation
good
Professionalism
good
Trustworthiness
high

Key observations

  1. Official Finnish government service website
  2. Provides electronic consultation services
  3. Clear navigation and bilingual support (Finnish and Swedish)
  4. No signs of malicious or suspicious content
  5. Uses Matomo analytics with cookies disabled
  6. Lacks explicit cookie consent mechanism
  7. No visible security.txt or vulnerability disclosure
  8. No phone numbers or physical addresses explicitly listed on main page
  9. Contact email provided for user support
Technical notes

Notes

The website uses a modern tech stack including jQuery and Bootstrap for responsive design, along with Matomo for privacy-focused analytics. The site is mobile-optimized and accessible, with clear navigation and bilingual support. Performance is moderate, with asynchronous loading of scripts and no blocking elements detected. The CMS or backend platform is not explicitly identified, suggesting a custom or government-specific solution. There is room for technical improvements in SEO and security header implementation to reduce technical debt and enhance resilience.
Standards and sources

Reference chips under each finding point to the standard, regulation or specification the finding relates to. They are taken from the official datasets below and mapped conservatively: a finding with no defensible link shows none. NIS2 and GDPR references mark where a finding is relevant evidence, not a compliance verdict. Implementing Regulation (EU) 2024/2690 binds digital infrastructure and digital service providers; for other entities it is the most detailed public reading of the Article 21 measures. WCAG, EN 301 549, European Accessibility Act and Web Accessibility Directive references name the requirement an automated accessibility rule relates to; they are not a conformance verdict.

Retrieved 2026-10-25

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