The Ministry of the Interior argues that since the Police and Border Guard Board (PPA) is authorized under the Law Enforcement Act to use cameras in public places to identify and prevent threats or respond to public order violations, the use of such cameras is lawful — even if no specific law explicitly provides for license plate recognition.

The ministry also notes that, because the Police and Border Guard Act requires the police to search for missing persons, investigate offenses and enforce penalties, license plate recognition cameras enable the police to fulfill these duties. In addition, the law provides for the creation and regulation of the police information system, Polis, through a ministerial regulation.

The ministry emphasizes that, under the law, Polis includes a preventive data registry, which also houses data collected through the license plate recognition system — namely, a photo of the vehicle and its license plate, along with the time and location of the image.

The police may retain this data in its database for up to three months, or longer if an investigation is initiated. Any queries made within the system must be justified and are logged.

Overall, the Ministry of the Interior believes that the types of data collected by license plate recognition cameras, as well as the rules for processing and retention, are defined with sufficient detail.

At the same time, the ministry acknowledges that current regulations could be more clearly and precisely codified in legislation — primarily to improve public awareness and predictability regarding the processing of their personal data.

In the ministry's view, however, there are no fundamental legal issues with the use of license plate recognition cameras or with the retention of the data they generate.

To support this position, the ministry points to examples of license plate recognition being used in the private sector — in parking lots, ports and gas stations — as well as in other countries.

The ministry also cites six cases in which the camera system proved helpful: identifying the rapist of a nine-year-old girl, locating computer store burglars, apprehending Lithuanian car thieves, identifying foreign extortionists, finding the assailant of Peep Talving and identifying criminals involved in a shooting incident in Lasnamäe.

The memo also notes that the system is useful in locating missing persons.

The PPA's use of a license plate recognition system relying on a network of CCTV cameras, which recently came to the attention of the public and which some politicians appeared to be unaware of, has drawn criticism in the media and from human rights advocates citing privacy concerns.

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