Hotels handle a wealth of sensitive data, from guest names and payment details to loyalty programme information and health records. The General Data Protection Regulation (GDPR), effective since May 25, 2018, mandates strict standards for collecting, storing, and using the personal data of EU citizens. For hotels, GDPR compliance is essential in building guest trust and protecting privacy.
This step-by-step guide will walk you through the essentials of GDPR for hotels, ensuring your establishment meets all requirements and mitigates potential risks associated with non-compliance.
- Understand what GDPR means for hotels
- Appoint a hotel data protection officer
- Conduct a data audit
- Review and update data protection policies
- Implement data security measures
- Manage third-party vendors
- Develop a data breach response plan
- Ongoing monitoring and updates
GDPR applies to any business handling the personal data of EU citizens, regardless of location. For hotels, GDPR includes guest data collected during reservations, check-in, or through digital channels, such as names, contact details, payment information, and preferences. GDPR for hotels focuses on transparency, accountability, and data security. Non-compliance can lead to fines of up to 4% of global turnover or €20million, whichever is higher.
The regulation also enforces guests’ rights to access, correct, and erase their personal data.
An important step in GDPR compliance for hotels is appointing a Data Protection Officer (DPO) to oversee data protection efforts and ensure regulatory compliance. While not mandatory for all hotels, a DPO is strongly recommended if your property processes significant personal or sensitive data or uses surveillance. This individual should have expert knowledge of hotel data protection laws, operate independently, and serve as the main contact for guests and authorities regarding data protection matters.
To ensure GDPR compliance, hotels must first understand what personal data they collect, process, and store. A thorough data audit should cover all touchpoints, including bookings, check-in, stay, and post-checkout communications. Key areas include booking systems, payment platforms, loyalty programmes, surveillance, employee records, and third-party service providers. After mapping data flows, assess the purpose and legal basis for processing each type of data. This helps ensure data is collected only when necessary and used transparently, aligning with both regulatory requirements and guest expectations.
Hotel data protection policies must align with GDPR requirements by collecting only necessary data and clearly informing guests of its purpose. Consent must be freely given, specific, informed, and easy to withdraw. Guests should be able to opt in during booking and withdraw consent anytime. Data should not be retained longer than needed and must be archived or deleted post-stay based on legal and business needs. Policies must also support data subjects’ rights to access, correct, or delete their information. Communicate these policies clearly across all guest touchpoints, including your website and registration forms.
Protecting guest data from unauthorised access, loss, or theft is vital for GDPR compliance in hotels. A strong cybersecurity strategy should include encryption, access controls, regular audits, and staff training. Sensitive data, such as payment details, must be encrypted in transit and at rest. Access should be limited to authorised staff based on roles. Regular vulnerability assessments and penetration tests help identify security gaps. Staff must also be trained to handle data responsibly and recognise cybersecurity threats, including phishing and other risks related to guest data protection.
Hotels often rely on third-party vendors for services like booking systems, payment processing, and marketing. Under GDPR, you’re still responsible for data protection and must ensure all external providers comply. When engaging third-party vendors, ensure that you sign a Data Processing Agreement (DPA) with each vendor, as mandated by Article 28 of the GDPR, to clearly define their responsibilities regarding data protection. You should also review their data protection practices to ensure they align with GDPR requirements, including their data security measures and protocols for handling data breaches.
Hotels must establish a clear data breach response plan, which includes identifying the breach and assessing its severity, notifying the relevant supervisory authority (if applicable), and informing affected guests about the breach and the measures they can take to protect themselves. In the event of a data breach, GDPR mandates that affected individuals must be notified within 72 hours of the breach’s discovery.[4] Your hotel must also ensure that it keeps an internal log of all data breaches and their resolutions as part of your accountability obligations.
GDPR compliance is not a one-time task; it requires ongoing monitoring and adjustments. As laws evolve, technology changes, and new data processing practices emerge, your hotel should continuously review its data protection practices and make necessary updates to remain compliant.
How can Infosys BPM help businesses achieve GDPR compliance?
As data privacy regulations evolve, hotels need more than just compliance. They need consistency, accuracy, and expert support. Infosys BPM brings deep legal process expertise tailored to the travel and hospitality industry, helping hotels manage GDPR obligations efficiently. With services spanning contract management, regulatory compliance, and data governance, Infosys BPM enables hotels to reduce risk and strengthen guest trust while staying focused on delivering exceptional experiences.
