COVID And Contactless Technology In Hotels

privacy Oct 28, 2020

Part of the response to the challenge of running a hotel during the COVID pandemic has been to adopt some contactless technology.

  • Check in has been made contactless.
  • Room keys can now use contactless systems.
  • Systems record attendance of individuals and groups of people.
  • Guests can enjoy the services of a digital concierge.
  • Some hotels have even installed interactive devices in their bedrooms.  Which means guests can now enjoy the delights of communicating with Alexa or the Google digital assistant.

The technology can be really easy to deploy.  In some cases deceptively easy.

Do you know what the technology is really doing?

  • Do you have a data controller/data processor agreement in place for each new technology vendor you have used?
  • Do you know what personal data each system is collecting and what it's doing with it?
  • Do you know where this personal data is being kept and for how long?
  • Have you run any sort of vendor assessment for each technology supplier?
  • Have you prepared and displayed privacy notices to inform your guests about what is happening with these new systems?
  • Have you carried out any sort of risk assessment on the personal data processing involved?

Who Is Responsible?

The data controller is responsible for everything those newly appointed data processors are doing.  In most hotels, the data controller is the board of directors or the owner.  The buck stops right there.

If you are an owner or a director of a hotel, it is your responsibility to make sure all this new contactless technology is used in a manner which protects people's privacy.  You are accountable under the Data Protection Act for upholding the privacy rights of your customers and staff.

The question for today then is this:

What is all this technology really doing?


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