Why is data security so hard in the hospitality industry? What can be done about it?

Written prior to Marriott International’s announcement on November 30, 2018 that a data breach exposed the private data of up to 500 million guests, Robert Braun, co-chair of JMBM’s Cybersecurity & Privacy Group, wrote the article Guest Privacy – It’s Your Business, published by HotelExecutive.com on December 2, 2018.

In that article, he writes:

“Gathering and processing information [about guests] provides not only opportunities, but creates obligations, one of the most basic of which is ensuring the security of guests’ personal information.

That obligation has become increasingly complex due both to the vulnerability of hotel companies to breach, and the enactment of laws and regulations, worldwide, that impose additional burdens on hotels – the EU’s General Data Protection Regulation, California’s Consumer Privacy Act, as well as industry developments have further heightened the concerns with guest privacy and security.”

He also notes:

“This focus must be seen in the context of two key issues: first, that hotels collect large amounts of data from their guests, both directly and through third parties; and second, that the hospitality industry has a checkered track record in protecting personal information. Both these demand that the hospitality industry take a renewed focus on data security.”

To read the full article, including Braun’s suggestions as to what hotel owners and operators should do to begin the process of securing their systems, see Guest Privacy – It’s Your Business.

To read more on Braun’s take on the Marriott International data breach, see Avoiding Hotel Data  Breaches with a Risk Assessment Audit – Lessons from the Marriott International “Glitch”.


Robert E. Braun is the co-chair of the Cybersecurity and Privacy Law Group at Jeffer Mangels Butler & Mitchell LLP. Bob helps clients to develop and implement privacy and information security policies, negotiate agreements for technologies and data management services, and comply with legal and regulatory requirements. He helps clients to develop and implement data breach response plans, and he and his team respond quickly to clients’ needs when a data breach occurs. Contact Bob at RBraun@jmbm.com or +1 310.785.5331.

JMBM’s Cybersecurity and Privacy Group counsels clients in a wide variety of industries, including accounting firms, law firms, business management firms and family offices, in matters ranging from development of cybersecurity strategies, creation of data security and privacy policies, responding to data breaches and regulatory inquiries and investigations, and crisis management. The Cybersecurity and Privacy Group uses a focused intake methodology that permits clients to get a reliable sense of their cybersecurity readiness and to determine optimal, client-specific approaches to cybersecurity.