The UK’s Information Commissioners Officer (ICO) have issued a notice of intent to fine Marriott International £99,200,396 for breaches of the General Data Protection Regulation (GDPR)

The UK’s Information Commissioners Office (ICO) have released a Statement in response to Marriott International, Inc’s filing with the US Securities and Exchange Commission saying that they intend to fine them for breaches of data protection law.

The proposed fine relates to a cyber incident last November in which personal data relating to approximately 339 million guest records globally were exposed by the incident.  Around 30 million of those records related to residents of 31 countries in the European Economic Area (EEA) and Seven million of those related to UK residents.

It is thought that the cyber incident began when the Starwood hotels group were compromised in a cyber incident in 2014. Marriott subsequently acquired Starwood in 2016, but the exposure of customer information was not discovered until 2018. Marriott failed to undertake sufficient due diligence when it bought Starwood and should also have done more to secure their own systems.

Information Commissioner Elizabeth Denham said:

“The GDPR makes it clear that organisations must be accountable for the personal data they hold. This can include carrying out proper due diligence when making a corporate acquisition, and putting in place proper accountability measures to assess not only what personal data has been acquired, but also how it is protected.

“Personal data has a real value so organisations have a legal duty to ensure its security, just like they would do with any other asset. If that doesn’t happen, we will not hesitate to take strong action when necessary to protect the rights of the public.”

Marriott will now have an opportunity to make representations to the ICO as to the proposed findings and sanction.

The ICO has been investigating this case as lead supervisory authority on behalf of other EU Member State data protection authorities. It has also liaised with other regulators. Under the GDPR ‘one stop shop’ provisions the data protection authorities in the EU whose residents have been affected will also have the chance to comment on the ICO’s findings.

If you’re not sure what your obligations are when it comes to cyber security, we’re here for you.  See