Consumers Affected
344,000,000
The FTC charged Marriott International and Starwood Hotels with failing to implement reasonable data security, leading to three data breaches affecting over 344 million customers. Under a proposed consent order, the companies must implement a comprehensive information security program, certify compliance annually for 20 years, and provide customers with ways to delete personal information and restore stolen loyalty points.
Marriott and Starwood must establish and maintain a comprehensive information security program with robust safeguards, undergo independent third-party assessments every two years, and certify compliance annually for 20 years. They must provide customers with a method to request deletion of personal information associated with their email or loyalty account, and review loyalty accounts upon request to restore stolen points. The companies are prohibited from misrepresenting their data security practices.
In-house legal teams should review vendor agreements (especially those involving data processing or IT services), customer privacy policies and terms of service, and employee data handling agreements. Specific clauses to scrutinize include data security obligations, breach notification timelines and procedures, data retention and deletion mechanisms, loyalty program terms regarding point security and restoration, and audit or certification requirements. Changes may be needed to incorporate specific security standards, mandate annual compliance certifications, establish clear processes for customer-initiated personal information deletion and loyalty point restoration, and strengthen third-party vendor oversight provisions.
Entity
Marriott International, Inc. and Starwood Hotels & Resorts Worldwide LLC
Also known as: Marriott
Industry
OtherOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/10/ftc-takes-action-against-marriott-starwood-over-multiple-data-breaches
1923022marriottacco
https://www.ftc.gov/system/files/ftc_gov/pdf/1923022marriottacco.pdf
1923022marriottcomplaint
https://www.ftc.gov/system/files/ftc_gov/pdf/1923022marriottcomplaint.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC"
"The FTC alleged that security failures by Marriott and Starwood resulted in at least three separate data breaches wherein malicious actors obtained the passport information, payment card numbers, loyalty numbers, dates of birth, email addresses and/or personal information from hundreds of millions of consumers"
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$1.9M
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