Consumers Affected
344,000,000
The FTC finalized an order against Marriott International and Starwood Hotels for failing to implement reasonable data security, which led to three data breaches affecting over 344 million customers. The companies must implement a comprehensive security program, delete unnecessary personal information, allow U.S. customers to request deletion, and restore stolen loyalty points. They are also prohibited from misrepresenting their data security practices.
Marriott and Starwood must establish a comprehensive information security program, implement a data retention policy to keep personal information only as long as necessary, provide a website link for U.S. customers to request deletion of personal information, review and restore stolen loyalty points upon request, and are prohibited from misrepresenting their data collection, use, and security practices.
In-house legal teams should review all customer-facing agreements (e.g., hotel registration terms, loyalty program terms), vendor agreements (particularly those involving data processing or access to personal information), and any data processing addendums. Specific clauses to scrutinize include: (1) data security standards and representations, ensuring they align with 'reasonable' practices and do not overstate security; (2) data retention and deletion provisions, confirming they allow for deletion upon customer request and comply with data minimization principles; (3) breach notification obligations, verifying timely and comprehensive notification requirements; and (4) loyalty program data handling terms. Changes may be needed to add explicit customer deletion rights, tighten data retention limits, strengthen security requirement language, and correct any misleading security assurances.
Entity
Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC
Also known as: Marriott
Industry
OtherOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/12/ftc-finalizes-order-marriott-starwood-requiring-them-implement-robust-data-security-program-address
1923022marriottfinalorder
https://www.ftc.gov/system/files/ftc_gov/pdf/1923022marriottfinalorder.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC"
"failed to deploy reasonable security to protect consumers’ personal information"
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