The controller is a person or company that determines the purposes and the means of processing data. Travel industry perspective. EU data protection rules, also known as the EU General Data Protection Regulation (or GDPR), describe different situations where a company or an organisation is allowed to Users also have the right to request transmission of the data directly to other organizations. It’s important to determine what consent you have been obtaining for this information. Data protection by design means that your company should take data protection into account at the early stages of planning a new way of processing personal data. Think again. While being one of the more well-known legal bases for processing personal data, consent is only one of six bases mentioned in the General Data Protection Regulation (GDPR). It does not include data where the identity has been removed (anonymous data). Ensure that you set up the right procedures to effectively detect, report, and investigate a personal data breach. Most marketing processes in online travel agencies are based on user experience personalization. The processor is a person (other than an employee of the data controller) or a company that processes the data on behalf of the controller. However, "failing to untick a box" does not comply with any of the five elements of consent under the GDPR. No such luck. It starts out just as vague as the article on processors’ responsibilities, saying “ … the controller and the processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk …” but then it gets more specific, with some specific measures that should be taken “as appropriate” (we’ll come back to that wording later): pseudonymization and encryption of personal data. Foursquare succeeds at communicating the purposes of data use and providing control over personal data. The Data Privacy Act is broadly applicable to individuals and legal entities that process personal information, with some exceptions. Lower level – up to €10 million or 2 percent of total worldwide annual global revenue for the latest financial year for smaller breaches. Practical recommendations for travel companies to prepare for GDPR, Create the new format for obtaining user consent, Give users access to the personal data you stored about them, Customer Experience Personalization in Travel and Hospitality Using Behavioral Analytics and Machine Learning, How Airline Industry Streamlines Check-In and Boarding with Digital Self-Services, Corporate Travel Management: Driving Technological Transformation in the World of Business Travel. One of the most important steps for wholesalers today is to upgrade contracts in place that contain the provision about protection of individual rights. For instance, OTAs send personal data to hotels, other accommodation providers, car rental services, and airlines that may be within or beyond the EU, but still render services to EU citizens. The DPO could be an existing staff member who takes the responsibility for data protection compliance or companies can hire an external expert for this role. The use of data masking is common in online transactions where, for example, most of your credit card number or email address is replaced by Xs in receipts or stored forms (XXXX XXXX XXXX 1243 or d*@outlook.com. Travel industry perspective. is devoted to the responsibilities that the law lays on the shoulders of data controllers. The same paragraph goes on to say that you must also take into account “the risk of varying likelihood and severity for the rights and freedoms of natural persons,” and then expands upon that to make it clear that “In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized [sic] disclosure of, or access to personal data transmitted, stored or otherwise processed.”. Whereas pseudonymization can be accomplished by several different methods, including scrambling or blurring, the most common way of pseudonymizing is through. The controller, as the name implies, is ultimately in control – this is the entity that determines the purposes and means of the processing of personal data. If you run a local tours and activities service that doesn’t collect any personal data besides emails and you don’t systematically face European tourists, it’s likely that you don’t need a DPO just yet. It is a centralized repository, which may be physical or virtual, may be analog or digital, used for the storage, management, and dissemination of data including personal data. The regulation lists some main identifiers such as name, identification number, location data, or some factors specific to the physical, cultural, or social identity of that person. Whereas pseudonymization can be accomplished by several different methods, including scrambling or blurring, the most common way of pseudonymizing is through masking. The purpose. It simply reiterates that “In particular, the controller should be obliged to implement appropriate and effective measures and be able to demonstrate the compliance of processing activities with this Regulation, including the effectiveness of the measures.”. All airline websites collect user emails addresses so they can send an e-ticket. Modern cryptographic systems are generally divided into two categories: symmetric (private key) and asymmetric (public key). Regulation enforcement must be in place after a two-year transition period, on May 25, 2018. The best way to contact your customers for consent is to include multiple tick boxes for each type of consent you need. 3 Prior to giving consent, the data subject shall be informed thereof. Regulation compliance is a complicated issue that all company employees must support. Companies must present the consent in easily accessible form that is written in clear language. All categories below are required (45 CFR 46.116) for written informed consent unless “if applicable” is noted. When a consumer hands over their email address for one purpose, this does not mean they can be contacted for any reason under the sun. Travel industry perspective. In this article, we will only be dealing with those that address aspects of securing the personal data, but be aware that the processor’s responsibilities extend beyond that. We discussed the new and strict requirements for consent to be considered valid, which are laid out in Article 7 (Conditions for Consent), and how this impacts “bundled” agreements that many companies have used in the past to obtain consent. Deb is owner and CEO of TACteam (Training, Authoring and Consulting) and has contracted with Microsoft, Intel, HP, Prowess Consulting, Sunbelt Software, GFI Software, ConfigureSoft, 2X Software and other software and hardware companies. Article 8 only applies when the controller is: offering information society services (ISS) directly to children; and; wishes to rely on consent … ... does not prescribe a specific retention period for personal data. The others are: contract, legal … Continue reading Consent Instead, the GDPR simply requires that there be sufficient documentation to demonstrate that consent was given. The GDPR sets rules relating to the protection of people’s fundamental rights and freedoms regarding the processing of personal data. The conditions that make processing of personal data lawful even without consent have not materially changed from the formulation contained in the current law (Data Protection Act 1988). A key part of this is marketing consent. The full text of the regulation includes 99 articles that contain the rights of individuals and obligations placed on organizations. The Regulation requires communicating clear purposes of information use. According to the GDPR, organizations must appoint a data protection officer (DPO) in some circumstances. You have legal grounds for processing all the data you use. Recital 32 seals the deal to the question though by stating that an oral statement may be sufficient as a clear affirmative act sufficient for consent. 1 The data subject shall have the right to withdraw his or her consent at any time. is the process of translating data into another form that prevents other people who don’t have access to a “key” or password from being able to read it. Penalties will be used in addition to or instead of the regulatory corrective powers. and how this impacts “bundled” agreements that many companies have used in the past to obtain consent. From a data handling perspective, the regulation applies to both ‘controller’ and ‘processor’ companies. It starts out just as vague as the article on processors’ responsibilities, saying “ … the controller and the processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk …” but then it gets more specific, with some specific measures that should be taken “as appropriate” (we’ll come back to that wording later): pseudonymization and encryption of personal data. Some of these requests can be addressed autonomously. The regulator can give a reprimand where the GDPR provisions were infringed. Last month, in my article titled Think you’re GDPR compliant? As a general rule, whenever you have difficulty meeting the standard for consent, this is a warning sign that consent may not be the most appropriate basis for your processing. The most important of these is Article 32, Security of processing. Other lawful bases may still be available. Travel industry perspective. The GDPR applies to the processing of personal data in all member states of the European Union. ID / Passport details: names, postal addresses, race, origin, biometric data; Contact information: email addresses, telephone numbers; Sensitive data: financial and payment information; HR records: current and former employee details. What does consent mean under GDPR? Companies should understand how their partners inform data subjects about the transfers they make. But airlines must ask for the explicit consent again if they were to use this data for email campaigns. Compare this penalty amount with the corresponding. The scaremongering: You won’t be able to … Massive data exchange via APIs is common practice in the travel industry. More specifically, ... Back up data often. 2 The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Controllers are required to “implement appropriate technical and organizational [sic] measures to ensure and to be able to demonstrate that processing is performed by this Regulation.”, doesn’t really clarify this very much. This will help analyze what data you have, why you store it, what you want to do with it, and how long should you keep it. Processing personal data is generally prohibited, unless it is expressly allowed by law, or the data subject has consented to the processing. The data subject can ask to transfer his or her personal data from one electronic processing system to another. Legitimate interests: when a private-sector organisation has a genuine and legitimate reason (including commercial benefit) to process personal data without consent, provided it is not outweighed by negative effects to the individual’s rights and freedoms. The GDPR uses wording that, at first glance, suggests that the use of pseudonymization and encryption is only a suggestion, not a requirement. It even says (in Article 32) you can take into account “the state of the art, the costs of implementation and the nature, scope, context, and purposes of processing.”. A lot of the GDPR’s main principles are similar to those in the current Data Protection Directive. The data must be provided in a structured and commonly used electronic format. How does Secure Flight work? If travel companies manage to introduce clear communication and allow travelers to shape promoted travel offers, there will be a real value in meaningful and up-to-date personalization. More on that in the next section. Data protection officer. because a cipher – an encoding method – was used to disguise it. Do you provide security measures to protect the data from a breach? Masking techniques involve hiding parts of the data by replacing it with random characters or with other data. One popular myth: Under the GDPR you need consent to contact customers. Seeking consent is usually the simplest way to ensure that you may lawfully use data about a person but it is not the only legal ground. The processor is the entity that actually performs the processing of data, and the processing entity is hired or appointed by the controlling entity. Get immediate results. Travel Industry Perspective. 3. In accordance with this principle, a data controller must take all necessary technical and organisational steps to implement the data protection principles and protect the rights of individuals. Travel services, from airport parking lots to hotel room bookings, must explain to customers why they are capturing their personal data, who is requesting that data, and who else will have the access to it. Data blurring is used to pseudonymize graphic data (drawings, photos, videos and diagrams), such as the blurring out of faces in videos to protect the identities of those captured by the camera, or blurring of the sections of a picture of a social security card where the sensitive information (name, card number) is displayed. The GDPR’s main goal is to replace the Data Protection Directive 95/46/EC 1998 and to introduce a single data protection law that increases privacy for individuals by enforcing stronger security rules for companies that handle personal data. Controllers are required to “implement appropriate technical and organizational [sic] measures to ensure and to be able to demonstrate that processing is performed by this Regulation.”, Unfortunately, the relevant recital (Recital 74) doesn’t really clarify this very much. It also needs to be separated from other terms and conditions. In subsequent articles, we’ll address additional requirements that include notification, documentation, and reporting, as well as the appointment and role of a data protection officer. Ultimately, the change applies to almost all travel companies that offer products and services in Europe and process personal data of EU citizens as well as other users, located within its borders. For all reservations booked on or after October 1, 2009 for travel on Southwest Airlines, you must provide your information before a boarding pass can be issued. . In some circumstances, companies need to appoint a data protection officer, who will be prepared for information requests from users. Data privacy or information privacy is a branch of data security concerned with the proper handling of data – consent, notice, and regulatory obligations. Booking.com, the largest flight, and accommodation OTA, collects a broad spectrum of personal details, including names, travel purposes (leisure or work), travel with children, emails, payment data, etc. Blurring has some serious drawbacks as a means of pseudonymization, in that computer algorithms can be used to easily match pixelated images to their original, unblurred versions. Be sure your software can export data in common formats, like csv or xlsx. When am I required to update my Secure Flight Passenger Data? However, there are new elements and important enhancements. You should be able to provide users with access to their personal data and information about how this personal data is being processed. Unintended Consequences: GDPR impacts you didn’t see coming. For example, when an Emirates-based hotel sells to EU travel agents or third-party wholesalers based in Europe, it falls under the Regulation. Ignore them. InteleTravel.com retains only that information which you voluntarily give to us. Personal data, or personal information, means any information about an individual from which that person can be identified. GDPR didn’t make the sky fall on Friday, 25th of May but it certainly caused an influx of myths, scaremongering and emails looking for our consent. However, no matter how meticulous you are about following all the rules and documenting the process to show that consent was, per Recital 32, “given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of the data subject’s agreement to the processing of personal data relating to him or her,” it’s vital to understand that this is only one step of many that must be taken to fully comply with the GDPR. Secure Flight matches the name, date of birth and gender information for each passenger against It differs from anonymized data in that it’s possible to restore the original state of pseudonymized data by replacing the artificial identifiers with the original ones. Travel companies will be directly affected thanks to the personal and sensitive data they gather and process. It’s short, but its provisions are broad in scope and not very specific. The EU’s General Data Protection Regulation has been in full force for almost three months as of this writing, but many companies are still struggling with the challenges of attaining and maintaining compliance with its numerous complex requirements. From the travel industry aspect, personal data could include the following types and sources of information: The person whose personal data is processed is called the data subject. Think you’re GDPR compliant? The consent form should be written in the second person (e.g., “You have the right to …”) and in easy to understand language. Article 8 imposes conditions on children’s consent, but it does not require parental consent in every case. The GDPR enforces extremely high penalties divided into two broad categories: The amount of the fine depends on what article’s rules are violated. Every travel business works with users’ personal data and supplier information. Think again, I wrote about how consent can be key to proving that your organization’s collection, storage, and processing of personal data of individuals is lawful under the GDPR. Data blurring is used to pseudonymize graphic data (drawings, photos, videos and diagrams), such as the blurring out of faces in videos to protect the identities of those captured by the camera, or blurring of the sections of a picture of a social security card where the sensitive information (name, card number) is displayed. According to the GDPR, companies should report certain types of data breach to the Information Commissioner’s Office within 72 hours. Infringements of the controller or processor organization’s obligations, including data security breaches, will result in the lower level fine. ... use or disclose personal data unless with the individual’s consent or if the collection, use or disclosure without consent is required or authorised under the PDPA or any other written law. The EU Parliament approved and adopted the GDPR on April 14, 2016. Define data collection purposes and uses cases; Outline the time period for which the personal data will be stored; Send a copy of all their data that is held; The organization is a public authority or body. Contract - the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. Consent is one of the trickiest parts of the General Data Processing Regulation (GDPR).Consent under the GDPR is not easy, especially in practice and when you start looking at it from a perspective of specific personal data processing activities whereby consent turns out to be the only or most appropriate legal basis for the lawful processing of personal data. The adoption of the General Data Protection Regulation (GDPR) has become one of the hottest topics across a broad spectrum of industries. She’s an author of and contributor to over 25 books on computer technology, including “Scene of the Cybercrime,” based on her previous experience as a police officer and police academy instructor. To some extent, your obligations are dependent on which of these categories you fit. However, it must be noted that the transmission of information via the Internet is not completely secure and while Key Travel will endeavour to ensure that any information entered into the Online Booking Services is secure, it does not guarantee the security of the data transmitted to or from such services. Organize an information audit. It does not mean that you have to rely on consent for your processing of the patient’s personal data. Travel industry perspective. The regulation applies directly to all EU member states and has an extraterritorial scope as it enforces non-EU companies to comply with data protection obligations when processing personal information from any individual located in the EU. You must be ready for such requests. The user must complete an affirmative action. Encryption is a complex subject, and an in-depth discussion is beyond the scope of this article, but for purposes of GDPR compliance, the stronger the encryption that you use to protect personal data, the better. Travel industry perspective. You’ll recall that the GDPR differentiates between two entities that are responsible for complying with its mandates regarding personal data: To some extent, your obligations are dependent on which of these categories you fit. The GDPR structure. As use cases grow in number and personal information is applied across various departments, it becomes difficult to track all the types of information collected. It doesn’t require any enabling legislation be passed by EU governments. In this article, we’ll discuss general positions and some specifics of the GDPR adoption in the travel industry. Holiday offers, low-cost airlines tickets, or comfortable hotel service suggestions motivate people. 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