Hotel WiFi GDPR Compliance: A Checklist for IT Directors
Executive Summary: Hotels collect massive amounts of personal data through captive portals. If you are collecting names, emails, or even MAC addresses for marketing, you are a Data Controller under GDPR. This checklist outlines the critical compliance requirements for European hospitality.
1. Why Hotel WiFi is a GDPR Risk
Many hoteliers mistakenly believe their WiFi provider is solely responsible for compliance. However, if you own the guest relationship and use the data for your own marketing, the legal liability rests with the hotel.
The "Legitimate Interest" Trap
Some hotels claim marketing is a "legitimate interest" to bypass consent. However, regulators explicitly state that intrusive profiling for ads requires explicit consent. You cannot simply add a line to your Terms & Conditions saying "We will email you offers."
2. The Compliance Checklist
Ensure your Captive Portal provider supports these specific features:
Granular Consent (Unbundled Opt-Ins)
You cannot bundle "Accept Terms of Use" with "Subscribe to Newsletter". These must be separate checkboxes. The marketing opt-in must be unchecked by default.
Right to be Forgotten (Data Erasure)
Your WiFi dashboard must have a "Delete User" button that purges all logs associated with a specific email or MAC address upon guest request.
Data Retention Policies
Logs should not be kept longer than necessary. While anti-terrorism laws in some countries (e.g., France, Italy) require 6-12 months retention, keeping data indefinitely is a violation. Configure auto-deletion rules.
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