Following an extensive investigation, the ICO has issued a notice of its intention to fine Marriott International £99,200,396 for data breach under the GDPR. The U.S. hotel group is the second firm to face a massive GDPR fine.
Marriott notified the ICO of a cyber incident in November 2018. A variety of personal data contained in approximately 339 million guest records globally were exposed by the incident, of which around 30 million related to residents of 31 countries in the European Economic Area (EEA). Seven million related to UK residents.
The vulnerability began when the systems of the Starwood hotels group were compromised in 2014. Marriott subsequently acquired Starwood in 2016, but the exposure of customer information was not discovered until 2018. The ICO’s investigation found that Marriott failed to undertake sufficient due diligence when it bought Starwood and should also have done more to secure its systems.
In a statement the ICO Elizabeth Denham said: “The GDPR makes it clear that organizations 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 organizations 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.
Since the investigation began, Marriot has co-operated and made improvements to its security agreements. The CEO has vowed to contest the notice of intent from the ICO.
Before a final decision is made, the ICO will consider the representations made by the company and other data protection authorities