ICO fines Marriot after it fails to secure systems of a company it acquired

Updated: Apr 14, 2020

Following an extensive investigation, the ICO has issued a notice of its intention to fine Marriott international £99,200,396 for infringements of GDPR.

You can read the press release on the ICO website here

The proposed fine relates to a cyber incident which was notified to the ICO by Marriott in November 2018. A variety of personal data contained in approximately 339 million guest records globally have been exposed through the incident, of which around 30 million related to residents of 31 international locations in the European economic area (EEA). Seven million related to UK citizens.

It is believed the vulnerability commenced when the systems of the Starwood hotels group had been compromised in 2014. Marriott acquired Starwood in 2016, but the exposure of customer information was not found until 2018. The ICO’s investigation discovered that Marriott didn’t undertake sufficient due diligence when it bought Starwood and should additionally have done more to secure its systems.

Marriott has co-operated with the ICO investigation and has made improvements to its security arrangements since these events came to light. The corporation will now have an opportunity to make representations to the ICO as to the proposed findings and sanction.

The ICO has been investigating this case as lead supervisory authority on behalf of different European Member state data protection authorities. It has additionally liaised with other regulators. Under the GDPR ‘one-stop-shop’ provisions, the data protection authorities in the European whose residents were affected will also have the chance to comment on the ICO’s findings.

The ICO will consider carefully the representations made by the company and the other concerned data protection authorities before it takes its final decision.

Information Commissioner Elizabeth Denham said “The GDPR makes it clear that organisations 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 real value so organisations 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.”