Skip to main content Skip to navigation

    Hotel GDPR compliance, documented for independent and boutique hotels

    GDPR may apply to a US hotel's processing based on an EEA establishment, targeted offers to people in the EEA, or monitoring their behavior. HotelComply documents the confirmed scope through ROPA, one-calendar-month request procedures, and vendor DPA status, delivered as a one-time Compliance Package for single properties and small portfolios.
    See the package
    One-calendar-month GDPR request proceduresROPA for hotel systemsVendor processor records$1,995 founding · $2,500 standard

    GDPR is showing up in hotel operations even when the property is not in Europe

    A California or US hotel may target people in the EEA or monitor their behavior, and nobody owns the GDPR scope review
    Access and erasure requests sit in inboxes with no one-calendar-month response clock
    PMS, channel, Wi-Fi, and CRM vendors process guest data with no DPA on file
    The only “ROPA” is a counsel memo from two years ago that does not match the current stack

    What hotel GDPR compliance documentation should contain

    A hotel GDPR file is not a privacy policy rewrite. It is evidence that you know which systems process guest and employee data, which vendors act as processors, how a one-calendar-month request gets answered, and how long records are kept. HotelComply assembles that file from the stack you already run, then leaves it with the operating team.

    What the Compliance Package puts in the GDPR file

    ROPA for hotel systems

    Records of processing for PMS, reservations, loyalty, payments, Wi-Fi, CCTV, F&B, HR, and marketing, with purpose, lawful basis, and retention notes.

    One-calendar-month guest rights procedures

    Intake, identity checks, search steps, and response windows for access, erasure, rectification, and restriction requests under the GDPR one-calendar-month period.

    Processor and DPA status

    Vendor inventory with processor vs controller notes and DPA status for the hotel systems and vendors that actually touch EU or EEA guest data.

    Retention and disposal notes

    Hospitality-specific retention context for folios, CCTV, applicant files, and loyalty records, so teams are not keeping EU guest data indefinitely.

    Transfer and sharing notes

    Where guest data leaves the property stack (channel managers, OTAs, CRMs, cloud PMS) so counsel can review transfer and sharing questions against real systems.

    Audit-ready binder

    A branded package operators can retain for owner reporting, insurer diligence, counsel review, or a regulatory inquiry. Not a dashboard rollout.

    Built around the systems that actually hold guest data

    PMS and reservationsChannel manager and OTAsPayment systemsLoyalty and CRMGuest Wi-FiCCTVHR and applicantsMarketing and messaging

    GDPR next to CCPA and CPRA, in one binder

    Request window

    GDPR rights requests ordinarily run on a one-calendar-month period. California response periods depend on the request type. The binder records the applicable deadline and any documented extension.

    What a regulator asks for first

    GDPR inspections start with records of processing, processor contracts, and how you handle erasure. California work starts with notice, sale/share, and sensitive personal information. Hotels usually need both files.

    Who it applies to

    GDPR scope depends on facts such as an EEA establishment, targeting people in the EEA, or monitoring their behavior. CCPA/CPRA applicability depends on California statutory thresholds and processing facts.
    California hotels often need both files because they serve California guests and international reservations from the same PMS. The package documents both clocks rather than pretending one statute covers the other. Documentation service

    Who this is built for

    Independent hotels

    Single properties with California and international guests that need one GDPR and CPRA file they can keep current.

    Boutique hotels

    Smaller properties documenting one-calendar-month request procedures and vendor DPAs across the systems they already run.

    Small portfolios

    Owners of a few hotels who want one consistent file per property to show lenders, buyers, or carriers, not just a privacy policy.

    A documentation service for hotels. Not a law firm, not legal advice, and not generic GDPR software.

    Frequently asked questions

    Put hotel GDPR records in place

    $1,995 per property founding price, $2,500 standard. Discovery confirms scope. The package is documentation for operators and complements qualified privacy counsel. It does not replace counsel.