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On 9 July 2019 Marriott International announced that UK Information Commissioner’s Office (ICO) had communicated its intent to issue a fine in the amount of £99 200 396 against the company in relation to the ‘Starwood guest reservation database’ incident that Marriott announced on 30 November 2018. In this incident a variety of personal data contained in approximately 339 million guest records globally were exposed, of which around 30 million related to residents of 31 countries in the European Economic Area (EEA), while seven million related to UK residents.

It is assumed that 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 had failed to undertake sufficient due diligence when it bought Starwood and should also have done more to secure its systems.

Marriott had co-operated with the ICO investigation and made improvements to its security arrangements since these events came to light. The company 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 other EU Member State data protection authorities and other regulators. Under the GDPR ‘one stop shop’ provisions the data protection authorities in the EU whose residents have been affected will also have the chance to comment on the ICO’s findings.