Court Rules
All enforcement actions
Consent DecreeLow Risk

FTC Orders Marriott to Implement Data Security Program After Breaches

Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLCDecember 20, 2024Federal Trade Commission

Consumers Affected

344,000,000

Summary

The FTC finalized an order against Marriott International and Starwood Hotels for failing to implement reasonable data security, which led to three data breaches affecting over 344 million customers. The companies must implement a comprehensive security program, delete unnecessary personal information, allow U.S. customers to request deletion, and restore stolen loyalty points. They are also prohibited from misrepresenting their data security practices.

Remedy

Marriott and Starwood must establish a comprehensive information security program, implement a data retention policy to keep personal information only as long as necessary, provide a website link for U.S. customers to request deletion of personal information, review and restore stolen loyalty points upon request, and are prohibited from misrepresenting their data collection, use, and security practices.

Compliance ProgramData DeletionInjunction

Contract Impact

In-house legal teams should review all customer-facing agreements (e.g., hotel registration terms, loyalty program terms), vendor agreements (particularly those involving data processing or access to personal information), and any data processing addendums. Specific clauses to scrutinize include: (1) data security standards and representations, ensuring they align with 'reasonable' practices and do not overstate security; (2) data retention and deletion provisions, confirming they allow for deletion upon customer request and comply with data minimization principles; (3) breach notification obligations, verifying timely and comprehensive notification requirements; and (4) loyalty program data handling terms. Changes may be needed to add explicit customer deletion rights, tighten data retention limits, strengthen security requirement language, and correct any misleading security assurances.

Contract Search Terms

reasonable data securitydata retention policycustomer deletion request mechanismbreach notification clauseinformation security programloyalty program data protectionpersonal information retention scheduledata minimization policysecurity representation clause

Violation Types

Entity Details

Entity

Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC

Also known as: Marriott

Industry

Other

Official Sources

Source Evidence

Entity Name
"Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC"
Violation Types
"failed to deploy reasonable security to protect consumers’ personal information"

Related Enforcement Actions

FTC

Vanilla Chip LLC

$750K

The FTC finalized an order against Vanilla Chip LLC (doing business as TruHeight) and its principals for deceptively advertising height-enhancing supplements for children and teens without scientific evidence. The company also used fake reviews and incentivized 5-star ratings. The order requires a $750,000 payment and prohibits false health claims and deceptive review practices.

FTC

RentGrow Inc.

$2.3M

The FTC alleged that RentGrow, a tenant screening company, violated the Fair Credit Reporting Act (FCRA) by failing to use reasonable procedures to ensure the accuracy of its reports, including by reporting duplicate records and failing to disclose data sources. RentGrow agreed to pay a $2.25 million penalty and is prohibited from further FCRA violations and from misrepresenting dispute outcomes.

FTC

Handy Technologies

The FTC and New York Attorney General took action against Handy Technologies for deceptive earnings claims and failure to disclose fees and fines that led to millions of dollars being withheld from workers' wages. The FTC is sending over $2.7 million in refunds to 62,893 affected consumers.

FTC

Hopper Inc.

$35.0M

The FTC alleged that Hopper, a travel booking app, charged consumers hidden and pre-selected fees (Tip and VIP Support) without their consent, misrepresented the benefits of VIP Support and Price Freeze services, and failed to clearly disclose total prices. Hopper agreed to pay $35 million for consumer redress and is prohibited from misrepresenting fees under a proposed order.

FTC

Publishing.com LLC

$1.5M

The FTC finalized a settlement with Publishing.com LLC and its principals for misleading consumers about potential earnings from self-publishing products. The company will pay $1.5 million and is prohibited from making unsubstantiated earnings claims, failing to disclose refund terms, and misrepresenting endorsements and reviews.

FTC

Federal Trade Commission

The FTC is seeking public comment on a proposed policy statement addressing concerns that AI companies may be manipulating AI system outputs contrary to consumer expectations for objectivity and accuracy. The statement explains that such conduct could be considered deceptive under Section 5 of the FTC Act. The public comment period runs until July 31, 2026.