Court Rules
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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"

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