Consumers Affected
344,000,000
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.
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.
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.
Entity
Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC
Also known as: Marriott
Industry
OtherOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/12/ftc-finalizes-order-marriott-starwood-requiring-them-implement-robust-data-security-program-address
1923022marriottfinalorder
https://www.ftc.gov/system/files/ftc_gov/pdf/1923022marriottfinalorder.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC"
"failed to deploy reasonable security to protect consumers’ personal information"
The FTC filed a complaint alleging that GovAssist LLC, Entry LLC, and Scott Zuckerman used deceptive paid search ads, misleading service and pricing claims, and fake reviews to deceive consumers seeking passport services. The complaint alleges violations of the FTC Act, the Impersonation Rule, and the Gramm-Leach-Bliley Act; the case will be decided by the court, and no penalty or remedy is reported as imposed.
The FTC issued its annual report to Congress describing fraud trends affecting older adults and the agency’s enforcement, education, and outreach efforts. The report is not a specific privacy enforcement action and announces no penalty or remedy.
The FTC referred a complaint against REPS & Company Inc. and company executives, alleging they bypassed ticket-issuer security controls and purchasing limits to acquire millions of tickets for resale. The complaint was filed by the Department of Justice, and the case will be decided by the court; the press release does not report a penalty or other remedy imposed.
$106.8M
A federal court entered a $106.8 million default judgment against corporate defendants in an alleged debt-relief scheme that impersonated banks and government entities and targeted seniors and veterans. The judgment permanently bans the defendants from the debt-relief industry and imposes additional prohibitions, including on impersonation, telemarketing, and misrepresentations.
The FTC sued Digital Forensics Corporation LLC and affiliated defendants, alleging they misled sextortion victims with promises of investigative and monitoring services that often were not provided, and used fake positive reviews. A federal court granted the FTC’s request to temporarily halt the defendants’ activities; the complaint remains for the court to decide.
The FTC alleged that Greenway Auto Group advertised vehicle prices thousands of dollars below the amounts consumers actually paid and used mailers falsely suggesting recipients had won cash prizes. Greenway agreed to an order requiring transparent pricing and prohibiting deceptive prize mailers and other misrepresentations; the press release does not state a monetary penalty.