Hospitality Industry: Privacy Policies and Compliance
Question
Your internship assignment for this week is with the Office of the Corporate Counsel & Chief Privacy Officer.
Padgett-Beale's Chief Privacy Officer has invited you to "shadow" the company's internal investigators as they look into a privacy problem that was uncovered in the Resort Operations organization (see "Background Information" at the end of this message). Your recent experience working in that organization is viewed as a plus since you may have seen or heard something during your time in Resort Operations and Guest Relations.
The CPO has also asked you to assist with identifying a set of appropriate and relevant updates to the company's internal training program for staff members with access to guest information. The goal of these updates should be to strengthen the training provided to staff so that they understand (a) the importance of maintaining guest privacy and (b) the consequences that may be imposed upon staff who are found to have violated company rules and policies regarding guest privacy.
To begin, read the Background Information section below. Then consult the course readings and do additional research into the privacy, data security, and liability issues surrounding the stated privacy problem. Next, identify 3 to 5 specific recommendations for appropriate and relevant updates to the Guest Relations staff training program. Remember to focus your research and recommendations upon the hospitality industry (specifically hotels).
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Summarize your research and present your recommendations in a 3 to 5 paragraph briefing paper. Please remember to list and cite your sources (APA format preferred).
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Background Information
Special requests from guests are entered into the reservation database for use by front desk, concierge, housekeeping, and maintenance personnel. Food service personnel may also need to access this information in order to address special dietary needs. Guests may enter the information themselves using a web-based form or a call center operator may enter it on a guest's behalf.
The Chief Privacy Officer recently became aware of a disturbing practice in which anonymous staffers have been posting "outrageous guest requests" under the "Humor" section of employee bulletin boards in the Resort Operations staff locker rooms. Some of these postings have included guest names and room numbers along with names and ages of children. This practice is a shocking violation of guests' privacy and could seriously harm the company's reputation if the practice were to continue. The bulletin boards have been moved to the semi-public hallway outside the locker rooms as a first step towards stopping this behavior.
A deeper investigation into the situation revealed that the recently revised guest relations privacy policy has strong protections in place that detail (a) who is allowed to access guest information and (b) the permitted uses of guest information. The consequences for violations, as listed in the policy, range from a two-week suspension without pay to termination of employment.
For examples of guest privacy policies, please see these resources:
1. https://www.lhw.com/Privacy-Policy
2. https://www.ihcltata.com/privacy-policy/
3. https://www.fourseasons.com/privacy/
Note: for the purposes of writing your discussion response and critiques, you may assume that Padgett-Beale's guest privacy policy is substantially similar to one or more of the above example policies.
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Solution
Hospitality Industry: Privacy Policies and Compliance
The hospitality industry is full of many issues, and privacy is one of the most significant issues in the industry due to the service type. All the issues are associated with the interaction and management variables of privacy including its collection, management and use. Most of the issues raised in the hotel industry are related to providing quality services, but the growing need to know and understand the customer has increased the use of personal information (Culnan & Armstrong, 1999). While this is a good move for marketing and other related components, it presents an exposure avenue to a customer’s privacy in the process.
One of the most vital ways is to train staff to collect and handle private and identifying information about clients. One way is to develop a culture where information access is controlled to limit access to that kind of information. The consequences of violating privacy policies and provisions of an institution should be clearly and concisely established. With the consequences already elaborated to the staff, they should also be taught the right way to handle privacy issues. In some cases, using countermeasures of similar measures may be unconventional but effective. Care must be taken when using the unconventional to avoid complications associated with the legality of the measures used.
Knowing a customer and their preferences are good, but hotel staff must be taught how to use information. It is necessary to have an information access control policy to address elements of privacy and the identity of customers. It is vital to train staff on the uses of the information they can access. Any use outside the listed ones should be considered a violation of policy and be punished appropriately. It controls the employees and ensures that damage control is in place should the information be accessed. The compliance should be made across the board and apply to all staff members, not just those who have access to the data. Employees should be encouraged to report noncompliance to provisions of the policies directly and indirectly related to privacy and identity.
Reference
Culnan, M. J., & Armstrong, P. K. (1999). Information privacy concerns, procedural fairness, and impersonal trust: An empirical investigation. Organization Science, 10(1), 104-115.
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