1.1 In its everyday business operations, The Ritz London makes use of a variety of data about identifiable individuals, including data about:
- Current, past and prospective employees
- Guests and customers
- Users of its websites
- Other stakeholders
In collecting and using this data, The Ritz London is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.
The purpose of this policy is to set out the relevant legislation and to describe the steps The Ritz London is taking to ensure that it complies with it.
This control applies to all systems, people and processes that constitute the organisation’s information systems, including directors, employees, suppliers and other third parties who have access to The Ritz London systems.
2. Privacy and Personal Data Protection Policy
2.1 The General Data Protection Regulation
The General Data Protection Regulation 2018 (GDPR) is one of the most significant pieces of legislation affecting the way that The Ritz London carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is The Ritz London’s policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.
There is a total of 26 definitions listed within the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:
Personal data is defined as:
any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
2.3 Principles Relating to Processing of Personal Data
There are a number of fundamental principles upon which the GDPR is based.
These are as follows:
- Personal data shall be:
(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
- The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).
The Ritz London will ensure that it complies with all these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.
2.4 Rights of the Individual
The data subject also has rights under the GDPR. These consist of:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Each of these rights are supported by appropriate procedures within The Ritz London that allow the required action to be taken within the timescales stated in the GDPR.
These timescales are shown below
Timescales for data subject requests
Data subject request Timescale
The right to be informed When data is collected (if supplied by data subject) or within one month (if not supplied by data subject)
The right of access Within one month
The right to rectification Within one month
The right to erasure Within one month
The right to restrict processing Without undue delay
The right to data portability Within one month
The right to object On receipt of objection
Rights in relation to automated decision
making and profiling. Not specified
You are entitled to implement any of your rights above by writing to the Data Privacy Officer at The Ritz London, 150 Piccadilly London W1J 9BR or emailing firstname.lastname@example.org
We require proof of your identity before we can disclose personal data. A scan / copy of your passport, driving licence or other government approved photographic identification will be accepted as proof. Without this proof of identification, we cannot accept your request.
2.5 Lawfulness of Processing
There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is The Ritz London policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.
Unless it is necessary for a reason allowable in the GDPR, The Ritz London will always obtain explicit consent from a data subject to collect and process their data. In case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights about their data explained, such as the right to withdraw consent at any time. This information will be provided in an accessible form, written in clear language and free of charge.
Where consent is given, a record will be kept documenting how and when consent was given.
If the personal data is not obtained directly from the data subject, then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.
You can opt out of receiving promotional emails from us at any time.
2.5.2 Performance of a Contract
Where the personal data collected and processed is required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a dining or room reservation cannot be made without a name, email address and credit card details.
2.5.3 Legal Obligation
If the personal data is required to be collected and processed to comply with the law, then explicit consent is not required. This may be the case for some data related to employment, financial, taxation or the scanning of non-UK passports of hotel guests on arrival for room reservations for example, and for many areas addressed by the public sector.
2.5.4 Vital Interests of the Data Subject
In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. The Ritz London will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data.
2.5.5 Task Carried Out in the Public Interest
Where The Ritz London needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.
2.5.6 Legitimate Interests
If the processing of specific personal data is in the legitimate interests of The Ritz London and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.
We process personal information for certain legitimate business purposes, which include some of the following
- To provide information on our products and services to business clients.
- Where processing enables us to enhance, modify, personalise or otherwise improve our services / communications for the benefit of our guests. We collect our guests’ room and dining preferences, dietary requirements and public ally available images of our guests for staff recognition for these purposes.
Business cards that have been provided to The Ritz London during sales office visits or at trade shows will be used to provide clients with relevant information on The Ritz products and services. This data will be retained until the data subject opts out of receiving marketing emails.
Media contact details are used for legitimate interests.
Hotel and dining guest profiles, which contain information such as number of visits, spend, preferences and complaints are collected to ensure we provide guests with exceptional service levels.
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regards and take account of these rights.
2.5.7 Sharing of data
We may share your information with systems that allow us to fulfil your reservation such as sending out confirmation and post stay emails, guest questionnaires, restaurant order information and transferring your booking details from online travel agent’s websites into The Ritz London’s property management system. Any personal data which is shared will only be with companies who have appropriate safeguards in place to protect your data.
2.5.8 Data collected
The Ritz London collects data such as customer name, postal address, email, address, telephone number of visits, spend, guest preferences, dietary requirements and CCTV images.
2.6 Privacy by Design
The Ritz London has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect, or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.
The data protection impact assessment will include:
- Consideration of how personal data will be processed and for what purposes
- Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
- Assessment of the risks to individuals in processing the personal data
- What controls are necessary to address the identified risks and demonstrate compliance with legislation
Use of techniques such as data minimization and pseudonymisation will be considered where applicable and appropriate.
2.7 Contracts Involving the Processing of Personal Data
The Ritz London will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.
2.8 International Transfers of Personal Data
Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.
The data received from The Ritz London website cookies is anonymized data, therefore individuals cannot be identified.
Adjusting your browser’s cookie settings
If you are using Internet Explorer 11, 10, 9, 8, 7, 6
Choose Tools then
Select the Privacy tab,
Under settings, select Advanced
Check Override automatic cookie handling
Check and choose if you want to allow, block or be prompted for first and third-party cookies.
If you are using Internet Explorer 5.0 or 5.5:
Choose Tools, then
Click the Security tab
Click on Custom Level
Scroll down to the sixth option to see how cookies are handled by IE5 and change to Accept, Disable, or Prompt for action as appropriate.
If you are using Internet Explorer 4.0
Choose View, then
Click the Advanced tab
In Internet Explorer 3.0: You can View, Options, Advanced, then click on the button that says Warn before Accepting Cookies.
If you are using Chrome
At the top right, click More and then Settings
At the bottom, click Advanced
Under “Privacy and security,” click Content settings
From here, you can,
Turn on cookies: Next to “Blocked,” turn on the switch
Turn off cookies: Turn off Allow sites to save and read cookie data
If you are using Safari
Click Privacy, then do any of the following:
Always block cookies: Select ‘Block all cookies’
If you are using Firefox
Select Options from the right side of the drop-down menu.
Click Privacy & Security tab
In History, select the use custom settings for history option in the drop-down menu of the panel’s History section.
There will you will have the option to tick or untick, always use private browsing mode, remember my browsing and download history, remember search and from history, accept cookies from web sites or clear history when Firefox closes.
2.10 Data Protection Officer
A defined role of Data Protection Officer (DPO) is required under the GDPR if an organisation is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.
Based on these criteria, The Ritz London does not require a Data Protection Officer but a Data Privacy Officer has been appointed.
2.11 Breach Notification
It is The Ritz London’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. In the event that a breach is likely to result in a high risk to the rights and freedoms of an individual, The Ritz will notify those concerned directly. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.
Under the GDPR the relevant DPA has the authority to impose a range of fines of up to four percent of annual worldwide turnover or twenty million Euros, whichever is the higher, for infringements of the regulations.
Within a breach notification, the following information will be outlined:
- The nature of the personal data breach, including the categories and approximate number of individuals and records concerned
- The name and contact details of the Data Privacy Officer
- An explanation of the likely consequences of the personal data breach
- A description of the proposed measures to be taken to deal with the personal data breach
- Where appropriate, a description of the measures taken to mitigate any possible adverse effects
2.12 Addressing Compliance to the GDPR
The following actions are undertaken to ensure that The Ritz London complies at all times with the accountability principle of the GDPR:
- The legal basis for processing personal data is clear and unambiguous
- All staff involved in handling personal data understand their responsibilities for following good data protection practice
- Training in data protection has been provided to all staff
- Rules regarding consent are followed
- Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
- Regular reviews of procedures involving personal data are carried out
- Privacy by design is adopted for all new or changed systems and processes
- The following documentation of processing activities is recorded:
- Organisation name and relevant details
- Purposes of the personal data processing
- Categories of individuals and personal data processed
- Categories of personal data recipients
- Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
- Personal data retention schedules
- Relevant technical and organisational controls in place
These actions are reviewed on a regular basis as part of the management process concerned with data protection.
2.13 Data Security
Any personal data in hard copy format will be kept in a locked filing cabinet, drawer or safe, with restricted access. Confidential paper records will not be left unattended or in clear view anywhere with general access. All electronic devices are password-protected to protect the information on the device in case of theft. Digital data is coded, encrypted or password-protected, on a network drive that is regularly backed up on and off-site. All members of staff are provided with their own secure login and password, and every computer regularly prompts users to change their password. Emails containing sensitive or confidential information are password-protected if there are unsecure servers between the sender and the recipient. The security of The Ritz London’s computer and storage systems, and access to them, is continuously monitored.
The Ritz London understands that recording images of identifiable individuals constitutes as processing personal information, so it is done in line with data protection principles.
The hotel operates a multi camera, multi-screen, digital CCTV system, which is monitored in the public areas to ensure our guests and members of staff’s safety or for investigative purposes. Cameras are only placed where they do not intrude on anyone’s privacy and are necessary to fulfil their purpose.
All CCTV footage will be kept for a period of time for security purposes, after which time will self-delete. Any CCTV footage which has been locked and saved on the system for investigative purposes is deleted once the case is completed.
2.15 Data Retention
Data will not be kept for longer than is necessary. Marketing data will be kept for as long as the consent is not withdrawn or three years after the last positive communication (i.e. no links have been clicked on a marketing email). Records with financial data will be retained for seven years. Personal data may be processed on the basis that The Ritz London has a legal obligation to perform such processing and has statutory retention periods of seven years. You can request information on our retention periods by emailing our Data Privacy Officer (details at the end of the policy).
Passport scans of our hotel guests will be kept for one year after the guest’s hotel stay.
If you have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website at www.ico.org/concerns or write to them at:
Information Commissioner’s Office
2.18 Contact details for the Data Privacy Officer at The Ritz London
Data Privacy Officer
The Ritz London
The Ritz London, 150 Piccadilly, London W1J 9BR Tel: +44 (0) 20 7493 8181