TravelTech & OTAs
Liability Check
TravelTech & OTAs handling passport details, itineraries, and real-time location data face immense scrutiny, with potential penalties up to ₹250 Crore for data breaches and non-compliance.
Why TravelTech & OTAs is at Risk
From booking flights on MakeMyTrip to hotel check-ins via OYO, travel platforms gather a treasure trove of personal data. This includes **passport numbers**, **travel history**, **payment details**, and even **health information** for travel insurance. Sharing this data across a complex ecosystem of airlines, hotels, car rentals, and payment gateways without explicit, granular consent or clear purpose limitation can lead to severe DPDP violations. The **cross-border transfer** of personal data, a common practice in global travel, adds another layer of compliance complexity, making you a prime target for high penalties.
Common Violations
- 1.Retaining passenger passport details and visa information beyond the required travel period and legal obligations.
- 2.Sharing customer flight/hotel booking patterns with marketing affiliates for personalized ad targeting without explicit consent.
- 3.Using location data collected during travel (e.g., via app) for purposes unrelated to the booking without informing the Data Principal.
The Immediate Fix
Conduct a data mapping exercise to identify all personal data collected, stored, and shared across your entire travel ecosystem. Immediately review your consent mechanisms, ensuring clear, granular opt-ins for all data sharing with partners (airlines, hotels, insurance). Update your privacy policy to explicitly detail how data is used and who it's shared with, especially for cross-border transfers.
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Need help checking your business?
- Start with the free self-check to find questions for your team.
- Our paid gap assessment takes four weeks. We check your apps, documents and records, then list what needs fixing.
- Fixing the agreed gaps takes two to three months. A final assessment checks the completed work.
Save your results and discuss the questions with your team.
Next step after the audit
The audit shows the gaps. Sanctum closes them. One programme covers legal position, data map, gap analysis, implementation, tooling, training, a written readiness opinion, and breach cover, under one accountable owner. See the all-in-one programme
What Should You Do Next?