DPDP Compliance for Travel & Hospitality
Travel platforms process passport data, travel patterns, hotel stays, and location history. DPDP compliance requires careful handling of some of the most revealing personal data categories.
Travel Data: A Window Into Personal Lives
Travel and hospitality platforms — MakeMyTrip, OYO, Ixigo, and others — collect data that reveals intimate life details. Where someone travels, with whom, how often, and the type of accommodation they choose paints a comprehensive personal picture.
The Booking Data Trail
A single hotel booking generates:
- Full legal name and phone number
- Government ID or passport data
- Co-traveler names and relationships
- Travel dates revealing work patterns and personal vacations
- Location data showing cities visited
- Payment data linked to the specific trip
Under DPDP, each of these data points has consent, retention, and purpose limitation requirements. Most travel platforms process all of this under a single, broad consent at booking time.
Guest Data: Hotels as Sub-Processors
When you book through MakeMyTrip, your personal data flows to the hotel property. The hotel:
- Checks you in using your government ID
- May photograph your ID for security
- Records room preferences and special requests
- Stores your data in their own PMS (Property Management System)
Under DPDP, the booking platform must ensure that hotel partners maintain adequate data protection. But most hotels — especially smaller properties — have minimal data governance. This creates a significant accountability gap.
The Passport Problem
International travel bookings require passport data. Under DPDP:
- Passport data must be stored with the highest security classification
- Retention should be limited to the booking/travel period plus regulatory minimum
- Most platforms retain passport data indefinitely “for faster rebooking”
- This indefinite retention violates DPDP’s data minimization principles
Loyalty Program Data Accumulation
Travel loyalty programs accumulate years of travel history, creating one of the most comprehensive lifestyle profiles available. A member’s Platinum status on a hotel chain reveals income level, travel frequency, business patterns, and personal preferences — all personal data under DPDP requiring proper consent and purpose limitation.
Travel Company Analyses
OYO Rooms
OYO processes some of the most personally revealing hospitality data: ID documents, stay patterns, co-guest information, and room preferences — all shared with individual hotel owners. At 40/100, the platform's franchise model creates a data governance vacuum where guest PII flows to thousands of independent hotel operators with minimal oversight.
MakeMyTrip
MakeMyTrip handles passport numbers, travel destinations, hotel stays, and co-traveler details — creating an intimate travel diary. At 48/100, the platform's lack of ID document protection policies and retention timelines for travel history that reveals lifestyle patterns creates significant DPDP exposure.