Guest Privacy and Staff Training
Padgett-Beale
Based on the recent finding regarding inappropriate use of guest
information on internal bulletin boards, the following action are
recommended. The actions will aim to help protect both Padgett
Beale and the privacy of our guests’ information through the
improvement of employee’s understanding of privacy concerns in
our business.
1. Inclusion of Data Privacy Training in Mandatory Employee
Training Activities
d d d All employees will receive training on company privacy
policy. d This training will include the following sections from the
company privacy policy.
a. Definitions
Each employee should have a common understanding of the data
and privacy related terms.
b. Data shared by our guests
Employees should understand what data is shared and collected
from our guests.
c. Our use of data
Employees should understand how we use the data that is collected
from our guests.
d. Use of data of Minors
Employees should be aware of the special legal area related to the
data of our guests under the age of 13 years old.
e. Sharing of Data
Employees should understand the data sharing practices of the
company as well as the limits imposed upon the use of guest data
by employees.
(IHCL, n.d.).
It should be communicated to employees as part of this training
that a violation of the privacy policy can result in suspension or
termination of employment.
2. Use of Guest Information
The training program should place special emphasis on the use of
guest information. The reproduction of guest information in any
form not related to the specified job function of the employee is
prohibited unless prior approval is received by Legal.
Any training program modification should present the employee
with scenario-based exercises to help ensure that the employee is
able to demonstrate understanding. This demonstration will be in
the form of written exercises. The results of these exercises will be
stored in the employee’s file.
3. Role Playing Exercises
d d d To further supplement the understanding of our employees,
various role-playing exercises will be performed in small groups of
employees. These exercises will have one person playing the role
of the guest and the other playing the role of an employee. The
intention of this training is to provide real-world context to the
privacy training.
d d d An example of a role-playing exercise is guest check-in. d
There are written procedures for how to check in a guest. These
will be the primary focus of the training, but there can still be the
opportunity for privacy violations even if the current procedures are
followed. d For instance, it is required for an employee to ask for a
guest’s identification so that they can enter information into the
system. A potential violation could occur if the employee reads the
full name, address or other info out loud so that other guests might
hear them. General confidentiality in such situations is called for to
help in the protection of our guests’ privacy.
4. The role of Management
Managers should be well-versed in the privacy policy of Padgett
Beale as it relates to our guests. d Managers will be expected to
guide employees with any questions they may have regarding the
privacy policy. Additionally, managers will be asked to handle any
requests from guests regarding the privacy of their information.
This level of interaction requires a more thorough understanding of
privacy policy beyond just passing a training examination.
5. Whistleblowing Policy
d d d We at Padgett Beale ask our employees to police
themselves as a general policy rather than submit to surveillance.
Should an employee notice a breach of the privacy policy, they
should immediately notify their manager. Should the manager be
involved in the breach, then the employee should contact our
ombudsman who will handle the employee’s request in a
confidential manner. Padgett Beale has a ‘Non-Retaliation’ policy
regarding whistleblowers.
References
The Indian Hotels Company Limited. (n.d.). Privacy policy: The
Indian Hotels Company Limited. South Asia's Largest Hospitality
Brand - Retrieved April 10, 2022, from
https://www.ihcltata.com/privacy-policy/
