How does the Atwell Suites FDD define 'IHG Marketing Data'?

According to the 2025 Atwell Suites FDD, 'IHG Marketing Data' refers to personal data concerning members of IHG's or its affiliates' marketing or loyalty rewards programs. This definition is crucial for franchisees to understand their responsibilities and limitations regarding the use of guest information.

Specifically, Atwell Suites franchisees must recognize that IHG Marketing Data is distinct from other types of personal data they might collect, such as 'Licensee Personal Data.' Licensee Personal Data excludes IHG Marketing Data and includes data held and processed locally at the hotel for which the franchisee is an independent controller. This distinction means franchisees have more control over Licensee Personal Data but must adhere strictly to IHG's guidelines for IHG Marketing Data.

The FDD emphasizes that franchisees act as IHG's processor concerning IHG Marketing Data. This role prohibits franchisees from selling or sharing this data, processing it for any purposes not expressly permitted by IHG, including commercial purposes, or combining it with personal data from other sources. This restriction ensures that IHG maintains control over its loyalty program data and that franchisees do not misuse it for their own marketing efforts.

In practical terms, an Atwell Suites franchisee must ensure their hotel's property management system is configured to separate IHG Marketing Data from other guest data. They must also implement procedures to prevent unauthorized use or disclosure of IHG Marketing Data, as any breach could result in significant penalties and damage to the Atwell Suites brand. Franchisees should seek clarification from IHG on permissible uses of IHG Marketing Data to avoid unintentional non-compliance.