What data is classified as 'Licensee Personal Data' for a Crowne Plaza franchisee?

According to Crowne Plaza's 2025 Franchise Disclosure Document, 'Licensee Personal Data' encompasses specific types of information managed by the franchisee. It includes any Personal Data (excluding IHG Marketing Data) that the franchisee holds and processes locally at their hotel, acting as an independent controller. This also covers Licensee employee Personal Data, where the Licensee is the sole controller, and Excluded Personal Data, again where the Licensee is the sole controller.

Specifically, this Licensee Personal Data includes data contained within the Hotel's property management system. It also includes Personal Data related to the hotel's employees. The FDD is explicit that 'Licensee Personal Data' does not include IHG Marketing Data, clarifying the distinction between data controlled by the franchisee versus data managed by the franchisor.

This definition is important for prospective franchisees as it clarifies their responsibilities and control over certain data categories. Understanding what constitutes 'Licensee Personal Data' helps franchisees comply with data privacy laws and manage their obligations regarding data protection. It also highlights the separation of data management responsibilities between the franchisee and IHG, particularly concerning marketing data.