DPDP Compliance for Travel and Hospitality Platforms: Passport and Itinerary Data

International flight and hotel bookings typically require passport details, and hotels statutorily require guest ID at check-in, so a travel platform often captures identity document data well before any government body technically requires it, simply because downstream partners (airlines, hotels, visa processors) will ask for it later in the journey. The notice at booking should be specific about which of these downstream parties will actually receive the passport scan, rather than a blanket “we may share your data with our partners” line.

Group and family bookings add a wrinkle: one person often enters passport and date-of-birth details for travelling companions, including children, meaning consent is being given by the booker on behalf of others who never interacted with the platform directly. Where a booking includes a minor, that raises the same verifiable-parental-consent consideration under Section 9 that any platform processing a child's data needs to address, even though the immediate user interface is the adult's.

Hotel check-in typically involves a physical or digital guest register capturing ID, photograph, and sometimes vehicle details, run by the property rather than by the platform that facilitated the booking. A booking platform's own notice should be clear that this on-property registration is a separate collection event outside its own systems, since guests often assume the platform's privacy terms cover the entire stay.

Loyalty and preference profiles built by hotel chains — room preference, dietary needs, past stay history — accumulate across visits and, particularly for chains with many properties, deserve a clear internal boundary on which staff and locations can see a guest's historical profile versus just their current stay.

Airline passenger name records circulate among the airline, the booking platform, ground-handling agents, and sometimes immigration authorities, and much of that circulation for international travel touches jurisdictions outside India — squarely within Section 16's cross-border transfer framework. A travel platform facilitating the booking is not typically the party controlling that entire chain, but it should be transparent with the traveller about which of its own partners initiate that further sharing.

Visa processing services, whether run in-house or outsourced to a specialist processor, handle some of the most sensitive identity data in the entire travel flow — passport, financial proof, sometimes biometric appointment data — and that relationship needs a clearly documented processor contract with strong security safeguards, given how attractive a visa-processing database is as a target.

A Data Flow Mapper exercise is worth doing specifically on the international-booking journey, since passport data alone can pass through four or five distinct parties before a trip even begins. The Consent Notice Builder can help produce booking-flow language that names each downstream recipient rather than relying on a single generic partner-sharing clause.