Data Privacy Risks for Aviation, Travel and Hospitality Businesses Under India’s DPDP Regime: Passenger Data, Surveillance and Global Compliance

Posted On - 9 February, 2026 • By - Aniket Ghosh

Introduction: Travel as a Data-Intensive Experience

Modern travel is inseparable from data. From the moment a passenger searches for a flight or hotel to the point of check-out or arrival, personal data is continuously collected, analysed, shared and retained across a complex ecosystem of airlines, airports, hotels, travel intermediaries, technology platforms and government authorities.

Airlines, airports, online travel agencies (OTAs), hotels, resorts, cruise operators and mobility providers routinely process:

  • Identity and KYC information
  • Passport, visa and travel document data
  • Passenger Name Records (PNR)
  • Location and movement data
  • Biometric identifiers (facial recognition, fingerprints)
  • Payment and loyalty programme information

Unlike many digital services, travel data processing is unavoidable. Passengers cannot meaningfully opt out without forfeiting the ability to travel. This structural imbalance places the travel and hospitality sector under heightened scrutiny under India’s data protection framework.

With the enactment of the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”), data privacy compliance has become a core operational, contractual and reputational issue for travel and hospitality businesses.

Applicability of the DPDP Act to Aviation, Travel and Hospitality

A. Entities Covered

The DPDP Act applies to any entity processing digital personal data, including:

  • Domestic and international airlines
  • Airport operators and ground handling agencies
  • Online travel agencies (OTAs) and aggregators
  • Hotels, resorts and hospitality chains
  • Tour operators and cruise companies
  • Loyalty programme operators
  • Travel technology and reservation system providers

Both Indian and foreign entities offering services to individuals in India fall within the scope of the Act.

B. Data Fiduciaries in the Travel Ecosystem

Most travel and hospitality entities qualify as data fiduciaries, as they determine:

  • What passenger or guest data is collected
  • How it is used and shared
  • How long it is retained

Third parties namely reservation system providers, payment gateways, cloud vendors, analytics platforms, generally act as data processors, though primary liability remains with the fiduciary.

Large airlines, OTAs and hotel chains may be notified as Significant Data Fiduciaries (SDFs) due to:

  • Scale of data processing
  • International data flows
  • Use of biometric and surveillance technologies

Passenger Data: A High-Risk Category by Design

A. Passenger Name Records and Travel Histories

PNR data typically includes:

  • Full name and contact details
  • Passport and visa information
  • Itinerary and seat selection
  • Meal preferences and special assistance requests
  • Payment details

Such data can reveal health conditions, religious beliefs, travel habits and personal relationships, making it highly sensitive.

B. Location and Movement Data

Airports, airlines and hotels process:

  • Real-time location data
  • Boarding and access logs
  • CCTV footage
  • Key-card and room-access records

Continuous monitoring significantly heightens privacy risk, particularly where retention is excessive or access controls are weak.

Under the DPDP Act, consent must be free, informed, specific, unambiguous, and capable of withdrawal. In travel, however, refusal to provide data often means denial of service. Regulators are therefore likely to scrutinise:

  • Over-broad consent clauses in tickets and booking terms
  • Bundled consent for analytics and marketing
  • Lack of meaningful opt-outs

B. DPDP Rules: Enhanced Notice Requirements

The DPDP Rules require clear disclosure of:

  • Categories of personal data collected
  • Purpose of processing (security, booking, marketing, analytics)
  • Third-party and cross-border data sharing
  • Retention periods
  • Passenger or guest rights and grievance mechanisms

Generic global privacy policies that obscure Indian-specific practices pose compliance risk.

Biometric Processing at Airports and Hotels

A. Facial Recognition and Digi-Yatra-Type Systems

Airports increasingly deploy:

  • Facial recognition for check-in and boarding
  • Automated security and access control systems

Biometric data processing significantly raises compliance stakes due to:

  • Irreversibility of harm
  • Surveillance concerns
  • Potential misuse or data breaches

Such processing must be:

  • Clearly justified
  • Transparent
  • Supported by strong security safeguards

B. Hotels and Access Control Systems

Hotels and resorts increasingly use Biometric or app-based room access and CCTV and smart surveillance. Without clear notice and proportionate use, such systems expose operators to enforcement risk.

Purpose Limitation and Commercial Use of Travel Data

A. Service Delivery vs Monetisation

Travel data is often repurposed for:

  • Targeted advertising
  • Cross-selling of services
  • Loyalty programme analytics

Under the DPDP Act, secondary commercial use requires explicit disclosure and valid consent. Legacy practices of silent profiling are no longer defensible.

B. Loyalty Programmes

Loyalty programmes involve long-term tracking of:

  • Travel behaviour
  • Spending patterns
  • Preferences

Without clear consent boundaries and retention controls, such programmes pose significant compliance risk.

Government Access, Security and Regulatory Overlap

A. Mandatory Data Sharing

Airlines and hotels often share data with:

  • Immigration authorities
  • Security agencies
  • Law enforcement

While the DPDP Act provides exemptions for certain state functions, exemptions are not blanket permissions. Businesses must:

  • Document legal basis for disclosure
  • Limit sharing to necessity
  • Maintain audit trails

B. Intersection with Aviation and Immigration Laws

Travel businesses must navigate overlapping obligations under:

  • Aviation security regulations
  • Immigration and passport laws
  • International treaties

Poor governance of government requests can expose businesses to legal and reputational risk.

Cross-Border Data Transfers: A Structural Challenge

The travel industry is inherently global. Airlines, hotel chains and OTAs routinely transfer data across borders for:

  • Centralised reservation systems
  • Global loyalty platforms
  • Analytics and fraud prevention

Under the DPDP Act, cross-border transfers are permitted only to government-notified jurisdictions, requiring businesses to:

  • Map global data flows
  • Monitor regulatory notifications
  • Reassess data-hosting strategies

Data Breaches and Systemic Fallout

A. Mandatory Breach Notification

Under the DPDP Act and Rules, travel businesses must notify the Data Protection Board of India and the affected passengers or guests. Given the scale of operations, breaches can quickly become high-profile public incidents.

B. Reputational Impact

Data breaches involving travel data can:

  • Undermine passenger safety perceptions
  • Trigger global media scrutiny
  • Lead to loss of customer trust

For hospitality brands, trust erosion can have long-term commercial consequences.

Penalties and Enforcement Exposure

A. Monetary Penalties

The DPDP Act empowers penalties up to INR 250 crore per contravention, based on:

  • Nature and sensitivity of data
  • Scale and duration of processing
  • Mitigation measures taken

Airlines, OTAs and hotel chains face systemic exposure due to volume and international reach.

B. Commercial and Regulatory Consequences

Beyond penalties, businesses may face:

  • Regulatory directives
  • Contractual disputes with partners
  • Loss of customer confidence
  • Increased scrutiny by foreign regulators

Compliance Roadmap for Travel and Hospitality Businesses

1. Passenger Data Mapping: Identify all PNR, biometric, location and loyalty data flows.

3. Biometric Governance: Limit biometric processing to necessity and enhance security controls.

4. Vendor and System Contracts: Update agreements with reservation systems, OTAs and vendors.

5. Breach Preparedness: Develop tested incident response plans covering multi-jurisdictional exposure.

Conclusion: Privacy as the New Dimension of Travel Trust

In aviation and hospitality, trust is inseparable from safety and service quality. The DPDP Act and Rules make it clear that operational convenience and security objectives do not justify opaque or excessive data collection.

Travel and hospitality businesses that embed privacy-by-design, respect proportionality and maintain transparent governance will be best positioned to earn passenger trust and regulatory confidence in India’s evolving travel ecosystem.