«A quarterly review helps maintain control without waiting for a problem to arise. It is also advisable to carry it out when regulations, processes, tools, suppliers or hotel services change.»
LEAN Team
Hotel System
specialised in PMS
emerging
Compliance in a hotel shouldn't be managed only when an inspection, a complaint or a legal query arises. For small and medium-sized hotels, the most useful approach is to work with an operational checklist: what data is collected, who has access, how it is communicated, which processes are documented and which points must be validated with consultancy, a DPO or legal leads depending on the country, region, category and services of the establishment.
This article is not legal advice. It is a practical guide for identifying critical points and streamlining operations. In Spain, document registration and traveller information are regulated by Royal Decree 933/2021, and the Ministry of the Interior provides the SES.HOSPEDAJES platform to facilitate the communication of accommodation data.
Before starting: compliance doesn't just depend on reception
Reception is usually the visible face of compliance because it requests data, verifies reservations, manages invoices and communicates information to the guest. But compliance does not depend solely on reception. It also affects management, administration, marketing, housekeeping, maintenance and technology providers.
For example, privacy is not just about “asking for data properly”. It also involves access permissions, retention, commercial communications, exports, CCTV surveillance, supplier contracts and staff training. Accessibility is not just an adapted room: it also affects information, signage, common areas and internal procedures.
The idea is not to turn the hotel into a legal department, but to work with a practical question: what should we review to avoid operating blindly?
Guest data checklist and traveller returns
Guest data collection is one of the most sensitive points. In Spain, the Ministry of the Interior states that the registration of traveller data is compulsory for accommodation establishments in Spanish territory, and SES.HOSPEDAJES is the platform enabled to facilitate these registration and information obligations.
Operational checklist:
- Check which guest details are mandatory depending on the relevant market.
- Please confirm that the online form and the paper form both require the same information.
- Verify identity in accordance with the procedure set out by the hotel.
- Avoid duplication between pre-check-in, reception and the PMS.
- Check which details are missing before arrival.
- Ensure that the relevant authorities are notified where appropriate.
- Review records management according to applicable regulations.
- Check that the system knows how to handle incomplete data or errors.
The aim is to avoid two extremes: ordering too little and having to make manual corrections, or ordering too much and increasing the risk to privacy.
What the PMS should monitor at this stage
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The PMS should help to ensure that the process is consistent. To this end, it is advisable to review:
- Mandatory fields depending on the market.
- Incomplete data alerts.
- Validations prior to check-in.
- Change traceability.
- Duplicate profile detection.
- Consistency between the guest’s details, the booking and the relevant correspondence.
- Export or communications controls, where applicable.
This is where a system such as LEAN comes into its own, with fields that can be tailored to each market and centralised guest information. The key is for the PMS to be a single source of data, not just another place where information has to be copied.
Data protection and privacy checklist
The hotel processes personal data every day: identification data, contact details, reservations, preferences, payments, billing, communications and, in some cases, CCTV images. The AEPD reminds us that the GDPR requires the implementation of technical and organisational measures appropriate to the risk, as well as the adaptation of data collection forms to the right to information.
Operational checklist:
- Check what personal data is collected and for what purpose.
- Check that the forms provide the guest with the correct information.
- Check who has access to sensitive data.
- Review marketing communications and consent where applicable.
- Check payment details or related reference information.
- Review data retention and disposal policies.
- Check CCTV footage, signage and any related information, where applicable.
- Review contracts and suppliers that process the hotel’s data.
- Consult with an adviser or the DPO to assess when a more in-depth assessment is required.
Common mistakes involving customer data
There are some mistakes that are all too common in hotels:
- Asking for more information than is necessary.
- Keeping unnecessary copies of documents.
- Use shared users.
- Export data to Excel without control.
- Keeping duplicate profiles.
- Sending documents through inappropriate channels.
- Failing to properly inform the guest.
- Recording excessive or unnecessary internal notes.
An important point: the AEPD has pointed out that the obligation to collect certain traveller data does not authorise the indiscriminate request for a copy of an ID card or passport; that data may be collected via an in-person or online form, but data minimisation must be respected.
Payments, invoicing, pricing and booking conditions checklist
Administrative errors also generate risk: complaints, discrepancies, differences between channels or incorrect invoices. This block does not replace fiscal or accounting review with an agency, but it helps to detect operational issues.
Operational checklist:
- Rates correctly configured in PMS.
- Revised taxes and charges.
- Visible and consistent cancellation terms.
- No-show policies correctly enforced.
- Extras and supplements defined with price and conditions.
- Invoices with correct data.
- Payments, deposits and guarantees recorded.
- Coherence between PMS, booking engine, channel manager and OTAs.
- Review of current promotions and potential overlaps.
- A clear process for returns, corrected charges or complaints.
The aim is to ensure that guests do not encounter different conditions depending on the booking channel, and that reception does not have to interpret each booking manually.
Accessibility, safety and communal areas checklist
Compliance is not limited to data and invoicing. It also covers accessibility, safety, communal areas, maintenance and guest information. In Spain, Royal Decree 193/2023 regulates the basic conditions of accessibility and non-discrimination regarding access to and use of goods and services available to the public.
Operational checklist:
- Check the accessibility of the main entrances.
- Check signage and information visible to guests.
- Check lifts, ramps, corridors and communal areas.
- Check details of accessible rooms, if applicable.
- Check the preventive maintenance of walkways.
- Monitor operational safety incidents.
- Review emergency plans and internal documentation.
- Check that the team knows how to respond to special needs.
- Check the communal areas: lobby, corridors, restaurant, terrace, swimming pool, spa or gym, if applicable.
Accessibility and safety must be treated as part of day-to-day operations, not as isolated documents.
How to use the PMS to monitor compliance without relying on Excel
The PMS is no substitute for legal advice, but it can be a great help in organising processes. When information is scattered across external sheets, emails, notes or loose documents, the hotel loses traceability and the likelihood of errors increases.
A PMS can centralise guest data, reservations, payments, invoices, room statuses, incidents, room changes, permissions and internal logs. In LEAN, this can be supported by profile-based environments, access control, centralised data and processes configurable according to the hotel's operations.
The advantage is not “automatic compliance”, but rather working with greater control: less duplication, less unnecessary access and less scattered information.
Permissions and users: each profile should only see what is necessary
Access rights are a key element of privacy and internal control. Reception, administration, management, housekeeping and maintenance do not all require the same level of access.
A practical guideline:
- Reception: bookings, check-in/out, operational details, payments and any necessary notes.
- Administration: invoicing, tax details and payments.
- Section: Reports, settings and general control.
- Housekeeping: statuses, tasks and incidents, without unnecessary access to sensitive data.
- Maintenance: operational incidents and outages; no personal data that you do not require.
This approach reduces errors and limits information exposure.
Final compliance checklist to be reviewed every quarter
A quarterly review helps you stay on top of things without having to wait for a problem to arise. It is also a good idea to carry one out whenever there are changes to regulations, processes, tools, suppliers or hotel services.
Travellers and guest details
- Mandatory data reviewed on a market-by-market basis.
- Online and in-person forms are aligned.
- Incomplete data checked prior to arrival.
- Notification to the authorities, revised where appropriate.
- Revised document retention policy.
- Duplicate profiles detected and corrected.
Privacy and data protection
- Forms with appropriate information.
- User permissions reviewed.
- Shared users deleted.
- Controlled exports.
- Revised retention and disposal.
- Verified commercial communications.
- Technology suppliers reviewed.
- CCTV reviewed if applicable.
Payments, invoicing and channels
- Updated tariffs and taxes.
- Cancellation and no-show policies revised.
- Conditions visible on engine and OTAs.
- Documented extras and supplements.
- Revised invoicing and tax details.
- PMS-channel-engine synchronisation validated.
Accessibility, security and incidents
- Signage and guest information have been revised.
- Entrances and communal areas have been reviewed.
- Accessible rooms or updated related information, where applicable.
- Internal plans and revised protocols.
- Open and recurring incidents analysed.
- Preventative maintenance linked to operations
Training and internal processes
- Team specialising in guest data.
- Clear scripts for reception.
- Procedure in the event of incidents or data errors.
- Roles and responsibilities defined.
- Review of shift changes and traceability.
- Updated internal documentation.
What should a regulatory checklist for hotels include?
What tasks does the reception team need to check every day?
How does a PMS help with regulatory compliance?
How often should a hotel’s compliance with regulations be reviewed?
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