Hotel Steward Privacy Policy
Last Updated: 20 Oct 2026
1. Introduction
Hotel Steward ("we," "us," or "the Supplier") provides the Hotel Steward platform to help hospitality venues manage compliance, safety logs, and operational workflows. This policy explains how we process personal data as a Data Processor (on behalf of hotels) and a Data Controller (for our own business operations), in accordance with the UK GDPR and the Data (Use and Access) Act 2025.
2. Data We Collect
We process the following categories of data to facilitate workplace safety:
User Information: Names and contact details of hotel staff.
Safety Logs: Operational data including HACCP (temperature checks), COSHH (chemical management), and fire safety logs.
Special Category Data: Staff accident reports and incident logs containing health information. These are processed under Article 9(2)(b) (Employment Law) and the 2025 Recognised Legitimate Interests framework for safeguarding.
Technical Data: IP addresses and usage logs to ensure network security.
3. Lawful Basis for Processing
Under 2025 standards, we rely on the following bases:
Contractual Necessity: To provide the SaaS platform to the Customer.
Legal Obligation: To assist hotels in maintaining statutory safety records (e.g., RIDDOR).
Recognised Legitimate Interests: For crime prevention, fraud detection, and responding to emergency safety threats at your venue. No separate balancing test is required for these specific 2025 statutory categories.
4. Automated Decision-Making (ADM)
Hotel Steward may use automated processes for staff scheduling or risk profiling.
Safeguards: We do not use ADM for decisions based on sensitive health data without human oversight.
Your Rights: Users have a right to meaningful human intervention, the right to be informed about significant automated decisions, and the right to challenge the outcome.
5. Data Retention & Deletion
We adhere to strict retention schedules aligned with UK safety laws:
Accident Reports: Minimum of 3 years to meet legal claim limitations.
Food Safety (HACCP) Logs: Minimum of 12 months post-entry.
User Account Data: Retained for the duration of the subscription plus 30 days for data export.
6. Data Subject Rights (2025 Updates)
Individuals (Staff/Guests) have specific rights regarding their data:
Subject Access Requests (SAR): We implement the "stop the clock" rule. If we require clarification or identity verification, the one-month response window is paused until provided.
Reasonable Search: We conduct "reasonable and proportionate" searches to fulfill data requests, as permitted by the DUAA 2025.
Complaints: You have a statutory right to lodge a complaint directly with us via our Electronic Complaint Form. We must acknowledge your complaint within 30 days.
7. Cookies & Tracking
In line with 2025 ePrivacy reforms:
Essential Cookies: We use strictly necessary cookies for security and authentication.
Analytics Cookies: Low-risk statistical cookies used to improve functionality are deployed by default. You may opt-out at any time through the [Privacy Dashboard].
8. International Transfers
Data transfers outside the UK only occur where the destination country’s protection is "not materially lower" than UK standards, following the 2025 data protection test.
9. Contact & Regulatory Authority
For privacy inquiries, contact our Senior Responsible Individual (SRI) at [Your Email Address]. If we cannot resolve your complaint, you may escalate it to the Information Commission (formerly the ICO).
What information we collect, use, and why
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:
Name, address and contact details
Video recordings of public areas (including corridors, waiting rooms and outside spaces to which some or all members of the public have access)
Audio recordings of public areas (including corridors, waiting rooms and outside spaces to which some or all members of the public have access)
Video recordings of private or staff only areas (including staff rooms, offices, surgical areas, consultation areas and outside spaces to which only staff or patients have access)
Audio recordings of private or staff only areas (including staff rooms, offices, surgical areas, consultation areas and outside spaces to which only staff and patients have access)
Witness statements and contact details
Relevant information from previous investigations
Financial information eg for fraud prevention or detection
We collect or use the following information for safeguarding or public protection reasons:
Name, address and contact details
Emergency contact details
Photographs
Health information (including medical conditions, allergies, medical requirements and medical history)
Relevant information from previous investigations
Records of meetings and decisions
We collect or use the following personal information to comply with legal requirements:
Name
Contact information
Identification documents
Health and safety information
Any other personal information required to comply with legal obligations
Right to work
Insurance details
Criminal offence data
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Addresses
Account information
Purchase or service history
Video recordings of public areas
Audio recordings of public areas
Video recordings of private or staff only areas
Audio recordings of private or staff only areas
Witness statements and contact details
Relevant information from previous investigations
Customer or client accounts and records
Information relating to health and safety (including incident investigation details and reports and accident book records)
Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details.
Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
Directly from you
CCTV footage or other recordings
Insurance companies
Publicly available sources
Councils and other public sector organisations
Others we share personal information with Insurance companies, brokers and other intermediaries
Emergency services
External auditors or inspectors
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Appropriate Policy Document (APD)
Required for processing Special Category (Health) and H&S Sensitive Data.
1. Purpose
This APD satisfies the requirements of Schedule 1 of the Data Protection Act 2018 and the DUAA 2025 regarding the processing of special category data (health/injury records) for employment and social protection purposes.
2. Conditions for Processing
We rely on the following legal conditions for health and safety data:
Article 9(2)(b): Necessary for the purposes of performing obligations in the field of employment, social security, and social protection law (e.g., RIDDOR reporting).
Recognised Legitimate Interests (Schedule 4, DUAA 2025): Processing for safeguarding purposes, responding to emergencies, and protecting the physical wellbeing of individuals.
3. Data Retention and Erasure
Accident Reports: Retained for a minimum of 3 years to comply with personal injury limitation periods.
HACCP/Food Safety Logs: Retained for 12 months post-consumption.
Secure Erasure: Once the retention period expires, data is purged from live databases and backup cycles within 30 days.
4. Technical and Organisational Measures
Access Control: Role-based access (RBAC) ensures only qualified H&S Officers or Senior Managers can view sensitive injury logs.
Integrity: Digital signatures on safety checks prevent retrospective alteration of compliance data.
Training: All Hotel Steward administrative users must complete annual data privacy training provided within the platform.
Actionable Resources for Implementation
Complaints Procedure: Implement an Electronic Complaints Form as required by Section 103 of the DUAA 2025.
