Hôtel TIAMA
Warning + formal notice (avertissement et mise en demeure). ARTCI (Autorité de Protection), 17 November 2022.
The facts
The decision arises from the authority's annual control programme, which listed Hotel TIAMA, a 137-room hotel in the Plateau district of Abidjan, for inspection in the 2021-2022 exercise. Sworn agents carried out an on-site control at the hotel on 12 July 2022, covering the processing of client, staff and visitor data and the processing carried out by the hotel's processors. The control found no processing authorisation and no compliance programme, insufficient security guarantees including weak passwords without limited validity and password sharing among administrators, no automated system for deleting data past retention periods, weak physical protection of the server room, an unauthorised biometric device, missing video-surveillance signage, no procedure for data subjects' rights, and unauthorised data transfers.
Orders and outcome
The authority issued a warning and a formal notice to bring processing into compliance within sixty days of receipt of the decision, ordered the hotel to designate a data protection correspondent within thirty days, and stated that sworn agents would carry out controls to verify compliance, with further statutory measures to follow on non-compliance. Dated at Abidjan, 17 November 2022.
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