Accommodation - personal data now required

[MikeyC]

It seems that after several pushbacks the new requirements come into force on December 2nd.
Accomodation providers will be required to collect a raft of personal data from all guests. This will include financial information such as credit card and bank details, full contact details and relationship between travellers.
The same applies to car hire companies.
The data is to be sent daily to authorities to help combat crime and terrorism.
Expect delays at check in.

 

[SabsP]

It seems that after several pushbacks the new requirements come into force on December 2nd.
Accomodation providers will be required to collect a raft of personal data from all guests. This will include financial information such as credit card and bank details, full contact details and relationship between travellers.
The same applies to car hire companies.
The data is to be sent daily to authorities to help combat crime and terrorism.
Expect delays at check in.

Which? What? Where?

An offficial link might be welcome.

 

[MikeyC]

Which? What? Where?

An offficial link might be welcome.

Non official link but from a trade body mentioning the relevant legislation.

https://www.businesstravelnewseurope.com/Management/Travel-groups-warn-over-enforcement-of-Spain-s-new-data-rule

 

[MikeyC]

Which? What? Where?

An offficial link might be welcome.

Text of the Decree:

BOE-A-2021-17461 Real Decreto 933/2021, de 26 de octubre, por el que se establecen las obligaciones de registro documental e información de las personas físicas o jurídicas que ejercen actividades de hospedaje y alquiler de vehículos a motor.

www.boe.es

 

[JCLima]

An old thread about it: https://www.caminodesantiago.me/com...nges-coming-for-spanish-accommodations.84192/

An older thread about it: https://www.caminodesantiago.me/com...-travellers-in-spain-starting-feb-2023.78423/

Edit: I’m assuming they’re all referring to the same thing; apologies if that’s not the case

 

[CWBuff]

Credit card AND bank details?!?! OK... I'm somewhat might be agreeable to give the 1st (although suppose I don't have one and paying cash for everything) but definitely NONE OF YOUR BUSINESS regarding the 2nd
Bank details,!?@?

 

[Pilgrim9]

Are the un-banked and un-credit-carded to be turned away?

 

[JCLima]

Credit card AND bank details?!?! OK... I'm somewhat might be agreeable to give the 1st (although suppose I don't have one and paying cash for everything) but definitely NONE OF YOUR BUSINESS regarding the 2nd
Bank details,!?@?

I'm assuming they need to keep the CC details if you pay with CC and the bank details if you pay with a bank transfer; if you pay by cash, those do not apply.

 

[Tincatinker]

Credit card AND bank details?!?! OK... I'm somewhat might be agreeable to give the 1st (although suppose I don't have one and paying cash for everything) but definitely NONE OF YOUR BUSINESS regarding the 2nd
Bank details,!?@?

that is not what is required. It's the "method" of payment ie: cash; credit card; bank card; bank transfer.

One simple avoidance is to pay cash. Or just take comfort that "they": the Bankers, and Elon, Steve, Sundar, Larry and all the rest already know who you are; where you've been; your shopping habits; favourite Coffee Chain and probably your shoe size and inside-leg.

 

[henrythedog]

I'm assuming they need to keep the CC details if you pay with CC and the bank details if you pay with a bank transfer; if you pay by cash, those do not apply.

You are correct. It is set out in ‘Anexo 1’as @Tincatinker says (in Spanish) as ‘the means of payment’ for the specific transaction.

I habitually pay for much of my social life in cash as it is not auditable. I have no concerns about the various official bodies, it’s Mrs HtD’s propensity to audit which keeps me awake at night.

There is a distinction in the decree between commercial and non-commercial organisations which may be relevant to donativos, but someone more thorough that I will have to opine on that.

 

[MaxHelado]

Accomodation providers will be required to collect a raft of personal data from all guests. This will include financial information such as credit card and bank details, full contact details and relationship between travellers.

A raft of personal data?
Reading the appendix in the decree it seems to me the hotel/albergue will want a copy of my passport (which they already ask for) plus my address, phone number and email.
They will only ask about the relationship if I am travelling with a minor.
If that’s the case it doesn’t seem like a big deal to me.

 

[MikeJS]

A raft of personal data?
Reading the appendix in the decree it seems to me the hotel/albergue will want a copy of my passport (which they already ask for) plus my address, phone number and email.
They will only ask about the relationship if I am travelling with a minor.
If that’s the case it doesn’t seem like a big deal to me.

You do not have to be truthful…..

 

[MaxHelado]

You do not have to be truthful…..

 

[Kathor1]

There is a distinction in the decree between commercial and non-commercial organisations which may be relevant to donativos

Yes, it would be interesting to hear from those who are directly concerned by this, i.e. those who manage and provide staff for non-commercial albergues such as donativo albergues, municipal albergues and parochial albergues.

There is an analysis by a European Travel Agents and Tour Operators Association (the analysis deals exclusively with data protection aspects and not with the additional administrative burden) which states that the new law, not yet applicable, concerns lodging activities open to the public and regulated by the corresponding sectorial laws - it is anyone's guess what these corresponding sectorial laws are. But whatever is exempt from these sectorial laws is also exempt from this new traveller registration law. For those who are exempt, the current traveller registration law will continue to apply as it is not suspended. Apologies for stating this, everybody will have read it themselves of course in the BOE.

At the end of the analysis, there is a list of possible actions. I don't know the date of this paper. As to their "Other actions": At least one question had been submitted in March 2023 (by C. Puigdemont and others btw) and there is a written answer; it does not say much. Another written question was submitted last month by two Spanish MEPs from the PPE and, as usual, there will not be an answer any time soon.

Like most of this stuff, this analysis paper is just yet another press release:

https://www.ectaa.org/Uploads/press-releases/DP-LED-Analysis-of-Spanish-Royal-Decree-933-2021.pdf

 

[Kathor1]

You do not have to be truthful…..

This has already been suggested and described in amusing detail in the older threads about this topic. What is overlooked in this suggestion: In the overwhelming majority of cases the personal data will be read electronically from an ID card - which is what every Spanish pilgrim has as well as the majority of other European pilgrims. ID cards often contain at least the name of the town where the pilgrim's residency is registered and, depending on the issuing country, also the complete address.

 

[Perambulating Griffin]

Soooooo, still slightly less data than is required by most standard hotels?
I know that our names and passport details are kept as a means of locating last known position if someone should go missing. I'm not sure how effective it is as a method, but I see a certain level of sense to it if family and friends are able to tell the Guardia the last village they know their person to have been staying. I know that customs officials have been *for decades* asking children travelling "Who is this adult?" and "Why are you travelling to X'? (When I was 3 I told US customs that I was heading to Vegas with my dad to shoot some craps and hit the Blackjack tables; we were actually heading to visit family, but I'd likely overheard Dear Old Dad on the phone talking about the trip... That was in about 1970...
When my son used to fly to meet me overseas while I was on sabbatical, we would be checked and double-checked at customs... I don't think verifying -- to the best of their capacity -- the relationship of minors to the adults with whom they are travelling is a bad thing. We live in an ugly world and it's shocking that *any* children fall into the wrong company. On a global scale, sure it's a minuscule percentage... but it should be zero. So customs and hostelry businesses do what they can... and the law does not get written to say "We check everyone except nice pilgrims who would never kidnap or traffic a child". Laws are blankets and they cover all situations of a given category: in this case, travel, temporary commercial lodging)...

 

[bullingtonce]

It seems that after several pushbacks the new requirements come into force on December 2nd.
Accomodation providers will be required to collect a raft of personal data from all guests. This will include financial information such as credit card and bank details, full contact details and relationship between travellers.
The same applies to car hire companies.
The data is to be sent daily to authorities to help combat crime and terrorism.
Expect delays at check in.

Evil needs to be confronted and dealt with, pure and simple. Convenience or personal preferences are not relevant. The focus is on the victims, doing what can be done to minimize those who suffer. Not a bad concept to support. Chuck

 

[SabsP]

Yes, it would be interesting to hear from those who are directly concerned by this, i.e. those who manage and provide staff for non-commercial albergues such as donativo albergues, municipal albergues and parochial albergues.

There is an analysis by a European Travel Agents and Tour Operators Association (the analysis deals exclusively with data protection aspects and not with the additional administrative burden) which states that the new law, not yet applicable, concerns lodging activities open to the public and regulated by the corresponding sectorial laws - it is anyone's guess what these corresponding sectorial laws are. But whatever is exempt from these sectorial laws is also exempt from this new traveller registration law. For those who are exempt, the current traveller registration law will continue to apply as it is not suspended. Apologies for stating this, everybody will have read it themselves of course in the BOE.

At the end of the analysis, there is a list of possible actions. I don't know the date of this paper. As to their "Other actions": At least one question had been submitted in March 2023 (by C. Puigdemont and others btw) and there is a written answer; it does not say much. Another written question was submitted last month by two Spanish MEPs from the PPE and, as usual, there will not be an answer any time soon.

Like most of this stuff, this analysis paper is just yet another press release:

https://www.ectaa.org/Uploads/press-releases/DP-LED-Analysis-of-Spanish-Royal-Decree-933-2021.pdf

Thanks again @Kathor1 putting this subject in the correct perspective .

 

[Kirkie]

You are correct. It is set out in ‘Anexo 1’as @Tincatinker says (in Spanish) as ‘the means of payment’ for the specific transaction.

I habitually pay for much of my social life in cash as it is not auditable. I have no concerns about the various official bodies, it’s Mrs HtD’s propensity to audit which keeps me awake at night.

There is a distinction in the decree between commercial and non-commercial organisations which may be relevant to donativos, but someone more thorough that I will have to opine on that.

I have no concerns about the various official bodies, it’s Mrs HtD’s propensity to audit which keeps me awake at night
You are the giddy limit!

 

[Kathor1]

@SabsP: I had a quick look at the two previous threads about this topic. @JCLima had provided the links in post #5.

@Juanma who owns a private albergue on the Camino Francés and is well known to numerous pilgrims posted two links to petition&information platforms about Decree 933/2021. These webpages are still active and updated:

https://sites.google.com/view/pau-plataforma-alojamientos-un/pau​

https://www.change.org/p/control-de-viajeros-intolerable​

​

The second thread has a link to a petition by the Camino Francés Federation CFF but when I clicked on it (the CFF has organized a petition, accessible here,), the link was dead. In fact, I could not find anything about Decree 933/2021on their website. I don't know what this means (if anything ...). Have they given up or does it not apply to the albergues that are covered by the CFF or did I just not search carefully enough?

 

[MikeJS]

This has already been suggested and described in amusing detail in the older threads about this topic. What is overlooked in this suggestion: In the overwhelming majority of cases the personal data will be read electronically from an ID card - which is what every Spanish pilgrim has as well as the majority of other European pilgrims. ID cards often contain at least the name of the town where the pilgrim's residency is registered and, depending on the issuing country, also the complete address.

No ID cards for me…...

 

[Kathor1]

No ID cards for me…...

I know. But, in this respect, you belong to a minority of Camino pilgrims.

 

[Tincatinker]

No Bank cards? No Bus Pass? No Credit Cards? No Store Loyalty cards? They all contain, or link to, a vast array of your personal data and that data is available to anyone with a legitimate case to access it (and, unfortunately, to quite a few bad-actors with the inclination).

Edit: I should have added mobile phone to my list.

To be blunt ID cards and Passports realistically only serve now as an item of convenience to Border Control. The really useful information about you is readily available to anyone that wants it

 

[Kathor1]

To be blunt ID cards and Passports realistically only serve now as an item of convenience to Border Control

If you don't have one you may not know this: I use mine each time I go to hospital appointments to check in at a kiosk. The kiosk then prints out a sheet with information about the corridors and elevators I take to find my way to the doctor in question and a number that tells me when it is my turn to enter the doctor's room. I also use it at home as a safe login device to access my tax returns online and numerous similar documents such as a list of my vaccinations. Or at the post office to identify myself to pick up a parcel that was not delivered because I was not at home. An ID card has many uses. We don't use electricity bills for such purposes.

The really useful information about you is readily available to anyone that wants it

That is actually not true and I think that it is important to point it out - at least if one wants to have a meaningful thread about 933/2021. It depends on the data protections laws of individual countries for their administrative systems at national, regional and local level. Some European countries are amazingly lackadaisical in this respect (imho) and others amazingly strict as to which services can have access to which databases and for which purposes.

 

[Tincatinker]

It depends on the data protections laws of individual countries for their administrative systems at national, regional and local level

My point, I think, is that local, national and even EC data protection rules are but supersoft toilet tissue on a wet bum when the global corporations decide what they are going to do with your data.

Personally I look forward to the days when the microchip in my shoulder saves me the bother of carrying two bank cards, a bus pass, half a dozen “loyalty” cards and my assorted licences that permit me to carry and even drive an assortment of lethal weapons.

As an alternative, an ID card would be a practical option.

 

[Kathor1]

I was referring to public administration and not to private commercial enterprises. The Decreto 933/2021 has nothing to do with mega-banks, AmazonTeslaWalmart or the local bus company.

Spanish hotels are not allowed to use the personal data that they must collect on behalf of the Spanish authorities for their own commercial purposes. If they attempt to do so they risk high fines and they will be found out because they will have customers who will take legal action against such practices. We had this spectacular case some time ago with a Dutch tourist and a hotel on Majorca if I remember correctly where personal data of the guest was used for other purposes than the intended purpose i.e. traveller registration for the police forces. The fine was €15,000.