SCENARIO – Please use the following to answer the next question:
Zoe is the new Compliance Manager for the Star Hotel Group, which has five hotels across Hong Kong and
China. On her first day, she does an inspection of the largest property, StarOne. She starts with the hotel
reception desk. Zoe sees the front desk assistant logging in to a database as he is checking in a guest. The
hotel manager, Bernard, tells her that all guest data, including passport numbers, credit card numbers,
home address, mobile number and other information associated with a guest's stay is held in a database.
Bernard tells her not to worry about the security of the database because it is operated for Star Hotels by a
local service provider called HackProof, who therefore are responsible for all the guest data.
Zoe notices what looks like a CCTV camera in the corner of the reception area. Bernard says they record all
activity in the lobby. In fact, last Tuesday he had received a data access request from a lawyer requesting a
copy of footage of all lobby activity for the preceding month. The lawyer's covering letter said that his client
has never visited the hotel herself, but is investigating whether her husband has been doing so without her
knowledge.
Zoe and Bernard head up to the hotel spa. The spa is independently owned by a company called Relax Ltd.
Bernard explains that Relax Ltd is a small company and, as they don't have their own database, they
transfer data about the spa guests to StarOne staff so that they can upload the data into the HackProof
system. Relax Ltd staff can then login and review their guest data as needed.
Zoe asks more about the HackProof system. Bernard tells her that the server for the Hong Kong hotels is in
Hong Kong, but there is a server in Shenzhen that has a copy of all the Hong Kong hotel data and supports
the properties in China. The data is in China for back up purposes and also is accessible by staff in the
China hotels so they can better service guests who visit their hotels in both territories.
How should Bernard respond to the lawyer’s request for the CCTV footage?
