COMPAREMYTRIP
DATA PROTECTION & PERSONAL DATA GOVERNANCE FRAMEWORK
Document Type: Internal Data Protection Framework
Organisation: CompareMyTrip
Legal Entity: [INSERT LEGAL ENTITY NAME]
Effective Date: [DD/MM/YYYY]
Version: 1.0
Document Owner: [NAME / DESIGNATION]
Approved By: [DIRECTOR / AUTHORISED PERSON]
Review Frequency: At least annually and whenever applicable law, technology, products, suppliers or data-processing activities materially change.
1. PURPOSE
This Data Protection & Personal Data Governance Framework ("Framework") establishes the principles, policies, procedures, responsibilities and controls that CompareMyTrip follows when collecting, processing, storing, sharing, protecting and deleting personal data.
The Framework is designed to help CompareMyTrip:
- Process personal data lawfully and transparently.
- Collect only personal data reasonably necessary for identified purposes.
- Provide appropriate privacy notices.
- Obtain and manage consent where consent is the applicable basis for processing.
- Enable applicable rights of individuals.
- Protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
- Manage third-party data processors and suppliers appropriately.
- Respond to personal-data breaches.
- Establish appropriate data-retention and deletion practices.
- Maintain appropriate records and accountability.
- Protect customer, traveller, employee and business information.
2. SCOPE
This Framework applies to personal data processed by CompareMyTrip through all applicable business channels, systems and services, including:
2.1 Website
- www.comparemytrip.in
- Booking pages
- Enquiry forms
- Contact forms
- Account and login systems
- Cookies
- Analytics and tracking technologies
2.2 Mobile Applications
- Android application
- Future CompareMyTrip mobile applications
2.3 Customer Communication Channels
- Meta Business tools
- AI-assisted customer-support systems
- SMS
- Telephone
- Website chat
- Social-media messaging
2.4 Travel Services
- Flight bookings
- Hotel bookings
- Holiday packages
- Sunrise treks
- Weekend treks
- Monsoon and forest treks
- Transportation
- Visa assistance
- Travel insurance where applicable
- Activities and sightseeing
- Supplier coordination
2.5 Internal Systems
- CRM systems
- Booking systems
- Accounting systems
- Customer-support systems
- Marketing platforms
- Cloud storage
- Email systems
- Employee systems
- Payment systems
- Other technology platforms used for business operations
3. DATA PROTECTION PRINCIPLE
CompareMyTrip follows the following core principle:
Collect what we need, use it for a clear purpose, protect it appropriately, retain it only for as long as necessary, and delete it when it is no longer required.
Personal data shall not be collected, accessed, used or shared unnecessarily.
4. DATA CATEGORIES
Depending on the service requested, CompareMyTrip may process the following categories of personal data.
4.1 Identity Information
- Full name
- Date of birth
- Age
- Gender where required
- Nationality where required
- Government identification information where required
4.2 Contact Information
- Mobile number
- Email address
- Residential or correspondence address
- Emergency contact information
- WhatsApp number
4.3 Travel Information
- Destination
- Travel dates
- Passenger information
- Traveller preferences
- Hotel preferences
- Room preferences
- Flight preferences
- Activity preferences
- Trek information
- Transportation requirements
- Booking history
4.4 Passport and Immigration Information
Where required for a travel or visa service:
- Passport number
- Passport expiry date
- Passport issue information
- Date of birth
- Nationality
- Passport copy
- Visa information
- Visa application information
- Immigration documentation
Passport and immigration information shall be collected only where reasonably necessary for the relevant service or legal requirement.
5. PAYMENT INFORMATION
CompareMyTrip may process transaction-related information such as:
- Transaction ID
- Payment status
- Payment amount
- Payment method
- Payment gateway reference
- Refund status
CompareMyTrip shall not request or intentionally store unnecessary authentication credentials such as:
- ATM PIN
- UPI PIN
- Banking password
- Card PIN
- OTP
Customers must never be asked to disclose such information through WhatsApp, email, telephone, website chat or AI-assisted customer support.
6. CUSTOMER COMMUNICATION DATA
CompareMyTrip may process information provided through:
- Website forms
- Telephone calls
- Customer-support conversations
- Website chat
- Social-media communication
- AI-assisted chat
- Reviews and feedback
Such communications may contain information relating to travel requirements, bookings, preferences and customer support.
7. TECHNICAL INFORMATION
Where applicable, CompareMyTrip may collect or receive:
- IP address
- Browser type
- Device information
- Operating system
- Website activity
- Cookies
- Session information
- Approximate location information
- Referral information
- Analytics information
- Security and diagnostic information
8. PURPOSE LIMITATION
Personal data shall be processed only for identified and legitimate purposes.
Examples include:
| Personal Data | Purpose |
|---|---|
| Name | Customer identification and booking |
| Mobile number | Booking and service communication |
| Email address | Booking confirmation, invoices and communication |
| Passport information | International travel, airline or visa requirements |
| Date of birth | Airline, visa, hotel or travel requirements |
| Emergency contact | Trek and travel operational purposes |
| Payment reference | Payment reconciliation |
| Booking history | Customer support and booking management |
| WhatsApp conversations | Enquiry and customer support |
| Website activity | Security, analytics and website improvement |
| Marketing preference | Promotional communication |
CompareMyTrip shall avoid collecting information merely because the technology permits collection.
9. DATA MINIMISATION
Before collecting personal information, CompareMyTrip shall consider:
Is this information actually necessary to provide the requested service or fulfil a legitimate or legal requirement?
Where the information is not reasonably necessary, it should ordinarily not be collected.
10. PRIVACY NOTICE
CompareMyTrip shall provide an appropriate privacy notice when personal data is collected.
The privacy notice should clearly explain:
- What personal data is collected.
- Why the data is collected.
- How the data is used.
- Who the data may be shared with.
- How applicable consent may be withdrawn.
- How applicable data rights may be exercised.
- How privacy complaints may be submitted.
- How personal data is protected and retained.
The notice should be presented in a clear and understandable manner.
11. CONSENT MANAGEMENT
Where consent is the applicable basis for processing, CompareMyTrip shall use an affirmative consent mechanism.
Consent shall not ordinarily be collected through pre-selected or pre-ticked marketing checkboxes.
Example:
☐ I would like to receive travel offers, promotions and updates from CompareMyTrip.
Marketing consent should be distinguishable from information or acknowledgement necessary to provide a requested travel service.
12. BOOKING CHECKOUT CONSENT
Where applicable, the CompareMyTrip checkout process should separately identify:
Terms & Conditions
☐ I have read and agree to the CompareMyTrip Terms & Conditions and Cancellation & Refund Policy.
Privacy Notice
☐ I acknowledge the CompareMyTrip Privacy Notice and understand how my personal data will be processed to provide the requested services.
Marketing
☐ I would like to receive promotional travel offers and updates from CompareMyTrip.
Marketing consent should not be bundled into mandatory booking acceptance.
13. CONSENT RECORDS
Where consent is relied upon, CompareMyTrip should maintain an appropriate record containing, where applicable:
- Customer identifier
- Date and time
- Consent wording
- Consent version
- Purpose
- Communication channel
- Consent status
- Withdrawal date
- Relevant transaction or booking reference
14. WITHDRAWAL OF CONSENT
Where processing is based on consent, CompareMyTrip shall provide an accessible mechanism for withdrawal of consent.
Withdrawal of consent should be reasonably straightforward and should not be unnecessarily more difficult than giving consent.
Withdrawal shall not affect processing that is otherwise permitted or required by applicable law.
Where withdrawal prevents CompareMyTrip from providing a service that requires the relevant data, the customer may be informed of the resulting limitation.
15. DATA PRINCIPAL REQUESTS
Subject to applicable law, individuals may submit requests concerning their personal data.
Such requests may include:
- Access-related requests
- Correction or updating
- Erasure or deletion where applicable
- Withdrawal of consent
- Grievance
- Other rights available under applicable law
Requests shall be submitted to:
Privacy Contact: [NAME / DESIGNATION]
Email: [PRIVACY EMAIL]
Phone: [PHONE NUMBER]
16. IDENTITY VERIFICATION
CompareMyTrip may conduct reasonable identity verification before processing requests involving disclosure, modification or deletion of personal information.
Verification shall be designed to prevent:
- Identity theft
- Unauthorised disclosure
- Fraudulent deletion
- Account takeover
CompareMyTrip shall avoid collecting unnecessary information solely for verification.
17. DATA SHARING
Personal data may be shared with relevant third parties where reasonably necessary to provide the requested service or comply with applicable requirements.
Recipients may include:
- Airlines
- Hotels
- Resorts
- Homestays
- Destination Management Companies
- Trek operators
- Transportation providers
- Activity providers
- Visa service providers
- Government authorities
- Immigration authorities
- Forest authorities
- Payment providers
- Insurance providers
- Technology providers
- Cloud service providers
- Other authorised service providers
CompareMyTrip shall seek to limit information shared to what is reasonably necessary for the relevant purpose.
18. DATA PROCESSOR AND SUPPLIER MANAGEMENT
Before engaging significant technology providers or data processors, CompareMyTrip should assess:
- What data the provider receives.
- Why the provider receives the data.
- Where the data is processed.
- Security safeguards.
- Sub-processors.
- Data retention.
- Data deletion.
- Data breach notification.
- Access controls.
- Contractual obligations.
Relevant supplier and processor arrangements should contain appropriate data-protection obligations.
19. DATA PROCESSOR CONTRACT REQUIREMENTS
Where appropriate, agreements with data processors should address:
- Purpose limitation.
- Confidentiality.
- Security safeguards.
- Access restrictions.
- Sub-processors.
- Data-breach notification.
- Data retention.
- Data deletion or return.
- Assistance with applicable data requests.
- Compliance cooperation.
- Security incident management.
- Applicable legal requirements.
20. INTERNATIONAL DATA PROCESSING
International travel bookings may require personal information to be provided to service providers or authorities located outside India.
Examples include:
- Foreign airlines
- Foreign hotels
- Destination management companies
- Foreign transport providers
- Visa authorities
- Immigration authorities
- International technology providers
Such processing shall be managed in accordance with applicable law and CompareMyTrip's privacy commitments.
21. DATA RETENTION
CompareMyTrip shall retain personal data only for as long as reasonably necessary for:
- Providing the requested service
- Maintaining booking records
- Accounting
- Tax compliance
- Legal compliance
- Contractual requirements
- Dispute resolution
- Fraud prevention
- Security
- Legitimate operational requirements
Different categories of information may have different retention periods.
22. SUGGESTED RETENTION FRAMEWORK
| Data Category | Retention Approach |
|---|---|
| Enquiry data | Until enquiry closure plus approved business retention period |
| Booking records | Applicable legal, contractual and business retention period |
| Accounting records | Applicable tax/accounting retention requirement |
| Passport copies | Delete when no longer operationally or legally required |
| Visa documents | Delete when no longer required |
| Marketing consent records | Retain as necessary to demonstrate consent and manage preferences |
| Marketing opt-out records | Retain necessary suppression information |
| Customer-support conversations | Approved customer-service retention period |
| Payment references | Applicable accounting/payment retention period |
| Security logs | Approved security/legal retention period |
Retention periods should be reviewed with appropriate legal, accounting and tax advisers before final implementation.
23. SECURITY FRAMEWORK
CompareMyTrip shall maintain reasonable technical and organisational safeguards appropriate to the nature, volume and risk of personal data processed.
Security controls should include, as appropriate:
- Encryption
- Masking
- Obfuscation
- Tokenisation
- Access controls
- Authentication
- Logging
- Monitoring
- Backups
- Security testing
- Vendor security controls
24. ACCESS CONTROL
CompareMyTrip shall apply appropriate access controls including:
- Unique user accounts
- Role-based access
- Least-privilege access
- Restricted administrator access
- Periodic access reviews
- Immediate access removal when an employee or contractor leaves
- Restricted access to passport and visa documents
Employees should only access personal data necessary for their role.
25. AUTHENTICATION
Where technically available, CompareMyTrip should use:
- Strong passwords
- Multi-factor authentication
- Secure administrator accounts
- Restricted privileged access
- Password-management controls
Shared administrator credentials should be avoided.
26. PASSPORT AND TRAVEL DOCUMENT SECURITY
Passport and visa documents must be handled with enhanced care.
Employees should:
- Access documents only when necessary.
- Avoid unnecessary downloading.
- Avoid storing documents on personal devices.
- Avoid forwarding documents to personal email accounts.
- Use approved business systems for storage.
- Share documents only with authorised suppliers.
- Delete documents when the approved retention period expires.
27. WHATSAPP DATA PROTECTION
CompareMyTrip's WhatsApp operations shall follow appropriate privacy and security controls.
Employees must never request:
- OTPs
- UPI PINs
- ATM PINs
- Card PINs
- Banking passwords
Employees should avoid requesting unnecessary identity documents.
Passport, visa and other sensitive documents should be exchanged only through approved business channels and stored in approved systems.
28. AI CUSTOMER-SUPPORT DATA
CompareMyTrip may use AI-assisted systems for:
- Frequently asked questions
- Travel enquiries
- Lead qualification
- Customer support
- Travel information
- Enquiry routing
- Booking assistance
AI systems shall operate only within approved access and data-processing boundaries.
29. AI SYSTEM RESTRICTIONS
The CompareMyTrip AI system should not independently:
- Guarantee a booking.
- Guarantee availability.
- Approve refunds.
- Promise compensation outside approved policies.
- Guarantee visa approval.
- Guarantee immigration clearance.
- Alter contractual terms.
- Request OTPs, PINs or passwords.
- Make representations outside approved business information.
Material contractual decisions should be handled or confirmed by authorised CompareMyTrip personnel.
30. AI CUSTOMER DISCLOSURE
Where appropriate, customers should be informed that they may interact with an AI-assisted customer-support system.
Recommended wording:
AI-Assisted Support Notice: CompareMyTrip may use AI-assisted systems to respond to travel enquiries and provide general information. AI-generated responses are not final booking, refund, visa or contractual confirmations unless expressly confirmed by an authorised CompareMyTrip representative.
31. MARKETING DATA
Marketing information should be managed separately from operational booking information.
CompareMyTrip should maintain, where applicable:
- Marketing consent
- Communication channel
- Consent date/time
- Consent status
- Withdrawal date
- Opt-out status
- Suppression status
A customer providing information for a booking should not automatically be treated as having consented to promotional marketing where consent is required.
32. COOKIE AND TRACKING GOVERNANCE
CompareMyTrip should maintain an inventory of technologies used on its website and applications, including:
- Cookies
- Analytics tools
- Advertising pixels
- Remarketing technologies
- Tag-management systems
- Third-party scripts
For each technology, the company should document:
Technology → Purpose → Data Collected → Provider → Retention → Consent Requirement → Website/Application Location
33. EMPLOYEE ACCESS
Employee access shall be based on job requirements.
Sales employees may require:
- Name
- Mobile number
- Destination
- Travel dates
- Budget
- Enquiry information
Visa employees may require:
- Passport information
- Visa documents
- Travel information
- Supporting documentation
Accounts employees may require:
- Invoice
- Payment reference
- Refund information
- Customer billing details
Employees should not have unrestricted access to all customer information.
34. EMPLOYEE CONFIDENTIALITY
Employees, contractors and relevant business partners who handle personal data should be subject to appropriate confidentiality obligations.
35. PROHIBITED EMPLOYEE PRACTICES
Employees must not:
- Store customer passport copies unnecessarily on personal devices.
- Send customer documents to personal email accounts.
- Share customer information with unauthorised persons.
- Upload customer documents to unapproved AI tools.
- Request OTPs, PINs or passwords.
- Download customer databases unnecessarily.
- Use customer data for personal purposes.
- Sell or disclose customer information.
- Export customer lists without authorisation.
- Use customer data outside approved business purposes.
36. PERSONAL DATA BREACH
A personal-data breach may include unauthorised:
- Access
- Disclosure
- Alteration
- Loss
- Destruction
- Availability compromise
- Other compromise of personal data
Any suspected breach must be reported immediately through the internal escalation process.
37. DATA BREACH RESPONSE PROCEDURE
Step 1 — Detect
Identify the suspected incident.
Step 2 — Report
Immediately report the incident to:
Data Protection Contact: [NAME]
Email: [EMAIL]
Phone: [PHONE]
Step 3 — Contain
Where appropriate:
- Disable compromised credentials.
- Isolate affected systems.
- Stop unauthorised access.
- Preserve relevant evidence.
Step 4 — Assess
Determine:
- What data was affected?
- How many individuals may be affected?
- How did the incident occur?
- Who may have accessed the information?
- What is the potential impact?
Step 5 — Notify
Where required by applicable law, CompareMyTrip shall make appropriate notifications to affected individuals and relevant authorities within the applicable statutory timelines and through prescribed mechanisms.
Step 6 — Remediate
- Correct the vulnerability.
- Reset credentials.
- Improve security controls.
- Address affected systems.
- Document corrective actions.
Step 7 — Review
Conduct a post-incident review and implement appropriate preventive measures.
38. DATA BREACH REGISTER
CompareMyTrip should maintain an internal breach register containing:
- Incident ID
- Date and time detected
- Date and time of incident, where known
- Systems affected
- Data categories affected
- Individuals affected
- Cause
- Containment measures
- Notifications
- Remediation
- Closure date
- Lessons learned
39. DATA DELETION
When personal data is no longer required:
- Identify the relevant data.
- Confirm that no legal, contractual or regulatory retention requirement applies.
- Confirm that no legal hold or dispute requires preservation.
- Delete or anonymise the data.
- Delete relevant copies where reasonably practicable.
- Record completion where appropriate.
Deletion procedures should address applicable:
- Databases
- CRM
- Cloud storage
- Shared drives
- Documents
- Temporary files
- Backups according to the applicable backup lifecycle
40. LEGAL HOLD
Personal data must not be deleted where preservation is reasonably required for:
- Litigation
- Consumer complaints
- Fraud investigation
- Regulatory investigation
- Legal notices
- Tax or accounting requirements
- Contractual disputes
- Other applicable legal obligations
41. CHILDREN'S DATA
Where a booking involves a child or minor, CompareMyTrip shall collect only information reasonably necessary for the requested travel service.
Where applicable under law, appropriate parent or lawful guardian mechanisms shall be followed.
Marketing, profiling and behavioural-monitoring practices involving children shall be handled with particular caution and in accordance with applicable law.
42. CUSTOMER PRIVACY REQUEST WORKFLOW
The standard process shall be:
Customer Request → Identity Verification → Request Logging → Data Identification → Legal/Retention Assessment → Action → Documentation → Response
Customer-support employees should not independently delete, modify or disclose personal data outside the approved process.
43. PRIVACY INCIDENT ESCALATION
Level 1 — Low Risk
Examples:
- General privacy question
- Routine preference update
Handled by customer support or privacy contact.
Level 2 — Medium Risk
Examples:
- Possible unauthorised disclosure
- Suspicious access
- Lost customer document
Escalate to management and the data-protection responsible person.
Level 3 — High Risk
Examples:
- Confirmed significant personal-data breach
- Large-scale unauthorised disclosure
- Compromised customer database
- Major system intrusion
Immediate management, technical and legal escalation is required.
44. THIRD-PARTY REVIEW
CompareMyTrip should periodically review major data processors and suppliers according to risk.
High-priority providers may include:
- Booking technology providers
- Payment gateways
- CRM providers
- WhatsApp/Meta services
- Cloud providers
- Email providers
- Analytics providers
- Flight APIs
- Hotel APIs
- Visa processing providers
- Suppliers receiving passport or traveller information
45. DATA PROCESSOR REGISTER
CompareMyTrip should maintain a register containing:
| Provider | Data Processed | Purpose | Location | Contract | Retention | Risk |
|---|---|---|---|---|---|---|
| Payment Gateway | Transaction data | Payment processing | [ ] | [ ] | [ ] | Medium |
| WhatsApp/Meta | Customer communications | Customer support | [ ] | [ ] | [ ] | High |
| CRM | Customer data | Sales/service | [ ] | [ ] | [ ] | High |
| Hotel API | Traveller information | Hotel booking | [ ] | [ ] | [ ] | High |
| Flight API | Passenger information | Flight booking | [ ] | [ ] | [ ] | High |
| Visa Partner | Passport/visa documents | Visa processing | [ ] | [ ] | [ ] | High |
| Analytics Provider | Technical data | Analytics | [ ] | [ ] | [ ] | Medium |
46. DATA INVENTORY
CompareMyTrip should maintain a master data inventory covering:
Collection Point → Data Collected → Purpose → Applicable Processing Basis → System → Supplier → Retention → Deletion Process
The inventory should be reviewed whenever a new feature, product, supplier or technology is introduced.
47. NEW PRODUCT AND TECHNOLOGY REVIEW
Before introducing:
- A new booking API
- WhatsApp integration
- AI agent
- CRM
- Payment provider
- Analytics platform
- Visa provider
- Customer form
- Marketing platform
- New mobile application
CompareMyTrip should conduct a privacy review.
The review should determine:
- What personal data will be collected?
- Why is it required?
- Is the collection necessary?
- Who will receive the data?
- Where will the data be processed?
- How long will it be retained?
- How will it be protected?
- Is consent required?
- Does the Privacy Policy require updating?
- Does the supplier agreement require updating?
48. CUSTOMER-FACING PRIVACY DOCUMENTS
CompareMyTrip should maintain the following customer-facing documents as applicable:
Core Documents
- Privacy Policy
- Data Protection Notice
- Terms & Conditions
- Cancellation & Refund Policy
- Cookie Policy
- Grievance Redressal Policy
Recommended Additional Notices
- WhatsApp & AI Customer Communication Notice
- Visa Data Processing Notice
- Trek & Adventure Data/Safety Notice
- Marketing Communication Notice
49. WEBSITE IMPLEMENTATION
The CompareMyTrip website should provide accessible links to:
**Terms & Conditions
Privacy Policy
Cancellation & Refund Policy
Cookie Policy
Grievance Redressal**
Where applicable, checkout should provide:
☐ I acknowledge the CompareMyTrip Privacy Notice.
Marketing should use a separate optional mechanism:
☐ I would like to receive travel offers and promotional communications from CompareMyTrip.
Trust Guarantee bookings should separately state:
☐ I understand that the CompareMyTrip Trust Guarantee applies only to eligible bookings specifically identified as covered.
50. DATA PROTECTION RESPONSIBILITY
CompareMyTrip shall designate an internal person responsible for coordinating privacy and data-protection matters.
Responsible Person: [NAME]
Designation: [DESIGNATION]
Email: [EMAIL]
Phone: [PHONE]
The responsible person may coordinate:
- Privacy requests
- Data incidents
- Supplier compliance
- Policy updates
- Employee training
- Data inventory
- Retention
- Security escalation
- Privacy audits
The internal title used by CompareMyTrip shall not be represented as a statutory Data Protection Officer unless the applicable law requires or permits such designation.
51. EMPLOYEE TRAINING
Employees who handle personal data should receive periodic training covering:
- Data-protection principles
- Customer privacy
- Password security
- Phishing
- WhatsApp security
- Passport-document handling
- Customer verification
- Data sharing
- AI usage
- Breach reporting
- Data retention
- Data deletion
52. DATA PROTECTION AND MARKETING
Information collected for fulfilling a customer's booking should not automatically be treated as marketing consent where separate consent is required.
Operational communication and promotional communication should be appropriately distinguished.
53. DATA PROTECTION AND SUPPLIERS
Before sharing traveller information with a supplier, employees should consider:
Is this information necessary to fulfil this booking or service?
If yes, it may be shared through an approved business channel.
If no, it should not be shared.
54. RECORD KEEPING
CompareMyTrip should maintain appropriate records relating to:
- Privacy notices
- Consent records
- Consent withdrawals
- Data-principal requests
- Privacy complaints
- Data breaches
- Processor contracts
- Data inventories
- Retention schedules
- Security reviews
- Employee training
- Privacy assessments
- Supplier reviews
55. ANNUAL REVIEW
At least annually, CompareMyTrip should review:
- Privacy Policy
- Data inventory
- Processor register
- Retention schedule
- Security controls
- Consent mechanisms
- Cookie technologies
- AI systems
- WhatsApp workflows
- Supplier data-sharing arrangements
- Breach history
- Applicable laws and regulations
A review should also be conducted whenever there is a significant:
- Technology change
- Product change
- Supplier change
- Data-processing change
- Legal or regulatory change
- Security incident
56. COMPLIANCE DASHBOARD
Management should periodically review the following:
| Compliance Area | Target |
|---|---|
| Privacy complaints | 100% logged and tracked |
| Data requests | 100% logged and processed |
| Data breaches | 100% logged and escalated |
| Employee privacy training | 100% relevant employees |
| Processor agreements | 100% high-risk processors |
| Data retention reviews | Completed periodically |
| Consent records | Available where required |
| Access reviews | Completed periodically |
| Passport-data exposure | Minimise |
| Unauthorised access | Zero tolerance |
| Privacy policy review | At least annually |
| Supplier privacy review | Risk-based |
57. DOCUMENT HIERARCHY
The CompareMyTrip privacy programme shall operate through the following hierarchy:
Level 1 — Applicable Law and Regulations
↓
Level 2 — CompareMyTrip Data Protection & Personal Data Governance Framework
↓
Level 3 — Privacy Policy and Customer Privacy Notice
↓
Level 4 — Internal Data Protection SOPs
↓
Level 5 — Employee Procedures and Training
↓
Level 6 — Technical and Organisational Controls
58. LEGAL COMPLIANCE PRINCIPLE
Nothing in this Framework, Privacy Policy, Terms & Conditions or any other CompareMyTrip document shall be interpreted as:
- Waiving a statutory right;
- Avoiding a mandatory legal obligation;
- Preventing an individual from exercising a lawful remedy;
- Removing any obligation imposed on CompareMyTrip by applicable law.
Where applicable law provides a higher level of protection, the applicable law shall prevail.
59. MANAGEMENT APPROVAL
This Framework shall be approved by an authorised representative of CompareMyTrip.
Approved By: __________________________________
Designation: __________________________________
Date: __________________________________
Signature: __________________________________
60. VERSION CONTROL
| Version | Date | Change | Approved By |
|---|---|---|---|
| 1.0 | [DD/MM/YYYY] | Initial Data Protection Framework | [NAME] |
COMPAREMYTRIP DATA PROTECTION IMPLEMENTATION CHECKLIST
Legal and Governance
Exact legal entity name inserted
Registered office inserted
Privacy contact appointed
Official privacy email created
Grievance Officer identified
Management approval obtained
Framework version recorded
Data Management
Master data inventory created
Personal-data collection points identified
Data-processing purposes documented
Data-sharing register created
Processor register created
International data flows identified
Retention schedule approved
Deletion process implemented
Website
Privacy Policy published
Privacy Notice implemented
Terms & Conditions published
Cancellation & Refund Policy published
Cookie Policy published
Grievance Redressal published
Consent mechanisms reviewed
Marketing opt-in separated
Trust Guarantee disclosure implemented
Booking Systems
Flight data flow reviewed
Hotel data flow reviewed
Visa data flow reviewed
Trek data flow reviewed
Payment data flow reviewed
Supplier access reviewed
WhatsApp and AI
WhatsApp data flow documented
Meta/AI data processing reviewed
AI disclosure implemented
AI access restrictions implemented
Staff prohibited-data instructions issued
Customer document handling procedure implemented
Security
Role-based access implemented
Administrator access restricted
MFA enabled where available
Security logs enabled where appropriate
Backup process implemented
Passport document access restricted
Employee access review implemented
Breach-response procedure established
Employee Compliance
Employee privacy training completed
Confidentiality obligations documented
Personal-device restrictions communicated
Personal-email restrictions communicated
AI-tool usage policy communicated
Breach reporting procedure communicated
Ongoing Compliance
Annual privacy review scheduled
Processor review scheduled
Access review scheduled
Retention review scheduled
Security review scheduled
Legal/regulatory review scheduled
END OF COMPAREMYTRIP DATA PROTECTION & PERSONAL DATA GOVERNANCE FRAMEWORK
