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HfP and the new data protection rules

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The new European data protection rules come into force today.

As you know, HfP collects very little directly identifiable data about readers since you do not need to register to use the site.  There are four areas where you may voluntarily choose to provide directly identifiable personal data to us and I thought I would run over how we operate:

Our email list

Some readers prefer to receive HfP articles by email instead of visiting the site directly.  You can read how we, actually Mailchimp, handle your data and your rights regarding it on this page.

We have not asked subscribers to reconfirm their interest as everyone on our list explicitly signed up to receive articles by email in the first place. We have never randomly added reader email addresses to our list.

When you comment on HfP

We have produced a page of information about what data we collect on comments on the site and your rights in relation to the deletion or export of comments you make.  You can read that here.

Head for Points and GDPR

When you enter a competition

Future competitions will include a statement on how your entry data is treated by Gleam, our Data Processor.  We have never used competition entry data for any other purpose and won’t be starting now.  We are deleting all of the existing entrant data held by Gleam, so we will no longer know if you entered a specific competition back in 2015 or not!  Going forward, entry data will be deleted shortly after a winner has been selected and verified.

When you contact Bon Vivant with a hotel enquiry

Our Bon Vivant enquiry page now includes details on how Emyr and ourselves handle your enquiry.

This covers all of the scenarios under which you may provide directly identifiable data to us.

You also provide indirectly identifiable data to us when you use the site, since we are obliged to use various cookies for the site to function.  The ‘legitimate interest’ basis allows us to collect indirect data as long as it is bare minimum required for the smooth operation of the site.

We have made necessary changes where possible to cookie collection.  There will be more to come over the coming weeks as a consensus emerges on what is and is not needed – WordPress is a patchwork quilt of products and we are reliant on a large number of people to update their code.  With WordPress running 25% of global websites there are obviously many people supporting this effort.

We do not, and never have, used indirectly identifiable reader data to build behavioural user profiles or to market for any other purposes.  You do not, for example, see ads for HfP popping up when you visit other websites.

We have also taken this opportunity to add a disclosure to our articles stating that HfP may receive a commission if you make a purchase using a link on the site.

Our full privacy policy can be found here.  You can find this page at any time via the link at the bottom of each page on the desktop / tablet site.

Comments (91)

This article is closed to new comments. Feel free to ask your question in the HfP forums.

  • the real harry1 says:

    Somebody should tell those passengers on the cancelled Kiev flights to see Champions League final that they are entitled to re-routing under EC261 and do not have to accept a refund. Given Kiev is at capacity (which is why the flights have been cancelled), they could fly to a nearby airport free of charge ie get it refunded, even if it meant taking World Choice Sports to MCOL. Then hire a car at their own expense to get to Kiev in time for the final tomorrow (possibly own expense but arguable).

    Or find themselves a place on any other carrier to Kiev, even if it meant going A—>B—C to get there.

    Black & white case and definitely winnable.

    • Melvin says:

      @the real harry1
      Are you saying that under EC261, someone is entitled to be flown to another airport AND receive a refund of the original fare?

      I ask because last year, Vueling cancelled my flight to TFS (months is advance) as they had decided to drop that route from their schedule. They offered to fly me to TFN (via BCN) instead. The new outbound flight would have departed within two hours of the original but arrive @TFN well over 7 hours later than the original due to the BCN stopover.
      I am considering taking them to the small claims court for the added expense incurred re-booking with another carrier as they would have failed to get me to the correct destination if I had accepted their offer.

      P.S. the ‘other’ carrier was Monarch so there we was even more expense as I had to book for a third time (with Jet2).

      • the real harry1 says:

        You wouldn’t get both the refund and re-routing. It’s one or the other.

        Not worth pursuing the small claims case as once you accept a refund, it’s case closed. If they just automatically refunded you without your authority, that’s different.

        You could possibly have found an alternative carrier to get you to Tenerife (either airport as they’re not too far apart) within a short period of before or after your original time and if this was clearly more convenient to you than the 7 hrs delayed arrival time, pretty much have forced Vueling to ticket you on that. If they refused, you’d book it yourself then MCOL them afterwards for the cost (again, not expecting to get a refund AND a new ticket, just the cost of the new ticket).

  • KR says:

    Not a huge variety of airports near Kyiv with flights from London but Warsaw + train would be one of the better options.

    One thing i’ve never been clear on in relation to EC261 and major sporting events is whether an airline could say ‘we’ll fly you to Kyiv as promised if you don’t want a refund – but you’ll have to wait until the next day’ – ie. after the event has taken place.

    • the real harry1 says:

      Under EC261 you as passenger can choose whichever date is more convenient for you for your re-routing flight, ie earlier by a day if you wish. And the reason being attending the final would surely weigh in your favour.

      Don’t forget how the CAA came down in favour of the passenger when Ryanair had that big problem last year and forced them to be very explicit about letting passengers book themselves on competitor airlines.

      Following an intervention from the CAA, Ryanair has confirmed to the UK regulator that it will reroute passengers on other airlines.
      The directive effectively ensures that where there is a significant difference in the time that a re-route can be offered on the airline’s own services, then it would be reasonable to ask them if a re-route could be made on another airline.
      Decisions on rerouting would be dependent of the specific circumstances and the differences in times and frequency of available flights.

      The CAA told TheJournal.ie, it would be monitoring the situation closely, to ensure that Ryanair is offering the best rerouting options available to the passenger. The CAA has said that if Ryanair does not fulfil its legal obligations, it will consider its next steps which includes enforcement action.

      CAA chief executive Andrew Haines, said:
      “Passengers affected by the disruption caused by Ryanair’s cancelled flights are protected under EU law.
      ‘The welfare of passengers must be the priority for any airline experiencing disruption and we fully expect all EU airlines to meet their obligations regarding passenger rights.’
      “Ryanair is well aware of these passenger rights and we have written to the airline to clarify their legal obligations and seek assurances on how and when they will provide alternative flights with other airlines.”
      http://www.thejournal.ie/ryanair-caa-rerouting-3612081-Sep2017/

      • Nick says:

        The crucial element you’re missing here is the word ‘reasonable’. Ryanair only had to agree to start rebooking on other carriers in cases where they couldn’t get someone there within one or two days – no one even challenged them on ‘same day’ as they knew it wouldn’t be upheld.

        So in this case, if an airline offered to rebook to Kiev a day later, that would be reasonable (within the bounds of their obligations). Similarly if there’s no availability – if there were no space into Kiev on the same day on another airline, what are they supposed to do?!
        This is where a good travel insurer comes into its own – if you were travelling for an event and missed that event, you’d expect it to pay out. Airlines can’t be the insurer of last resort.

        • the real harry1 says:

          Of course, reasonable. I wouldn’t consider a day later ‘reasonable’ if it meant missing my match & I could arrange an alternative flight to get into Kiev a lot closer to my original arrival time, even if it meant flying to another city and making my way to Kiev by car/ train. Especially with tickets to the European final.

          I’m sure this would play out positively for the Liverpool fans if it came to MCOL.

  • New Card says:

    I think JAL might be funny about when they load seats onto the system. Comment here from David suggests they only load in 90 days before the flight – but that might have been your comment!

    https://headforpoints.com/2017/11/21/how-to-use-avios-for-domestic-japanese-flights-with-no-taxes/

  • luckyjim says:

    OT: Did anyone ever establish whether the IHG Free Night voucher for 10K spend on the Premium Card is issued upon hitting the 10k spend or at the end of year?
    It is used to be upon hitting the threshold but the Ts & Cs for the latest incarnation of the card seem to indicate it is the end of the card year.

    • Rob says:

      It is at the year end, 100% and on purpose.

    • Kathy says:

      End of your card year. Mine turned up yesterday, I hit the spend some time ago!

      I am now trying to decide where to use it! I am unlikely to go anywhere long-haul before it expires next year. Maybe Dublin? Or Budapest? Anyone have suggestions?

      • Leo says:

        Similar situation doesn’t fit with any of our booked travel plans – I’m struggling to find a use for mine.

    • luckyjim says:

      Hmm. So another one of those where you effectively need to renew the card to guarantee getting the reward for your previous year’s spending.

      Still, with the extra 10 000 points upon sign up and the voucher (eventually) it is still probably worth the £99 fee.

      Kathy, I find these sort of vouchers are good for turning stopovers into mini-city breaks when I’ve been unable to get direct flights. New York on the way back from Florida for example.

  • KR says:

    Excellent. Thanks.

  • jason says:

    O/T Amex hiton offer £50 off £250 spend….I stayed at the Hilton Garden Inn at Lancaster shire Cricket Club, its showing up as Lancaster Cricket club transaction rather than Hilton. It on the list as a participating hotel anyone had issues of this not tracking?

    • johnny_c-l says:

      Not stayed at that that hotel but the Hilton promo didn’t post for me either. It took a protracted chat conversation to get it sorted but was OK in the end.

  • amerikajinjanai.teemill.com says:

    O/T: Awful service with KLM yesterday. Paid over £500 for BLL-AMS-NCL as I had a very tight schedule. First leg was 50 mins late arriving (plane not at BLL on time) and so was denied boarding on the connecting flight, despite it being at the gate, because “they had already disconnected the tunnel”. Was rerouted via SOU on Flybe which would already be a 3.5 hour delay, and then the SOU to NCL leg was also delayed by about an hour.

    Have put in an EU261/2004 claim for the delay but also requested a full refund as there was no longer any reason to travel to NCL (although I still needed to go as my flight home with another carrier was from NCL).

    Customer service was terrible – cabin crew saying they have been told we won’t have a problem so everything would be fine, when it clearly wasn’t as we were still in the air when boarding for the next flight was due to close. In fact “alright” meant already rebooked on different flights that were too late (and vastly different level of service).

    What do you think the chances are on the compensation and refund claims?

    • the real harry1 says:

      If KLM through-ticketed it on one PNR then they obviously thought there was plenty of time to make the connection. Provided you arrived at NCL about 4.5 hrs late, and there were no extraordinary circumstances, you should get your short haul compensation EUR250. (You wouldn’t necessarily accept at face value their possible defence of extraordinary circumstances without asking for further details & possibly challenging them – eg knock-on effects from an earlier delay on another flight genuinely caused by extraordinary circumstances don’t mean later flights can just claim extraordinary circumstances as well. Though plenty try.)

      No chance in law on the refund front as you made your journey and any consequential losses (incl missing out on whatever it was you were due to do NCL end) is irrelevant. You might hope for a goodwill gesture, I guess, though pretty unlikely IMV..

      • Amerikajin Janai says:

        Thanks. KLM’s own literature does suggest that if the journey becomes pointless you should get a refund, and their staff who rebooked me suggested the same, but doubtless their highly-trained claim blocking task force (AKA customer service) will try to say otherwise…

        I’ll post the outcome, although I suspect it may take a while – KLM seem to be experiencing a high volume of customer complaints right now, for some reason…

        • Will says:

          If it gets annoying just hand it over to an EU261 no win no fee online company.

  • Rob says:

    Amusingly, I just had an email from Google to say that it will be October before they have worked out the technology to allow WordPress sites like ours to switch off targeted advertising on a reader by reader basis. So they are fully on the ball ….

    That said, this is a stupid concept. You (the reader) either:

    a) like targeted advertising – I personally do
    b) hate targeted advertising – which you can turn off on ALL two million Google-driven sites in one click via the link in our privacy policy
    c) hate all advertising full stop – in which case you’ll have a blocker

    I can’t seriously believe that anyone thinks ‘you know what, I like seeing targeted advertising on Head for Points but I don’t like it on Business Traveller or ft.com so I want different setting for each site’ ……

    • CV says:

      Rob,

      Unfortunately opportunity to monetise Data is too lucrative and Business believe they own data and is equivalent to your Capital adequacy war chest for future, to let it pass in digital era. World doesn’t look things in Black & White.

      For Businesses- some of the key principle they should operate for data processing in post GDPR World:

      1. Lawful, fair& transparent processing
      2. Purpose Limitation
      3. Data minimisation

      Now let’s take your above concept for targeted advertsCan any of the individual access say Google or facebook services w/o accepting their Privacy policy sans data collection and analytics? There goes your fair processing and voluntary consent through the window.

      You can build individual credit risk profile on any individual based on their browsing pattern, travel and social media posts- all the above can be done through Cookies, IP number and GPS w/o any voluntary disclosure of PII. You don’t need any consent; which is gold dust for behaviour analytics firms. Today we are building so many business models for Banks or fintech (like Kabbage) based on data profiling, Cambridge Analytica is more a trailer for real picture.

      • Nick says:

        … I delete cookies and don’t have GPS turned on, precisely because I don’t want to be tracked in this way. I don’t like IP address being used, but thankfully most residential ISPs in the UK still use dynamic ones so this is hopefully of limited utility. But what most people don’t realise is the extent to which they’re tracked… I work in data so know what they’re capable of! A friend works for a branch of a telco that does ‘innovative’ data mining. Whenever your mobile phone is turned on, booster signals in shopping centres, that kind of thing. Free WiFi in shops, cafes, etc… ever wondered why it’s ‘free’ even where the place doesn’t have any need to offer it? Yep, so you can be tracked. ‘The Cloud’ (Sky) and O2 are the biggest, and track you across multiple sites, even ones you don’t go in, just so happen to walk past the entrance doorway and your phone triggers (e.g. O2 auto-connects at every McDonald’s and non-franchised Costa). Scary as hell when you think about it. I’m glad regulators are finally starting to catch up, just don’t think they’ve gone far enough.

        • Lady London says:

          +100.

          “To make your life easy just sign up for our app” really means “sign up for our app so we can totally track you, sell everything we get from this, match your data with other site data so we know things you thought you hadn’t told us” and soon “let us knowvexactly what you are willing to pay for something from us sobwell never offer you a lower price unless you refuse 10 times” etc.

          If someone commits a crime don’t bother asking the police to find them just ask Google!

        • the real harry1 says:

          Turn off telemetry with 1 click https://www.safer-networking.org/spybot-anti-beacon/

          Speedup your computer as well, which just goes to show how much stuf you’re sending the other way.

    • luke says:

      I would say Rob though, this is a site I support, I read when I can and try to slightly point people into this direction. Obviously not everyone I meet travels or worries too much about travel.

      I have a blocker, as some sites adverts take a long time for a page to load. I am trying to add thsi site to my approved pages. If a company advertised on here I would try to use the link if I was interested in buying things from them.

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