Can I paste guest data into ChatGPT or another AI? What the GDPR and data protection authorities say (2026)

Updated: 10 November 2026

Pasting a guest's email into ChatGPT to draft the reply, or dropping the arrivals list into an AI to sort it, saves time. But that email and that list are personal data your property is responsible for. This guide sums up what the General Data Protection Regulation (GDPR), the authorities of Spain, Italy, Portugal and Greece, the European Data Protection Board (EDPB) and the official terms of OpenAI, Google and Microsoft say, checked on 10 November 2026. Anything we could not confirm is marked «unconfirmed». This is not legal advice: for a specific question, ask your adviser or data protection officer.

The short answer

The essentials:

There is no general ban on using AI, but the GDPR still applies: only the data you need, adequate security, and a provider acting as a processor under contract.
With personal or free versions of assistants you sign no such contract and, under their own terms, what you type may be used for training or read by a human reviewer.
Business versions (ChatGPT Business or Enterprise, Copilot with a work account, the API) do not train on your data by default and offer a data processing agreement (DPA).
Rule of thumb: without a business version and a DPA, paste nothing that identifies a guest. Never ID cards, passports or payment cards.
If you use AI with guest data, add it to your record of processing activities and your privacy notice.

What the GDPR says

The articles that matter when a staff member pastes guest data into an AI:

Art. 5(1)(c), data minimisation: data must be «adequate, relevant and limited to what is necessary». To improve the tone of an email, the AI does not need the name or booking number.
Art. 5(1)(f) and Art. 32: appropriate security through technical and organisational measures; Art. 32 expressly mentions pseudonymisation and encryption.
Art. 6(1): every processing operation needs one of six legal bases (for example, performing the booking contract). Convenience is not a legal basis.
Art. 28: you may only use processors providing «sufficient guarantees», under a contract stating they process data on your documented instructions, with confidentiality, and delete or return it at the end.
Art. 30: the record of processing must list categories of recipients and transfers to third countries.
Arts. 44 to 46: if data leaves the European Economic Area (many AI providers are American), you need a Commission adequacy decision or safeguards such as standard contractual clauses. Check which mechanism the provider's DPA names.

Free or personal version versus business version

What each provider's official terms say:

OpenAI (ChatGPT): for individual services «we may use your content to train our models» unless you opt out in data controls or its privacy portal; Temporary Chats are not used for training. For business products (Team or Business, Enterprise and the API) it does not train by default, offers a Data Processing Addendum and, for eligible Enterprise, Edu and API customers, data storage in Europe.
Google (Gemini): in the personal app, a subset of chats is read by human reviewers and Google asks you not to enter confidential data or anything you would not want a reviewer to see. If you turn off Keep Activity, future chats do not train its models but are kept for 72 hours. Work accounts may have different terms; the exact Google Workspace terms are unconfirmed.
Microsoft (Copilot and Copilot Chat): when used by an organisation, it is covered by the Data Protection Addendum and Product Terms, with Microsoft as processor, and prompts and responses do not train foundation models. Note: for the web searches Copilot runs (Bing), Microsoft acts as an independent controller. Terms for Copilot with a personal account: unconfirmed.
Turning off training in a personal account reduces risk, but it does not make the provider your Article 28 processor under contract.

What the authorities have said

No authority has published guidance specifically for hotels; this is the closest:

AEPD (Spain): its recommendations for chatbot users say not to give third parties' personal data «if there is doubt that the processing will go beyond the household sphere», to share as little as possible and to check whether the chatbot keeps learning from conversations. A hotel is not a household. In April 2023 it opened its own investigation into OpenAI.
Garante (Italy): on 2 November 2024 (decision no. 755) it fined OpenAI 15 million euros, among other things for training ChatGPT on users' data without an adequate legal basis and for not notifying a March 2023 breach. The Court of Rome annulled the decision on 18 March 2026 because, from February 2024, the Irish authority was competent; it did not rule on the merits. Whether it has been appealed: unconfirmed.
EDPB: its ChatGPT taskforce (report of May 2024) noted that what users type is used for training and that GDPR responsibility cannot be shifted onto users. Its Opinion 28/2024 (18 December 2024) deals with personal data in AI models and mainly addresses those who develop them.
CNPD (Portugal): in April 2025 it publicised the EDPB guide on the risks of large language models, which according to the CNPD «introduce significant privacy risks»; one of its examples is a customer-service chatbot.
HDPA (Greece): published training material on AI and the GDPR in April 2025. A Greek guide specifically on pasting data into chatbots: not found.

What you can paste and what you cannot

Practical advice drawn from the rules and the providers' terms:

Anonymise before pasting: remove name, email, phone, booking number and exact dates; write «guest A, arrives on day X». To improve the tone of a reply, the text without data is enough.
Never paste or upload photos of ID cards or passports, card numbers or guest registration lists. No AI task needs them.
Take special care with health data (allergies, reduced mobility, pregnancy) and children's data.
Do not upload full PMS exports (arrival lists, customer databases) to a personal account.
Use company accounts, not each employee's personal account, and turn off training wherever possible.

If you will use AI with guest data

Sensible steps before you start:

Choose a business version and sign or accept its DPA; file it with your other processor contracts.
Check in the DPA where data is stored, for how long and under which transfer mechanism (Arts. 44 to 46).
Update your record of processing: the AI provider as recipient and, where relevant, the transfer outside the EEA.
Update your privacy notice (recipients and transfers) and write a short internal rule: which tool, for what, and which data never.
Train front desk and reservations staff: most risks come from a hurried copy and paste.

How iQuota helps

iQuota publishes your property's data, not your guests' data, so that the AI assistants travellers already use read it correctly:

The booking page iQuota creates does not ask for ID documents or card details: payment is made at the property.
No one can guarantee that a given AI will show or recommend you.

Frequently asked questions

Can I use free ChatGPT to answer guest emails?

Yes, if you paste nothing that identifies the guest: remove name, email, phone and booking number. With personal data, the prudent choice is a business version with a processor contract (DPA).

Is turning off training in my personal account enough?

It helps, but it does not replace the processor contract required by Article 28 GDPR. In Gemini, chats are also kept for 72 hours even with activity turned off.

What happened to the Garante's fine on OpenAI?

The Garante imposed 15 million euros in 2024 (decision no. 755). The Court of Rome annulled it on 18 March 2026 for lack of competence, without ruling on the merits.

Do I have to mention it in my privacy notice?

If an AI provider processes your guests' data, it is a recipient and there may be a transfer outside the EEA: it belongs in your record of processing and your privacy notice.

What if a staff member already pasted data into a personal AI?

Assess it with your adviser: it may be a security breach that must be documented and, depending on the risk, notified to the authority. Delete the conversation and review your internal rule.

Sources

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