What guest-registration and ID details should an Irish hotel collect at check-in?
A check-in form should tell reception who is staying, support the applicable guest register and avoid collecting unnecessary identity data. Decide what each field does before making it compulsory.
Collect the names and stay details needed to manage the booking, with contact information where necessary. Separately, apply Ireland’s hotel-register requirements to guests within their legal scope, using a legally checked register specification. Keeping a register does not itself require retaining a full passport copy. Decide separately whether identity verification, particular document fields or an image are necessary.
Establish who the register covers
Section 10 of the Immigration Act 2004 requires commercial accommodation providers to keep a register of non-nationals at the premises and produce it when requested by a Garda or immigration officer. It provides for regulations governing the form, entries and retention; it does not itself enumerate the fields.
“Non-national” is a statutory category, not a synonym for an overseas booking. The 2004 Act’s definition refers to the 1999 Act, which incorporates Aliens Act exemptions. British citizens benefit from the 1999 exemption order. Do not classify someone by their address, accent or arrival airport.
Section 2 also contains immunities and preserves European Union (EU) law obligations. Have your adviser resolve EU, European Economic Area (EEA), Swiss and other relevant cases before configuring nationality rules; “non-national” must not simply become “non-EU”. The Act’s Second Schedule concerns section 9 immigration registration, not a ready-made hotel check-in form.
Check the actual form before enforcing fields. The 1946 Aliens Order contains an older seven-column register and a two-year retention provision. Its present application alongside section 10 needs confirmation. Do not automatically adopt that period, a UK hotel form or a software default as your current Irish requirement.
A field matrix for your check-in form
This proposed operational matrix assumes a hotel in the Republic of Ireland. “Necessary” means needed for the stated task; “legally verify” means confirm the applicable requirement before treating the field as compulsory. It is not a certified statutory register.
| Field | Status and purpose | Access | Retention control |
|---|---|---|---|
| Guest names, booking reference, room, arrival and departure dates, occupancy | Necessary: identify the stay and occupants; verify register coverage separately. | Reception and duty manager; share only operational subsets with other teams. | Apply the approved booking/register schedule; do not keep duplicate arrival lists indefinitely. |
| One suitable contact method | Necessary where needed for stay communications. Avoid demanding both email and phone without a reason. | Reception and relevant guest-service staff. | Review after stay-related communications and unresolved issues end. |
| Nationality | Legally verify: determine register scope and any required entry; residence is different. | Authorised registration staff. | Use the confirmed register period; exclude from routine marketing exports. |
| Usual address, previous accommodation address, onward address | Legally verify: these appear in the historical register; confirm current applicability individually. | Registration staff; billing staff receive only necessary billing details. | Confirm the register rule before activating collection or deletion. |
| Date of birth, signature, ID type, document number or expiry | Legally verify or justify separately. A scanner’s available fields do not make them mandatory. | Limited registration staff and authorised reviewers. | Assign a purpose-specific period to each field; no automatic lifetime guest-profile storage. |
| Identity-check outcome, date and staff reference | Necessary only where a justified verification process requires evidence of the check. | Reception and authorised managers. | Keep only for the documented verification or dispute purpose. |
| Full passport or ID image | Not a default field. Requires a separate lawful, necessary and proportionate purpose. | Specifically authorised staff only. | Delete when the justified purpose ends, unless a documented obligation requires continued retention. |
| Car registration or room preference | Optional unless needed for a requested service, such as controlled parking. | Parking or guest-service staff, as relevant. | Remove when the service purpose ends; review any agreed future preference separately. |
Access and review triggers above are proposed controls, not statutory periods. The Data Protection Commission (DPC) retention guidance confirms that the General Data Protection Regulation (GDPR) supplies no universal retention period: purpose and applicable legal obligations determine it.
Hypothetical example: a Galway hotel needs a registration number for its gated car park. It asks drivers using that service, rather than making the field compulsory for guests arriving by coach. The parking record is kept separate from any statutory guest register.
Separate verification from copying
Looking at an ID, extracting selected fields and retaining its image are different processing activities. Apply the DPC’s data-protection principles to each: identify a lawful purpose, minimise collection, explain it clearly and protect access.
- Match the arriving guest to the reservation; resolve booker-versus-guest differences before issuing a key.
- Explain which details are required by a verified legal obligation, which support the stay and which are optional. Make the privacy notice available before collection.
- Where an ID check is justified, consider whether sighting the document and recording the outcome achieves the purpose without an image.
- If scanning, inspect the extracted fields and correct errors. Check whether images persist in the system, device, downloads or backups.
- Avoid collecting passport images through staff phones or shared inboxes. Escalate an exceptional copying request to the responsible manager with its purpose and deletion trigger.
The DPC’s 2023 Airbnb case found infringements involving an ID-copy request and continued retention after verification. It illustrates proportionality and retention risks; it does not establish the statutory fields for Irish hotels.
Apply the policy in RoomRaccoon
RoomRaccoon’s RaccoonID hotel ID scanner is presented as an upgrade that automatically fills guest details, including through online check-in. Its property management system (PMS) supports reservations and check-in workflows. These capabilities assist data entry; they do not determine your legal collection policy.
Use a test reservation to review captured fields, staff visibility, image handling and deletion behaviour. Ask which controls and upgrade arrangements are available for your account before adopting the workflow.
Bring your approved field matrix and test how it fits your property’s arrival process.
Book a demo for your propertyGuest registration and ID questions
Must every guest hand over a passport?
The register duty is not, by itself, a blanket passport-copy requirement. Define acceptable verification methods and an escalation route for guests without the requested document. Distinguish your justified hotel policy from a legal obligation.
Is the lead booker’s name enough for a group?
A booker may not be staying. Identify the actual occupants needed for your operational records and assess applicable register requirements per guest. Do not automatically copy one person’s nationality or ID details across the whole reservation.
Should children complete the adult ID fields?
Use age-appropriate collection and confirm the applicable register rules. An age exemption in a different immigration provision does not automatically settle hotel registration. Avoid collecting a child’s full document simply because the adult form includes an upload box.
Does giving an email address permit marketing?
Keep stay communications and marketing decisions separate. Do not treat a required contact field or a signed registration form as blanket permission for promotional emails.
Sources and checks
Checked 13 November 2026. Republic of Ireland; operational controls are distinguished from statutory requirements.
- Law Reform Commission: Immigration Act 2004, sections 1, 2, 9 and 10.
- Immigration Act 1999: definition of non-national; British-citizen exemption order.
- Aliens Order 1946, article 12 and Third Schedule; 2004 Act amendments and instruments directory.
- DPC: data-protection principles and retention guidance.
- DPC Annual Report 2023, page 49: Airbnb ID verification case.
- RoomRaccoon: ID Scanner for Hotels and Property Management Software.
