When may an Irish hotel send marketing emails to past guests?
A guest email address can support a booking without belonging on your offers list. Before sending a return-stay campaign, check what the guest agreed to, how you collected their details and whether they have since opted out.
An Irish hotel normally needs a guest’s affirmative consent before emailing offers. The existing-customer exception can apply only when every condition is met, including an opt-out when collecting the address, similar services from the same business, an opt-out in each email and a first marketing message within 12 months of the sale. A previous stay alone is insufficient. See the Data Protection Commission’s conditions.
Separate booking messages from marketing
Start with the purpose of the email. A receipt, cancellation update or necessary arrival instruction concerns an existing booking. A winter-break offer or invitation to book again promotes another purchase. As a practical rule, keep promotional offers out of service templates unless the recipient is eligible for marketing.
Hotel email marketing consent in Ireland involves both the General Data Protection Regulation (GDPR) and the ePrivacy rules. A GDPR lawful basis does not bypass electronic-marketing requirements. The DPC’s consent guidance explains how the two regimes work together.
Check every existing-customer condition
- You obtained the customer’s email lawfully in connection with a sale, rather than an uncompleted enquiry.
- The offer concerns your own services of a similar kind to those purchased.
- The customer had a clear, easy, free opportunity to object when you collected the address and did not object.
- Every marketing email includes an easy opt-out, and the first is sent within 12 months of the original sale.
These are cumulative conditions under Regulation 13(11), as explained by the DPC. Adding an unsubscribe link now does not repair a missing opt-out at collection.
A decision matrix for your guest list
The following wording is illustrative. Assume a fictional Galway hotel called Example Hotel, a direct booking by the recipient and no third-party promotions. Adapt the wording to the actual business and provide its privacy information beside the choice.
| Route and decision | Illustrative wording | Evidence to retain |
|---|---|---|
| Service email | “Your booking is confirmed for 21 November. Check-in starts at 15:00.” Send necessary booking information without promotional additions. | Reservation reference, purpose, approved template version and send time. Keep the marketing preference separate. |
| Explicit opt-in | “Yes, email me accommodation offers from Example Hotel. I can unsubscribe at any time.” Use an optional, initially unticked box, separate from booking terms. | Email address, affirmative action, timestamp, collection source, wording and privacy-notice versions, named sender and email-marketing scope. |
| Existing-customer exception | At collection: “We may email you offers for similar stays at Example Hotel. Tick here if you do not want these emails. You can unsubscribe at any time.” Use only if every exception condition is satisfied. | Sale reference/date, collection date, notice and opt-out shown, recorded response, similarity assessment, first and subsequent marketing send dates. |
| Unsubscribed or objected | “Unsubscribe from accommodation offers.” Make the action work. After it is completed, show: “You have been unsubscribed from marketing emails.” | Address, scope and time of objection, source, systems updated and suppression status. Exclude from campaigns. |
Suggested operational records, not a prescribed software schema. An unknown preference must not be imported as consent. The DPC guidance distinguishes affirmative consent from the conditional opt-out exception.
Hypothetical timing check: assume the sale and lawful email collection occurred on 20 November 2025. A first offer on 13 November 2026 is within 12 months, provided every other condition holds. If the only sale was 1 October 2025 and no earlier marketing email was sent, a first offer on 13 November 2026 is outside that window.
For later campaigns, retain the send history and check the timing test in Regulation 13(11)(d), which also refers to prior marketing use within the relevant 12-month period. One timely email is not an indefinite permission slip.
Make withdrawal effective across your systems
Under the DPC’s guidance on objections, marketing must stop when the person objects; withdrawing consent must be as easy as giving it. Identify the sender and provide a valid contact address, as required by Regulation 13(10)–(12).
- Before each send, compare recipients with the latest suppression list, including objections received by reception or email.
- Test unsubscribe on mobile and confirm that it removes the address from queued campaigns and connected mailing lists.
- Keep a restricted, minimal suppression record to prevent accidental re-import; document its purpose and retention review.
- Do not let a repeat booking, spreadsheet import or profile merge silently overwrite a previous refusal.
These are practical controls for implementing the right to object. Keep necessary booking communications available separately; opting out of offers does not cancel a reservation.
Check the workflow in RoomRaccoon
RoomRaccoon’s hotel property management system (PMS) describes guest records and automated booking confirmations, cancellations and check-in emails. These capabilities do not establish marketing permission for an individual guest.
In a demonstration, trace one consent record and one unsubscribe through your proposed setup. Confirm where evidence is stored, how exports treat unknown preferences and whether suppression across an email platform needs an integration or manual process. Verify which elements are included in your subscription.
Bring a sample booking form and your mailing workflow to discuss the controls your property needs.
Book a demo for your propertyPast-guest marketing questions
Can we email guests who booked through an OTA?
An online travel agency (OTA) booking does not itself prove permission for your hotel’s campaigns. Check what information and choice the guest actually received, who collected the address and whether your intended use meets a valid route. A booking contact or relay address alone is insufficient evidence.
Does one booker’s consent cover everyone staying?
No. Do not apply the lead booker’s marketing choice to companions. Establish the applicable route for each recipient, rather than copying a preference across the reservation.
Can we email an old list to ask for consent?
Do not assume a permission-request campaign escapes marketing rules. If you cannot establish a valid route, exclude those addresses. Invite voluntary sign-up through your website or a future direct interaction instead.
Does the 12-month rule mean consent expires annually?
The first-message condition described here concerns the existing-customer exception, not a universal annual expiry for affirmative consent. Review the original scope, evidence, current expectations and any withdrawal before using older consent records.
Sources and checks
Checked 13 November 2026 for personal guest marketing in the Republic of Ireland. The matrix and system checks are practical applications of the sources below.
