Case Study Ryanair

CASE STUDY 7/01

Ryanair – on-line booking – delayed credit card charge – whether charge activated upon a subsequent transaction – question of disclosure of passenger data

The complainant booked an airline ticket from Ryanair, a major �low-cost’ carrier, on the internet using her credit card. However, the charge did not appear on her subsequent credit cards bills. Over ten months later, however, she booked another flight with the same airline. Her next credit card bill included two charges – one for the recent booking, and one for the booking from ten months earlier. The complainant suspected that Ryanair had associated her details with her previous booking, and had taken the opportunity to charge her credit card account for the first flight, to compensate for its own oversight. The complainant accepted that she owed the money for the first flight; but she maintained that she had given her credit card details in good faith on the first occasion, and it was hardly her fault that the airline had neglected to charge her at the time. It was not acceptable, in her view, that her credit card details – made available specifically for the second flight – should be appropriated to pay for the first flight.

The data protection issue which arose was whether the credit card data, obtained for the second booking, had been �obtained and processed fairly’ by Ryanair, as required under section 2(1)(a) of the Act. On the face of it, there was a clear suggestion that the information obtained on the second occasion was used for the purpose of a completely separate transaction.

On investigating the matter, the airline company stated that the delay in processing the payment for the first flight was due to a computer error. A batch file containing data relating to the date of the first flight, including the complainant’s data, had not been sent to the bank for processing. This error was discovered some time after the event, whereupon the processing of the original batch file was reactivated. This processing happened to take place around the same time as the complainant made her second flight booking. Accordingly, the fact that both payments appeared together on the complainant’s credit card bill was simply a coincidence. The airline specifically denied that the data obtained on the second occasion had been used to secure payment for the first flight booking.

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