Online check-in: collecting guest data before arrival without keeping the documents
Updated 14.09.2026
The evening of arrival is the worst time to collect data. The guest has driven three hours, is tired and wants to get inside. And you need eleven pieces of information from whoever fills in the form — and seven from each of the others — because within twenty-four hours they have to reach the Questura, and within six if the stay is a single night. Doing it on the doorstep means copying by hand while someone waits. Asking beforehand over WhatsApp solves the evening and opens another problem: that photo never comes back.
- Eleven details from the signatory, seven from the others
- Twenty-four hours — or six, for a single night
- Why WhatsApp is not the answer
- The duty is to report, not to retain
- If check-in is digital, you have to tell the guest
- Collecting in advance does not replace looking them in the face
- How Chilloso solves it
- Frequently asked questions
Eleven details from the signatory, seven from the others
The technical annex to the decree lists what you have to transmit, and it is not the same for everyone. For family units and guided groups the rule is lighter: it is enough for one of the spouses to fill in the form, listing the other spouse and any minor children, or for the group leader to do so, listing the other members.
| Detail | Person filling in | Family and group |
|---|---|---|
| Date of arrival | yes | — |
| Number of nights of stay | yes | yes |
| Surname and first name | yes | yes |
| Gender | yes | yes |
| Date of birth | yes | yes |
| Place of birth | yes | yes |
| Nationality | yes | yes |
| Type of document | yes | — |
| Document number | yes | — |
| Place of issue | yes | — |
Place of birth and place of issue are given as municipality and province if in Italy, or as the country if abroad. For members of a family unit or a group, the document details are not transmitted at all.
A family of four is not forty-four items: it is eleven for the person filling in and seven for each of the other three, thirty-two in all. Still far too many to copy by hand at the kitchen table at eleven at night. Four friends, on the other hand, are four complete forms: forty-four.
Twenty-four hours — or six, for a single night
The ordinary deadline is set by Article 109 of the consolidated law on public security: the report must be made within the twenty-four hours following arrival. But there is a case where the time shrinks to a quarter of that, and it is precisely the short-let case: for stays of no more than twenty-four hours the report must be made within the six hours following arrival. This comes from the decree of 7 January 2013 as amended by the decree of 16 September 2021, in force since 12 January 2022.
Work it through on a single night. The guest arrives on Saturday at eleven at night and leaves the next morning: the deadline falls at five in the morning. If you already have the data, the report goes out before you go to bed. If you still have to copy it off the document, you are either working at dawn or already late.
That is why collecting the data in advance is not convenience: it is margin.
Why WhatsApp is not the answer
It is the most common shortcut, and it is the one the Garante addressed by name. In its note to the trade associations of 29 April 2026 the Authority states that document data should be collected without taking photographs using mobile devices and without relying on instant messaging services, naming WhatsApp expressly.
The reason is not a formality. A copy sent through a chat stays on the guest’s phone, on yours, in the backups and on the messaging provider’s servers. You no longer control it, and you cannot delete it from where it ended up.
The Garante writes that it stepped in now precisely because data breaches have increased in which large quantities of copies of identity documents have been exfiltrated from accommodation facilities. This is not a theoretical risk: it is the stated reason for the note.
The duty is to report, not to retain
This is the point that overturns what many are used to. The obligation under Article 109 concerns the transmission of the data to the authority, and does not imply any need to retain it at the property: retention for five years takes place on the systems of the Ministry of the Interior, not on your computer.
The only copies allowed are those strictly instrumental to entering the data into Alloggiati Web, up to the issuing of the acceptance receipt. After that moment the digital copy must be erased and the paper one destroyed. The decree itself says so, in Article 4-bis paragraph 2: erasure and destruction as soon as the system has generated the receipt — which must instead be kept for five years.
A folder of scanned passports does not protect you in an inspection: the proof of compliance is the receipt, not the image. That archive is nothing but exposure. And if it ends up where it should not, you must notify the Garante without undue delay and, where feasible, within seventy-two hours.
If check-in is digital, you have to tell the guest
There is an obligation almost nobody knows about, and it applies precisely to online check-in. Where the operations are carried out using devices capable of capturing and storing a digital copy of the document, the Garante requires you to make clear to the guest that the property will not store those images.
So it is not enough not to keep them: you also have to say so, clearly, at the moment you ask for them. Together with an equally clear account of the rationale and the methods by which that data is collected and used.
Collecting in advance does not replace looking them in the face
Beware of a misunderstanding that costs dearly. Online check-in brings forward the collection of data, not the identification. The guest must be identified on arrival, in person or over a video link: the key box with a code is not enough on its own.
The two moments are distinct and serve different purposes. Beforehand you collect the data, calmly and without transcription errors. On arrival you look at the document and check that the person in front of you is that person. The first can be automated, the second cannot.
How Chilloso solves it
After booking, the guest receives a link of their own, in their own language. They upload the documents from there, whenever it suits them: at the airport, the evening before, not at eleven at night in front of the gate.
The image serves one purpose only: reading the data. Chilloso reads it, fills in the form, and as soon as the report has gone to the Questura the image is deleted from our systems. No passing through messaging apps, no copy left lying around. And the upload page tells the guest, in writing, that the image is not stored.
On the evening of arrival you copy nothing: you look at the document, check it is the right person, and you are done. The long part is already behind you. And the Questura receipt lands in your property’s archive without your having to download it.
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