Advice to STB on the improvements to the publication of hotel industry information
In November 2015, the Singapore Tourism Board (“STB”) consulted CCS on a proposal to improve the timeliness in the publication of hotel industry information. This information includes historical average room rates (“ARR”), historical average occupancy rates (“AOR”), historical revenue per available room (RevPar) (collectively, “Data”). This Data is collected from gazetted hotels in Singapore and published on an aggregated basis as well as by the four hotel tiers (luxury, upscale, mid-tier and economy). The time lag in publication of the Data on STB’s corporate website is several weeks after the close of each month. To reduce the time lag in the publication of the Data and to provide more useful information for the hotel industry, STB is exploring the possibility of automating the information collection process from hotels and to also allow users to customise the information they obtain from STB’s website. CCS considered that the exchange and publication of certain information can increase market transparency, encourage competition and assist efficient resource allocation. CCS also noted that the competition risks are greater where commercially sensitive and confidential information is exchanged or published. For example, the exchange or publication of current or prospective commercially sensitive information is more likely to facilitate anti-competitive conduct and lead to price convergence. As the Data published by STB will continue to be aggregated and historical in nature, CCS advised that STB’s proposal is unlikely to raise competition concerns. However, regarding the potential customisation of the Data obtained from STB’s website, CCS advised that it is important to have a sufficiently large sample size to make sure that users will not be able to reverse-engineer the Data to arrive at individualised hotel information.