EU privacy board warns of smart glasses risks, urges clear recording signals

Preliminary guidance for users and industry

At its latest plenary, the EDPB adopted the statement and published the report "The connected gaze. Video recording, surveillance and administering evidence in the age of smart glasses". According to the Board, smart glasses are becoming widely available and more frequently used. They raise significant questions for the protection of personal data, rights and freedoms, even though they create new opportunities for communication, assistance and innovation.

The text is described as an initial statement. It offers preliminary guidance to users, manufacturers and service providers and aims to raise awareness of the risks the devices pose.

EDPB Chair Anu Talus said the devices "look like ordinary glasses, but they include cameras and microphones and are connected to the internet." She pointed to greater risks in sensitive environments such as hospitals, schools or workplaces, and when recordings are shared on social networks. She added that children are especially at risk, both when using the glasses and when they are filmed.

Who is responsible under the GDPR

The Board says a user's responsibility under the GDPR depends on how the glasses are used. A user would be considered a data controller if they share a photo or video on a public social media account, or if the glasses are used as part of official, professional or political activities.

If a user records family members or friends, or uses the device for personal translation in a private context, this is considered a purely personal activity. In that case the GDPR does not apply, under the household exemption. The EDPB notes that criminal, civil or labour law, as well as other sector-specific rules, may still apply.

The statement also stresses that producers and providers of linked applications or services are data controllers as well. They cannot transfer their obligations to users. They must comply with data protection law and ensure any new data processing remains compatible with the original purpose of collection.

Transparency for bystanders

The EDPB names transparency as one of the main challenges. Because of the discreet appearance and use of smart glasses, bystanders may not know that their data is being processed, by whom, or for what purposes.

Talus said smart glasses should make recording obvious, for instance with bright LED lights, audio signals or voice activation cues, privacy-friendly smartphone notifications, or unique designs. In her words, these warnings need to be "reliable, hard to ignore, and always up to date", and bystanders should clearly understand when someone is filming or photographing them, even in public spaces. The statement also encourages industry standards and awareness-raising measures.

What the commissioned report found

The report was commissioned by the Board through its Support Pool of Experts (SPE) programme, following a proposal from the French data protection authority. Its aim was to better understand smart glasses usage, their privacy implications and their societal acceptability.

It was developed by a digital sociologist and examines both user experiences and the perceptions of non-users about the associated risks, supported by real-life examples from interviewees. The research shows that smart glasses are sometimes becoming instruments of interpersonal surveillance and handling of evidence. It also finds that people's ability to use the devices effectively varies widely, which creates power imbalances between those who use them and those being recorded.

The EDPB points out that the report was prepared by an external contractor. Its views are those of the authors and do not necessarily reflect the official position of the Board.

What it means for users and manufacturers

For wearers, the statement makes clear that sharing footage publicly or using the glasses in professional settings can bring GDPR duties. For manufacturers and service providers, it signals that responsibility cannot be passed on to users and that visible recording indicators are expected. As an initial statement, it gives preliminary guidance rather than final rules.