Smart glasses are no longer a glimpse of the future. Devices such as Meta’s Ray-Ban smart glasses are becoming increasingly mainstream, bringing AI, cameras, microphones and real-time assistance into everyday environments.
Recent scrutiny from the UK Information Commission Office (ICO) highlights just how quickly wearable technology is challenging established expectations around data protection and workplace privacy. As organisations balance innovation with compliance obligations, now is a good time to review whether existing policies are fit for purpose.
Why Are Meta Smart Glasses in the Spotlight?
Earlier this year, reports emerged that the ICO was seeking information from Meta following allegations that human reviewers working on AI training programmes had access to recordings captured through Meta smart glasses. According to reporting by The Register, concerns centred around personal footage, conversations and other sensitive information that may have been unintentionally captured through the devices.
The ICO described the allegations as “concerning” and reiterated that organisations deploying technologies that capture personal data must be transparent about what information is collected, how it is used, and who may have access to it. The regulator also emphasised the importance of ensuring users understand when their data may be used to train or develop AI systems.
While Meta maintains that users can control and manage recordings through device settings, the wider debate has highlighted a growing challenge: wearable technology makes data collection more seamless, less visible and often less obvious to those around the wearer.
The Bigger Issue: Trust
In its recent article, Enabling technology for good: smart glasses, privacy and a broader challenge for public trust, the ICO argues that smart glasses should not simply be viewed as either “good” or “bad” technology. Instead, the focus should be on how society, regulators and organisations develop safeguards that enable innovation while maintaining public trust.
The regulator notes that many of the underlying technologies already exist in smartphones. The difference is that wearable devices make data collection easier, more continuous and less noticeable. This creates important questions around:
- Transparency
- Consent
- Accountability
- Data minimisation
- Privacy by design
The ICO also highlights a critical challenge: people may not always know when information about them is being captured by wearable devices, particularly as cameras and AI become smaller and less obvious.
What Does This Mean for Employers?
For many organisations, wearable technology policies simply don’t exist yet. Most acceptable use, information security and bring-your-own-device (BYOD) policies were written before AI-enabled glasses entered the workplace. As a result, businesses may find themselves exposed to risks they have not fully considered.
Potential concerns include:
Unauthorised Recording: Employees may unintentionally capture colleagues, customers, visitors or confidential business discussions.
Sensitive Information Exposure: Screens, documents, whiteboards, customer records or commercially sensitive conversations could be recorded without realising it.
Compliance and Regulatory Risk: Depending on how recordings are used, stored or shared, there may be implications under UK GDPR and data protection legislation.
Customer and Employee Trust: Even where a use case is legitimate, uncertainty around recording can create discomfort and damage trust if expectations are not clearly managed.
Our Advice: Start with Policy, Not Technology: As with most emerging technologies, banning a device outright is rarely the long-term answer. Equally, allowing unrestricted use introduces unnecessary risk.
Instead, organisations should focus on establishing clear governance and user expectations.
We recommend reviewing existing policies to ensure they address:
- Wearable technology and smart devices
- Workplace recording and photography
- AI-enabled consumer devices
- Data handling and information security
- Remote and hybrid working environments
- Visitor and customer-facing interactions
Policies should clearly explain where devices can and cannot be used, what information should never be recorded, and the responsibilities of employees when using emerging technology in a professional environment.
Privacy by Design Matters
One of the most important messages from the ICO is that privacy should not be treated as a compliance exercise. It should form part of the design, deployment and use of technology from the outset. That principle applies equally to organisations considering wearable technology internally.
Before introducing or permitting smart glasses within a business environment, organisations should consider:
- What personal data could be captured?
- Is there a legitimate business purpose?
- Are less intrusive alternatives available?
- How will people be informed?
- What controls are in place to minimise risk?
These are the same questions that underpin good information governance and responsible AI adoption and carrying out a data protection impact assessment, will help in answering these questions.
Looking Ahead
Smart glasses are unlikely to be the last technology to challenge traditional approaches to privacy and compliance. As AI becomes increasingly embedded within everyday devices, organisations will need to adapt policies and governance frameworks accordingly. The businesses that navigate this successfully will be those that balance innovation with transparency, establish clear expectations and build trust alongside capability. Technology continues to evolve. Good governance should evolve with it.
From information governance and data protection policies to AI governance frameworks and cyber security assurance, we help organisations implement practical controls that support innovation while keeping compliance and trust front of mind. Get in touch at info@evolvenorth.com or call 01748 905 002 to discuss how we can help.