EDPB Statement on Smart Glasses

Statement on Smart glasses

The statement sets out the EDPB's preliminary reflections on processing personal data through smart glasses, defined as wearable devices resembling ordinary eyewear that include cameras, microphones, speakers and software, including AI systems. It identifies risks from near-invisible recording, capture of background conversations and possible combination with facial or voice recognition. It also lists sensitive contexts such as medical facilities, schools, changing rooms and workplaces. On controllership, it explains that users fall under the household exemption in Article 2(2)(c) GDPR only for purely personal use. Producers and providers of linked applications or AI services may be independent or joint controllers and cannot rely on users to meet their transparency obligations towards bystanders. The statement finds traditional notices insufficient for non-users under Articles 12–14 GDPR. It describes in-the-moment transparency mechanisms: LED and audio indicators, smartphone proximity notifications, and distinguishing design. On legal basis under Article 6(1) GDPR, it notes that valid consent is difficult to obtain from bystanders. It also finds legitimate interests hard to rely on, particularly for further processing or AI training, and recalls the right to object under Article 21. It recommends data minimisation, on-device blurring of bystanders, storage disabled by default, geofencing and "privacy frictions" on social media sharing.