EDPB Publishes Statement on Data Protection Challenges Posed by Smart Glasses

The European Data Protection Board (“EDPB”) adopted Statement 1/2026 on Smart Glasses and published the report entitled “The Connected Gaze: Video Recording, Surveillance and Administering Evidence in the Age of Smart Glasses” on 13 October 2026. The report was developed within the framework of the Support Pool of Experts (“SPE”) programme.

The statement addresses the data protection risks arising from the increasing availability and use of smart glasses, which, despite creating new opportunities for communication, assistance and innovation, raise significant concerns regarding the protection of individuals’ personal data and fundamental rights and freedoms.

The statement highlights the following matters in particular:

• The determination of whether a user qualifies as a data controller under the General Data Protection Regulation (“GDPR”) depends on the manner in which smart glasses are used. Where photographs or videos are shared through public social media accounts, or the devices are used for official, professional or political activities, the user may be considered a data controller. By contrast, activities carried out purely for personal or household purposes, such as recording family members or friends or using translation functions in a private context, may fall within the household exemption. Nevertheless, even where the GDPR does not apply, the use of smart glasses may remain subject to criminal, civil and employment law, as well as other sector-specific legislation.
• Manufacturers and providers of connected applications or services cannot transfer their own data protection obligations to users. Compliance with applicable data protection legislation must be ensured, and any further processing of personal data must remain compatible with the original purpose for which the data was collected.
• Transparency has been identified as one of the main data protection challenges associated with smart glasses. Due to their discreet appearance and use, bystanders may be unaware that their personal data is being processed, who is processing it and for what purposes. To address this concern, the use of clear and reliable recording indicators, such as visible LED lights, audio signals, voice activation cues, privacy-friendly smartphone notifications or distinctive designs, has been encouraged.
• Particular concerns have been raised regarding the use of smart glasses in sensitive environments, including hospitals, schools and workplaces, as well as the sharing of recordings on social media. The risks faced by children have also been emphasised, both when smart glasses are used by them and when they are recorded by others.
• The development of industry standards and awareness-raising measures has been encouraged to help individuals recognise when smart glasses are being used and understand how their personal data is processed.

In addition, the report entitled “The Connected Gaze: Video Recording, Surveillance and Administering Evidence in the Age of Smart Glasses” was commissioned by the EDPB through its SPE programme, following a proposal by the French Data Protection Authority. The report examines the use of smart glasses, their privacy implications and their societal acceptability. Both users’ experiences and non-users’ perceptions of the associated risks are analysed, with real-life examples drawn from interviews.

The findings indicate that smart glasses may be used as instruments of interpersonal surveillance and for the collection and handling of evidence. Moreover, differences in individuals’ ability to use these devices effectively may create power imbalances between those using the devices and those being recorded.

The statement is intended to provide preliminary guidance to users, manufacturers and service providers while raising awareness of the data protection risks associated with smart glasses.

You can access the full text of the report.

Kind regards,
Zumbul Attorneys-at-Law
info@zumbul.av.tr

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