Privacy Ref Blog

Business and wearable technology

Over the past few weeks I have been wearing my Google Glass in public. The experiences have been invaluable to my understanding of the privacy implications of wearable technology. Lately I have been giving some thought to the business policy challenges the technology presents.

Introducing wearable technology to your business

It can be argued that the use of wearable technology in business is not new. For an example visit an Office Depot retail store and notice that every employee on the floor is wearing a headset. The headset allows the staff to communicate with other store team members to get assistance or for a manager to direct resources to assist customers. With a headset there are visible and audible queues that the technology is being used. Also, since two-way communications is readily accepted by the public, there is little controversy about its use. Introducing wearable technology that is still emerging and is more comprehensive than a two-way radio will present some challenges.

If your business begins to utilize wearable technology, it may be met with some resistance by the public. Regardless of the setting, in a retail store or within an office, visitors may be skeptical of the technology, its use, and its impact on privacy. Establishing policies to support the use of wearable technology will assist in addressing concerns. Further, a marketing-type campaign explaining how the technology will improve things for your stakeholders, be they customers or vendors, will help to put these visitors at ease.

Policy considerations

If your organization is using wearable technology in its operations some basic etiquette can be introduced as part of your policy.

  1. Be transparent that wearable technology is being used.
  2. Provide verbal notice to visitors / customers by explaining what the technology is and how it is used.
  3. Respect requests for information from anyone that approaches.
  4. Respect privacy requests from individuals.

Organizations also need to recognize that visitors and employees may be using wearable technology for their professional or personal use as well. Policies should be defined and enforced regarding the use of this technology in the organization’s environment. Items to consider should include:

The use of cameras – Many businesses have prohibitions regarding the use of cameras, both photo and video, on premises. However, with the ubiquity of smartphones, these prohibitions are often not enforced. This could easily result in privacy breaches and the loss of intellectual property. Businesses need to re-evalute the applicability and enforcement of these policies.

Location-based services – The ability to determine location of an individual through their wearable (or smartphone or tablet) technology introduces risk to a business’s security. If a person is known to work in an area that contains personal and/or classified material, the tracking of their location can assist “evil-doers” in determining where the information resides and how to access the area. It is recommended that any personal technology that can determine location be banned from areas containing classified information or processes.

Perceptions of surveillance – Wearable technology can collect images, sound, location , as well as biometric information. If a business implements wearable technology employees may perceive that they are under constant surveillance. In addition to any legal requirements that must be addressed, businesses must work with their employees, unions, works councils, etc. to ensure acceptance of the use of the technology including dispelling any surveillance concerns.

It is important to note that other examples of wearable technology, such as the Samsung Galaxy Gear smartwatch, may be more difficult to detect; their presence is not as apparent as that of Glass. When defining your business’s policies you will need to consider how to enforce policies when you cannot easily detect the presence of wearable technology.

Wearable technology and privacy

My perspective continues to evolve, but I am less concerned about privacy related to Glass than I was before I started using the product. I am beginning to view the basic privacy challenges as similar to those associated with existing mobile technology. For Glass, the privacy risks are basically the same as with any Android-based technology.

A simple example of the parallelism can be seen if you consider taking a picture or video with wearable technology on your smartphone. In both cases an image is being taken of a person with or without their knowledge and consent (remember that Romney fundraiser?). In both cases the onus lies with the app/glassware developers, businesses, and users to decide what is collected, what is shared, how it is shared, and who else receives any information collected.

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    By: Bob Siegel

    Bob Siegel, the founder and President of Privacy Ref, Inc., has extensive professional experience in the development and improvement of privacy policies and procedures, the definition of performance metrics to evaluate privacy maturity, and the evaluation of compliance. He utilizes a combination of alignment, adaptability, and accountability strategies to guide organizations in achieving their privacy goals.

    He is a Fellow of Information Privacy (FIP) and a Certified Information Privacy Professional, awarded from the International Association of Privacy Professionals, with concentrations in U.S. private-sector law (CIPP/US), US public sector law (CIPP/G), European law (CIPP/E), and Canadian law (CIPP/C). He is also a Certified Information Privacy Manager (CIPM) and Privacy Technologist (CIPT).

    Siegel is a member of the IAPP faculty, has served on the Certification Advisory Board for the CIPM program the Publications Advisory Board.

    Siegel also writes the blog “Operational Privacy” on CSOonline.com

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Privacy Ref provides consulting and assessment services to build and improve organizational privacy programs. For more information call Privacy Ref at (888) 470-1528 or email us at info@privacyref.com

Posted on February 17, 2014 by Bob Siegel
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