Smart glasses at work: seven things for HR to consider
Smart glasses are moving from novelty gadget to mainstream wearable technology. That creates a new question for HR: what happens when employees start wearing them at work?
The answer is not simply to treat them like an ordinary pair of glasses. Depending on the device, smart glasses can take photographs, record audio and video, livestream, respond to voice commands and process information using AI. Some may also transmit data to external providers.
That creates obvious risks around privacy, data protection and confidentiality. But there is also a significant employee relations issue. Colleagues may have no way of knowing whether someone wearing smart glasses is recording them. The perception of being monitored can itself cause discomfort and undermine trust. HR need to get ahead of the issue.
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Decide what your position is
Don’t wait until someone turns up wearing smart glasses. Consider whether there is any legitimate reason for employees to use them at work and balance this against the risks. In workplaces involving confidential conversations, personal data or commercially sensitive information, a prohibition on personal smart glasses may be the simplest approach.
Elsewhere, employers might permit them but prohibit recording or restrict their use in particular areas.
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Don’t make a ban completely inflexible
There may be good reasons for prohibiting smart glasses in some workplaces, but employers should leave room for exceptions. For some disabled employees, smart wearable technology may help to remove workplace disadvantages and could potentially amount to a reasonable adjustment under the Equality Act 2010. Smart glasses might, for example, provide real-time captions or transcription for someone with a hearing impairment, audio assistance for someone with a visual impairment, or prompts and reminders which assist a neurodivergent employee.
That does not mean an employer must automatically permit a particular device. The usual reasonable adjustment principles still apply, and the employer can consider issues such as effectiveness, practicality, privacy, confidentiality and security. However, an absolute ban which allows no scope for individual circumstances could create discrimination risks.
Policies should therefore build in some flexibility, for example by prohibiting personal smart wearable devices unless their use has been expressly authorised by the employer, including where agreed as a reasonable adjustment.
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Update your policies
Check whether existing IT, data protection, monitoring and acceptable use policies actually cover wearable technology.
A policy drafted around phones and laptops may not be wide enough. Consider using a broader definition of ‘smart wearable devices’ covering smart glasses, smart watches, body-worn cameras and similar emerging technology.
The rules should also cover capturing, storing and transmitting data, rather than simply “recording”.
An updated policy can also set out the disciplinary consequences of failing to follow workplace rules on smart wearable devices – giving the business a key element of control and acting as a deterrent to breach.
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Think beyond actual recording
An employee may respond to concerns by saying: “But I’m not recording anything.” That does not necessarily solve the problem.
Colleagues, customers and clients may not know whether a device is active. Employers should therefore consider whether simply wearing recording-capable technology in certain environments creates an unacceptable perception of surveillance.
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Think about customers and other third parties too
The issue does not stop with employees wearing smart glasses. From 30 October 2026, employers will have specific obligations concerning harassment of employees by third parties. That provides a reason to think about how smart wearable technology is used by customers, clients, contractors and visitors.
If, for example, an employee is concerned that a customer is using smart glasses to record them, employers should not automatically dismiss the concern simply because the individual is not a member of staff. Depending on the circumstances, appropriate steps might include asking the third party to stop recording, making clear that recording staff is prohibited on the premises, displaying appropriate notices or incorporating restrictions into visitor or contractor rules.
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Don’t forget data protection and confidentiality
Smart glasses could inadvertently capture considerably more than their wearer intends: colleagues’ conversations, computer screens, customer information, health information or confidential business discussions.
The risk increases where information can be uploaded automatically or shared with technology or AI providers. Once that happens, the employer may have little practical control over where the information goes or how it can be retrieved or deleted.
A risk assessment, and potentially a data protection impact assessment where the employer intends to introduce or authorise the technology, should therefore form part of the process.
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Make the consequences clear
Finally, employees need to know where the boundaries lie. Policies should make clear that unauthorised recording, transmission or storage of personal or confidential information using smart wearable devices may be treated as a serious disciplinary matter and could also result in a reportable data breach.
Key takeaway
Smart glasses may be new, but the underlying HR issues aren’t. Privacy, transparency, confidentiality and trust are familiar territory. Employers should decide their position now; update their policies and make sure employees understand where the boundaries lie.