As AI-powered smart glasses become more accessible, employers may face a growing range of legal and practical challenges. Liam Entwistle, an employment law specialist at Wright, Johnston & Mackenzie LLP, warns that businesses need to consider the impact of this technology on their workplaces. With the market for smart eyewear described as “early and emerging” but driven by growing consumer demand for hands-free AI technology, Entwistle emphasizes the urgency of addressing these issues.
Smart glasses can record conversations, take photographs, and capture video without the wearer having to visibly operate a device. This raises concerns about privacy, harassment, data protection, and confidentiality. The discreet nature of these devices means employees can record interactions without others being aware, creating an environment of uncertainty and potential discomfort.
Legal Implications and Employer Responsibilities
The issue is particularly significant for public-facing businesses. New harassment protections coming into force in October 2026 will require employers to take reasonable steps to prevent sexual harassment and third-party harassment by customers or clients. Under the Employment Rights Act 2025, employers must not only prevent harassment of employees but also ensure that third parties, including customers and clients, do not engage in harassing behavior. This obligation extends to situations where smart glasses could be used to record employees without their consent, creating a complex challenge for businesses.
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With the growing popularity of hands-free AI technology, some UK businesses have already banned Meta’s smart glasses due to privacy and moral concerns. Employers must now consider what constitutes a reasonable response to customers wearing such devices, balancing customer service with employee protection. This includes deciding whether to prohibit the use of smart glasses in certain areas or implementing policies to inform employees when recording is taking place.
As smart glasses become more prevalent, employers will need to reassess their workplace policies. This includes addressing data protection concerns, especially when recordings are automatically transferred, stored, or processed elsewhere. The potential for unauthorized data collection and storage raises questions about compliance with data protection laws, such as GDPR, and the need for explicit consent in recording scenarios.
The challenge extends beyond traditional offices. With hybrid and remote work arrangements, employers must ensure their policies cover situations where employees use wearable technology to capture audio or visual material less conspicuously than with conventional devices. This includes virtual meetings and remote interactions, where the risk of unnoticed recording remains high. Employers need to establish clear guidelines for the use of smart glasses in all work settings to mitigate risks.