Smart Glasses at Work: Are Your Policies Ready?
Smart glasses and AI-enabled wearables are no longer future technology.
With affordable recording-capable glasses now available in Australia, employers face a practical new question:
Could someone be recording in your workplace without you knowing?
For employers, this isn't just about smart glasses. It's about whether existing workplace policies have kept pace with increasingly discreet recording technology.
What's the risk?
Wearable devices can potentially capture:
- workplace conversations and meetings;
- employees, candidates, customers and visitors;
- computer screens and systems;
- documents and whiteboards; and
- confidential or commercially sensitive information.
Captured information may also be transferred to personal devices, apps, cloud platforms or third parties.
A 5-point check for employers
1. Review your policies
Do your privacy, confidentiality, IT, BYOD, workplace conduct and recording policies actually cover wearable technology?
2. Set a clear position
Decide when recording-capable wearables can be used, when recording requires approval, and whether certain areas or activities should be device-free.
3. Consider where your people work
Employees working at client or third-party sites may also need to comply with that organisation's recording and device requirements.
4. Don't forget visitors
Consider whether contractors, candidates, suppliers and other visitors need to be informed about recording restrictions.
5. Create a reporting process
Employees should know exactly what to do and who to contact if they suspect unauthorised recording.
What about the law?
There is no single Australian law dealing specifically with smart glasses in the workplace.
Depending on the organisation and circumstances, employers may need to consider the Privacy Act 1988 (Cth), Australian Privacy Principles, Fair Work legislation, work health and safety requirements, anti-discrimination obligations and applicable state or territory surveillance and recording laws.
Importantly, surveillance and recording laws differ between Australian states and territories.
For organisations operating across multiple jurisdictions, a national policy may therefore need to account for local requirements.
Where can employers find more information?
Start with authoritative sources:
Office of the Australian Information Commissioner (OAIC)
Privacy guidance, Australian Privacy Principles and emerging guidance on surveillance wearables.
Federal Register of Legislation
Current Commonwealth legislation, including the Privacy Act 1988.
Safe Work Australia
Guidance on workplace health and safety and managing workplace risks.
Fair Work Ombudsman
Practical information about employer and employee workplace obligations.
Your relevant state or territory legislation website and WHS regulator should also be checked for local surveillance, recording and workplace requirements.
The takeaway
Technology is changing faster than many workplace policies.
Employers don't necessarily need another complicated policy.
But they do need a clear position on wearable recording technology — what is permitted, what isn't, who can authorise it and what employees should do when something doesn't look right.
Need help reviewing your workplace policies?
Complete Staff Solutions can support organisations to review existing workplace policies, identify gaps created by emerging technology and develop practical policies and procedures that can be understood and applied by employees. Book a consultation with our team - HR Consultancy
Good policy shouldn't just sit in a handbook. It should tell people what to do.
This information is general in nature and is not legal advice. Organisations should consider their individual circumstances and obtain appropriate professional or legal advice where required.
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