New Zealand Privacy Commissioner sets expectations for AI-enabled smart glasses

New Zealand’s Privacy Commissioner has issued new guidance on smart glasses, warning that devices combining discreet cameras with AI can create privacy risks when people are recorded or analysed without realising it.

The guidance is particularly relevant as consumer glasses increasingly connect with AI systems capable of recognising and describing people, objects and environments. The Commissioner says New Zealand’s existing privacy rules still apply even when the technology is new.

Key facts

  • Smart glasses can capture photos, video and other information while appearing similar to ordinary eyewear.
  • Connected AI applications can recognise and describe scenes and environments.
  • Covert recording is a particular concern because people may not realise they are being filmed.
  • Organisations using smart glasses must consider whether collecting personal information is necessary and lawful.
  • Transparency and clear notification remain important where people may be recorded.
  • The guidance applies existing New Zealand privacy principles rather than creating a separate regime for the technology.

Our take

This is a useful reminder that adding AI to an everyday device does not remove existing privacy obligations. In practice, the combination of wearable cameras, facial or object recognition and generative AI can make information collection much less obvious to the people affected.

New Zealand organisations considering smart glasses for field work, inspections, healthcare or other operational uses should treat them as information-collection systems, not simply wearable hardware. Privacy impact assessments, clear purpose limitations and controls over what gets uploaded to AI services should come first.

Sources

About the author

Campbell McKenzie is a Director at Incident Response Solutions, a New Zealand firm experienced in cyber incident response, digital forensics, investigations and technology risk. Through KiwiGen.AI, Campbell helps professional services firms adopt generative AI safely, with practical governance and controls.