As wearable technology becomes more sophisticated, employers are facing a new workplace risk that many policies have yet to address … smart glasses. Devices such as Meta glasses allow users to take photographs, record conversations, livestream content and access AI-powered assistance, often with little visible indication that recording is taking place.

While the technology offers potential benefits, particularly around accessibility and productivity, it also raises significant concerns for employers around harassment, confidentiality, data protection and intellectual property among other considerations. For directors, HR professionals and managers, the key question is not whether these devices will enter the workplace, but how organisations can manage the risks they create.

Sexual Harassment risk

One of the most obvious concerns is the potential for employees to record colleagues without their knowledge. Unlike a mobile phone, smart glasses can capture images, video and audio discreetly during meetings, conversations and day-to-day interactions.

This creates a heightened risk of sexual harassment, particularly where recordings are used to focus on an individual’s appearance, shared inappropriately with others or used to humiliate or intimidate colleagues. Employers should be mindful that under the Equality Act 2010, sexual harassment occurs where there is unwanted conduct of a sexual nature that violates a person’s dignity or creates an offensive, hostile, degrading, humiliating or intimidating environment.

Since October 2024, employers have been under a positive duty to take reasonable steps to prevent sexual harassment at work. From 30 October this will extend to a duty on an employer to take ‘all reasonable steps’ to prevent sexual harassment in the workplace. The emergence of wearable recording technology means employers should now consider whether their existing risk assessments and policies adequately address these new forms of misconduct.

Harassment and workplace culture

The risks are not limited to sexual misconduct. Employees may use smart glasses to record colleagues, disagreements, workplace conversations or meetings and then use them for personal retention or to share footage with colleagues or on social media.

Even where a recording is not unlawful, employees who believe they are being watched or recorded by colleagues may feel uncomfortable, anxious, harassed or less willing to engage in open discussion. Over time, this can undermine trust and damage workplace culture.

A workplace where employees feel constantly observed is unlikely to be one in which people feel safe or confident in raising concerns, challenging decisions or contributing ideas.

Third-Party harassment

A further issue for employers is the risk of third-party harassment. From 30 October 2026, employers will face a new statutory obligation to take reasonable steps to prevent employees from being harassed by third parties, such as customers, clients, contractors, suppliers and visitors.

Smart glasses have the potential to increase this risk significantly. For example, a customer could record an employee without consent, make inappropriate comments while filming, or distribute footage online. Similarly, visitors could use wearable technology to target employees in ways that amount to sexual harassment.

The forthcoming changes reinforce the need for employers to consider not only employee use of smart glasses but also the use of such devices by people entering the workplace. Clear visitor policies and staff reporting procedures will become increasingly important.

Confidentiality, data protection and intellectual property

For many organisations, the greatest risk may be the ability of smart glasses to capture sensitive information without detection.

A confidential strategy meeting, HR investigation, client discussion or commercial negotiation can potentially be recorded and stored externally within seconds. Employees may also inadvertently capture personal data displayed on screens, confidential documents left on desks or conversations involving customers and colleagues.

Beyond data protection concerns, employers should also consider written confidential information and intellectual property risks. Product designs, business plans, software development, pricing strategies and trade secrets can all be recorded and retained long after an employee leaves the business.

For organisations operating in highly competitive sectors, a single unauthorised recording could have significant commercial consequences.

Monitoring employees in the workplace

Many employers will be tempted to introduce greater monitoring in response to these risks. However, workplace monitoring must remain lawful, necessary and proportionate.

In the UK, employers should be transparent about any monitoring activities and ensure employees understand what information may be collected, why it is being collected and how it will be used. Excessive or intrusive monitoring can create employee relations issues and may raise privacy concerns.

The better approach is often prevention rather than surveillance. Clear policies, training and communication are usually more effective than attempting to monitor every potential misuse of technology.

Disciplinary consequences

Misuse of smart glasses may justify disciplinary action, depending on the circumstances. Recording colleagues without permission, breaching workplace policies or sharing inappropriate content could all amount to misconduct.

More serious cases, such as covert recording, harassment, sexual harassment, disclosure of confidential information or misuse of personal data, may constitute gross misconduct and potentially justify dismissal following a fair investigation and disciplinary process.

Employers should avoid making assumptions and ensure that any action is taken in accordance with their policies and the ACAS Code of Practice.

Practical steps for employers

Employers should review whether existing policies adequately deal with wearable technology. Whilst many organisations have rules covering mobile phones, social media and recording meetings, few specifically address AI-enabled smart glasses.

A sensible starting point is to:

• Review, and where appropriate, update policies. This may include dignity at work, sexual harassment, confidentiality, data protection, disciplinary procedures and bring-your-own-device arrangements.
• Employers should also consider whether smart glasses should be restricted or prohibited in certain environments, particularly where confidential information, vulnerable individuals or sensitive commercial activities are involved.
• Consider any regulatory or compliance matters including safeguarding, contractual risks, legal requirements.
• Managers should be trained to recognise the risks and employees should be encouraged to report concerns at an early stage.

As with any workplace issue, prevention is far easier than dealing with the consequences after an incident has occurred.

Looking ahead

Smart glasses are likely to become as commonplace as smartphones over the next few years. Forward-thinking employers should therefore start considering the implications now. By reviewing policies, assessing risks and setting clear expectations, organisations can balance the benefits of new technology with the need to protect employees, maintain trust and safeguard confidential business information.

For HR professionals, directors and managers, wearable technology should now be firmly on the workplace risk agenda. ViewHR can support employers in reviewing and updating their policies, assessing workplace risks and providing practical guidance to managers on handling the use or misuse of wearable technology. Contact us for more information.