The scrutiny is attached to purchasing
Digital rights organisations have pushed hard on the technology schools buy, and EDRi's work on why edtech needs schooling sets out the case that children should not have to trade privacy for access to education. That campaign has produced guidance, complaints and in some jurisdictions binding decisions.
Every mechanism it relies on is triggered by a transaction. Someone signs a contract, a controller is identified, an assessment is required, a regulator has a target. Now consider a device that arrives on a face. Nobody purchased it, no contract exists, no vendor is accountable to the school, and the assessment process never activates because there is nothing to assess.
The people in the room cannot consent in any meaningful sense
A classroom is the clearest case of a space where the ordinary answer fails. Children cannot give the kind of consent this situation would require, a compulsory setting means nobody present chose to be there, and the adult wearing the device usually holds authority over everyone else in the room.
That combination does not appear in the guidance because the guidance was written for software. It also does not appear in most conduct policies, which were drafted when the relevant device was a phone and the relevant behaviour was visible.
Treat it as conduct, not as data protection
Our position is that school boards should handle this as a rule about behaviour on premises rather than waiting for a data protection framework to reach it. Conduct rules can be written this term by people already employed to write them. The other route requires a controller who does not exist.
The hard part is exemptions, and we have not seen anyone draft a good one. These are eyewear. Some wearers need prescription lenses, some use assistive features for hearing or low vision, and a blanket prohibition on smart eyewear collides directly with accommodation obligations. A rule that ignores that will either be unenforceable or discriminatory, and a rule that carves out assistive use has to define it well enough to survive contact with a determined parent. Nobody has published language that does both.