The trigger is already on the list

Among the circumstances that oblige a controller to run a data protection impact assessment, the IAPP's summary of what triggers a DPIA under the GDPR includes the large-scale monitoring of public areas. Read plainly, several million camera glasses moving through streets, transit and shops is a close fit.

Read as a compliance professional would, it collapses immediately. An assessment is performed by a controller who determines purposes and means. Ask who that is for a pair of consumer glasses and you get three unsatisfying answers. The manufacturer builds the thing and sets what it can do, but does not choose when it points at anyone. The wearer chooses that and determines almost nothing else. The cloud provider processes and often has no relationship with the person in the frame.

The household exemption is carrying the whole category

What keeps the question theoretical is the assumption that a person wearing glasses is engaged in a purely personal activity, which puts them outside the framework entirely.

That assumption is weaker than it looks. In Ryneš, the Court of Justice held that a home security camera covering a public footpath was not purely personal, and a fixed camera on a wall is a much narrower intrusion than a moving one that crosses a city over the course of a day. We have not seen a serious argument for why the wearable case should come out the other way, and the industry has not had to make one, because nobody has forced the question.

Assess the fleet, not the unit

Our position is that manufacturers should publish an assessment covering the deployed fleet, treating aggregate collection as the processing operation it plainly is, rather than pushing responsibility onto individual buyers who cannot perform it.

The obstacle is structural and worth naming rather than glossing. No regime currently attaches controller obligations to a manufacturer for what a distributed population of consumer devices collects. Until one does, the trigger stays on the list, the assessment stays unwritten, and the practitioners best equipped to evaluate this have no client with standing to instruct them.