The camera belongs to a visitor

Consider where your organisation meets the public. A reception area, a retail floor, a clinic waiting room, a service counter, a conference session, a branch queue. In every one of those, people who are not employees stand around wearing whatever they own.

The organisation is not the controller of anything a customer's glasses capture. It did not procure the device, cannot configure it and has no lawful basis to assert over it. It is also the party whose patients, clients and other visitors are in the frame, and the party that will be asked to explain itself when a recording made in its waiting room turns up somewhere unpleasant. CPO Magazine has covered the underlying tension in how biometric technology outpaced the frameworks built to govern it, and the gap has widened since.

Register the space, not the processing

Our position is that this belongs in the visitor conduct policy and the physical security brief rather than in the data protection register, because the register holds what you control and this is not that. Signage at entry, a stated rule for the areas where it matters most, and a line in the staff brief covering what to do when it comes up.

Choose the areas deliberately. A lobby is not a changing room and a trading floor is not a waiting room, and a blanket rule across all of them will be ignored in the places it is least needed, which teaches everyone to ignore it in the places it is most needed.

The part that lands on the front desk

Enforcement means somebody asks a customer about their eyewear. That person will be a receptionist, a nurse, a security guard or a retail associate, usually the lowest-paid person present, and the conversation is a confrontation about a device that looks like ordinary glasses and may be prescription.

We have not seen an organisation that trained for this properly, and writing the policy without writing the script is how a good rule becomes an incident. If you draft one this year, draft the script first and test it with the people who will have to say it out loud.