A Draft Policy For Schools Specific to Smart Glasses, Wearable Recording Devices and AI Enabled Wearable Technology
- The White Hatter
- 1 day ago
- 14 min read
Caveat - This article and the accompanying policy template are being made freely available for schools and school districts to use, adapt, reproduce, and share under Creative Commons. There is no cost or permission required to use these materials for educational purposes. Our goal is simply to provide schools with a practical starting point that they can modify to reflect their own administrative procedures, policies, provincial legislation, and local needs based our subject matter expertise.
Based on several of our recent articles examining smart glasses and their growing presence in schools (1)(2)(3), we have had a number of teachers and school administrators reach out to ask what we believe a reasonable and balanced school policy addressing this technology might look like.
Given that we are based in British Columbia, we developed the following policy template primarily through a B.C. legal and educational lens. In B.C. public schools, the Freedom of Information and Protection of Privacy Act (FIPPA) governs how schools collect, use, disclose, and safeguard personal information, while the Criminal Code of Canada addresses potentially criminal conduct such as voyeurism, the non-consensual distribution of intimate images, and child sexual abuse and exploitation material.
Although this draft policy/ administrative procedure template was developed with B.C. schools in mind, many of the underlying principles surrounding privacy, consent, accessibility, appropriate use, safeguarding, and responsible technology use can be adapted by schools and districts elsewhere in Canada. Provincial and Territory privacy, education, human rights, and school legislation can differ, however, so any school or district considering adopting or adapting this template should have it reviewed within its own provincial legal and policy framework.
We also attempted to create a document that was forward looking considering technology is quickly changing.
DRAFT POLICY/ DRAFT ADMINISTRATIVE PROCEDURE
Smart Glasses, Wearable Recording Devices and AI Enabled Wearable Technology Policy
1. Purpose and Guiding Principles
Rapid developments in consumer technology have placed cameras, microphones, wireless connectivity, artificial intelligence, and cloud based processing into devices that can look almost indistinguishable from ordinary eyewear, watches, earbuds, pendants, body worn cameras, and other everyday accessories.
Unlike a conventional smartphone, some wearable devices can capture photographs, video, audio, or other information from a first person perspective without it being readily apparent to people nearby that recording or data processing is taking place. Some devices may also transmit information to third party servers where artificial intelligence can analyze images, recognize objects, transcribe conversations, translate speech, identify text, generate descriptions, or perform other automated functions.
The School recognizes that these technologies can provide legitimate educational and accessibility benefits. In particular, AI enabled smart glasses and similar technologies may assist students who are blind or visually impaired, students with disabilities, or students requiring other accommodations.
At the same time, covert or inappropriate recording can interfere with privacy, dignity, safety, academic integrity, and the school’s responsibility to maintain a safe and respectful learning environment.
Information captured through wearable devices may also be copied, uploaded, analyzed, manipulated, or combined with other publicly available information. Images, voices, and video may potentially be used for impersonation, harassment, synthetic media, voice cloning, sexualized deepfakes, or other harmful purposes.
The purpose of this policy is therefore not to prohibit technology simply because it is new. Its purpose is to establish reasonable boundaries governing when and how wearable recording and AI enabled technologies may be used on school property and during school activities.
This policy will be interpreted and applied consistently with applicable Canadian and British Columbia law, including the School Act, the Freedom of Information and Protection of Privacy Act where applicable, the Human Rights Code, the Criminal Code, applicable Ministerial Orders and school district policies, and the school’s obligations to accommodate students with disabilities.
Where this policy conflicts with applicable legislation, a lawful accommodation, a court order, or binding school district policy, those requirements prevail.
2. Policy Scope
This policy applies to students, employees, volunteers, parents and caregivers, contractors, guests, and other visitors while:
on school property;
participating in school sponsored activities;
attending school events where the school has supervisory responsibility;
participating in field trips or extracurricular activities; or
travelling on school provided or school arranged transportation.
The policy applies regardless of whether a device is personally owned, school owned, borrowed, or supplied by a third party.
3. Devices Covered
For the purposes of this policy, a wearable recording or AI enabled device means a device worn or carried on the body that is capable of one or more of the following:
taking photographs;
recording video;
recording or transmitting audio;
live streaming;
transmitting captured information to another device or online service;
using artificial intelligence to analyze images, voices, text, surroundings, or individuals;
performing facial, object, text, or environmental recognition;
generating transcripts, summaries, descriptions, translations, or other AI generated outputs from information captured around the wearer.
Examples may include smart glasses, camera glasses, AI glasses, body worn cameras, camera equipped watches, wearable cameras, AI enabled pendants, and similar technologies, and may include a cellphone.
The presence of an AI feature is not required for this policy to apply. A pair of glasses containing only a camera or microphone, for example, remains a wearable recording device for the purposes of this policy.
4. General Principle: Possession Is Different From Use
The School distinguishes between possessing a device and activating its recording, transmission, or AI processing functions.
Unless otherwise prohibited by school or district policy, mere possession of a wearable device will not automatically constitute misconduct.
Students and other members of the school community must not use a wearable device to photograph, record, livestream, transmit, analyze, or otherwise capture another person’s image, voice, activity, personal information, schoolwork, computer screen, conversation, or surroundings where doing so:
violates this policy or another school policy;
interferes with teaching or learning;
compromises academic integrity;
constitutes harassment, bullying, intimidation, or discrimination;
creates a safety concern;
infringes upon a reasonable expectation of privacy;
involves sexualized or intimate content;
circumvents school security or safeguarding procedures; or
is otherwise contrary to applicable law.
The fact that Canadian criminal law may permit a particular recording does not necessarily mean that the recording is permitted under school policy. Schools may establish reasonable rules governing conduct and technology use on its property or during school sponsored events, in order to maintain a safe, respectful, and effective learning environment.
5. Students
5.1 General Rule
Students may not activate or use smart glasses or other wearable or hand held recording devices to photograph, video record, audio record, livestream, transmit, or AI-process people or activities at school unless:
1.the use has been expressly authorized by a teacher or administrator for an educational purpose; or
2.the device forms part of an approved disability related accommodation or individualized learning support.
Where a student brings such a device to school without authorization to use it, recording, transmission, and AI processing functions must remain disabled during instructional time and in other circumstances where school or district personal digital device rules require the device not to be used.
Where reasonably necessary, the School may require the device to be securely stored in accordance with established school procedures.
5.2 Recording Teachers, Staff, or Other Students
Students must not use wearable or handheld technology to covertly record teachers, staff members, students, visitors, classroom discussions, meetings, presentations, assessments, or private conversations contrary to school policy.
The School recognizes that Canadian law relating to recording conversations is more nuanced than a simple requirement that everyone being recorded must consent. This policy therefore establishes a school conduct expectation rather than representing that every unauthorized recording is necessarily illegal.
Unauthorized recording may nevertheless result in school based consequences where it interferes with privacy, safety, respectful conduct, learning, or the operation of the school.
6. Accessibility and Disability Accommodation
Nothing in this policy is intended to prevent a student with a disability from receiving an accommodation to which they are entitled under applicable human rights law.
Smart glasses and other wearable technologies can provide important accessibility functions, including reading printed text aloud, recognizing objects, describing surroundings, assisting with navigation, identifying colours, translating text, providing captions, and supporting communication.
Accordingly, the School will not impose a blanket prohibition where doing so would improperly interfere with a student’s disability related needs.
Where wearable technology is required or proposed as an accommodation, the School should work collaboratively with the student, parent or caregiver where appropriate, relevant educational or accessibility professionals, administration, and the School or District Privacy Officer where necessary.
An accommodation plan should consider:
what functions are required by the student;
when and where the device needs to operate;
whether continuous recording is necessary;
whether photographs, video, or audio are stored;
whether information is transmitted to cloud based services;
what third parties receive or process information;
applicable privacy and security requirements;
whether less intrusive settings can provide the required accessibility function;
how other student’s and staff member’s privacy can reasonably be protected; and
how the accommodation can be implemented without stigmatizing the student.
An accommodation should be designed to meet the student’s legitimate accessibility needs while minimizing unnecessary collection, retention, transmission, or disclosure of information about others.
The mere presence of a camera or AI system within an accessibility device is not, by itself, sufficient reason to deny an otherwise reasonable accommodation.
7. Staff
Employees must not use personally owned wearable or handheld recording or AI enabled devices to record students or collect student information in the course of their duties unless the use has been authorized in accordance with school or district policy.
School approved wearable technology may be used for legitimate educational purposes, including vocational instruction, accessibility, demonstrations, research activities, media production, or other approved learning activities.
Before technology that records or processes identifiable student information is formally adopted for educational use, the School or District should determine whether appropriate privacy, security, procurement, and information management reviews are required.
Consideration should include:
what information the device collects;
why the information is necessary;
where information is processed and stored;
who has access to it;
how long information is retained;
whether information is used for advertising, profiling, analytics, or AI model training;
whether the provider can use captured information for its own purposes;
whether recordings can be deleted;
applicable contractual safeguards; and
whether a Privacy Impact Assessment or other privacy review is required.
Where recordings are created for legitimate educational purposes, they should be retained only for as long as required by applicable law, records management requirements, or the educational purpose for which they were collected.
8. Parents, Caregivers, Contractors, and Visitors
Parents, caregivers, contractors, volunteers, and visitors are expected to respect the privacy and dignity of students and staff while on school property.
The School may prohibit or restrict the use of wearable recording devices in classrooms, meetings, offices, counselling spaces, studentsupport areas, and other locations where recording could interfere with privacy, safety, confidentiality, learning, or school operations.
Visitors may be required to deactivate recording, live streaming, or AI processing functionality while in restricted areas.
A school administrator may direct a visitor to stop using or remove an operational wearable recording device where its use is inconsistent with this policy or reasonably creates a privacy, safety, safeguarding, or operational concern.
A person who refuses to comply with a reasonable direction may be required to leave school property in accordance with applicable school district procedures and legal authority.
This section does not prohibit ordinary photography or recording at public school performances, sporting events, ceremonies, or similar events where such activity is otherwise permitted by the School. Separate restrictions may nevertheless apply to the publication, distribution, or subsequent misuse of those recordings.
9. High Privacy and High Risk Locations
Wearable and handheld recording devices must not be used to photograph, video record, livestream, or otherwise visually capture individuals in locations where there is a heightened expectation of privacy.
These locations include:
washrooms;
toilet stalls;
changing rooms;
locker-room changing areas;
showers;
spaces being used for changing clothing;
medical examination or treatment areas where private care is being provided; and
other locations in which a person would reasonably expect a high degree of visual privacy.
Additional restrictions apply in:
1/ Counselling and Student Support Areas
Recording is prohibited unless specifically authorized for a legitimate professional, accessibility, or safeguarding purpose.
2/ Examinations and Assessments
Smart glasses and other wearable and handheld technologies capable of accessing, transmitting, recording, or generating information may be prohibited during examinations, tests, and assessments unless required under an approved accommodation.
3/ Staff and Administrative Meetings
Recording must comply with applicable school or district policies and any lawful accommodation requirements.
10. Artificial Intelligence, Deepfakes, and Manipulated Media
Students and other members of the school community must not use photographs, video, audio, biometric characteristics, or other information captured at school to create harmful or deceptive AI generated or digitally manipulated representations of another person.
Prohibited conduct includes using another person’s likeness, image, or voice for:
sexualized or intimate deepfakes;
so called “nudification”;
sexualized face swapping;
non-consensual synthetic intimate imagery;
malicious impersonation;
deceptive voice cloning;
fabricated recordings intended to portray a person as saying or doing something they did not say or do;
harassment, bullying, intimidation, extortion, or humiliation; or
other conduct prohibited by school policy or law.
The School will assess the conduct and resulting harm, rather than simply the technology used.
AI generated material should not automatically be characterized as a criminal offence. Depending upon its nature and circumstances, however, synthetic or manipulated material may engage provisions of the Criminal Code or other applicable legislation and may warrant referral to law enforcement.
11. Sexualized Images, Voyeurism, and Child Sexual Abuse and Exploitation Material
The School treats any suspected creation, possession, distribution, or threatened distribution of sexualized imagery involving students or staff as a serious safeguarding matter.
Particular care must be taken where technology has been used to:
surreptitiously record a person in circumstances involving a reasonable expectation of privacy;
record a person who is nude or engaged in sexual activity;
create or distribute intimate images without consent;
create sexualized AI generated representations depicting a person who is or appears to be under 18; or
possess, access, distribute, or make available material that may constitute child sexual abuse and exploitation material under Canadian law.
Where there are reasonable grounds to believe that material may constitute evidence of a criminal offence, staff should not unnecessarily view, copy, forward, download, screenshot, or distribute the material.
The matter must instead be handled under the School’s safeguarding, critical incident, and law enforcement referral procedures.
12. Response to Suspected Violations
Where a staff member reasonably believes that a wearable device has been used contrary to this policy, the immediate priority is to stop any ongoing recording or transmission and protect students and staff from further harm.
Depending upon the circumstances, staff may:
1.direct the person to stop recording or deactivate the device;
2. separate the device from continued use in accordance with existing school or district policy;
3. notify school administration;
4. document what was observed or reported;
5. preserve relevant information already lawfully available to the School;
6. contact the School or District Privacy Officer where a privacy incident may have occurred;
7. follow safeguarding or child protection procedures where appropriate; and
8. contact law enforcement where there are reasonable grounds to believe a criminal offence may have occurred or where immediate safety concerns exist.
School employees should not conduct forensic searches of personal devices, attempt to defeat passwords, access private cloud accounts, or manipulate suspected evidence unless specifically authorized by law and applicable school or district procedures.
Where potential criminal evidence is involved, administrators should consider obtaining direction from law enforcement before accessing, deleting, resetting, searching, or otherwise manipulating the device.
13. Temporary Possession of a Device
Where existing school or district policy authorizes staff to temporarily take possession of a student’s device, the device should be:
handled only to the extent reasonably necessary;
securely stored;
documented where appropriate; and
returned in accordance with established school procedures unless another lawful process requires otherwise.
Staff should not promise that information on a device can be preserved, and staff should not attempt to electronically isolate, disable, unlock, search, or forensically preserve a device unless authorized under applicable procedures and law.
Nothing in this policy authorizes a search that would otherwise be unlawful.
14. Privacy Incidents Involving School Controlled Information
Where wearable or handheld technology used by the School, an employee, contractor, or service provider results in the unauthorized collection, use, disclosure, loss, or exposure of personal information under the School’s custody or control, the incident must be reported promptly to the appropriate administrator and School or District Privacy Officer.
The School will respond in accordance with applicable privacy legislation, district privacy breach procedures, contractual obligations, and any notification requirements.
Where an AI or cloud provider is involved, the School should determine what information was transmitted, where it was transmitted, whether it was retained, whether it was accessible to third parties, and what steps are available to contain or delete the information.
15. Progressive and Proportionate Response
A violation of this policy will not automatically result in police involvement.
School responses should be proportionate to the student’s age, maturity, circumstances, intent, previous conduct, nature of the recording, degree of harm, and any disability or other relevant individual circumstances.
Responses may include:
education and restorative intervention;
temporary loss of device privileges;
parent or caregiver involvement;
administrative consequences consistent with the school’s code of conduct;
safeguarding intervention;
privacy breach procedures;
threat or risk assessment where appropriate; and
referral to law enforcement or child protection authorities where circumstances reasonably warrant such involvement.
A student who inadvertently activates a device should not ordinarily be treated in the same manner as a student who deliberately records another person in a washroom or uses captured imagery to create sexualized synthetic content.
The objective of enforcement is safety, accountability, education, privacy protection, and prevention of further harm.
16. Education and Awareness
The School recognizes that a policy alone is insufficient.
Students, employees, and families should receive age appropriate information explaining:
when recording is and is not permitted at school;
why wearable cameras create different privacy considerations from conventional devices;
the difference between Canadian recording law and school rules;
consent and reasonable expectations of privacy;
appropriate use of AI;
risks associated with uploading another person’s image or voice to AI platforms;
deepfakes and synthetic media;
academic integrity;
accessibility and disability accommodation; and
consequences associated with misuse.
Students should understand not merely that a rule exists, but why the rule exists.
17. Review
Because wearable computing and artificial intelligence are developing rapidly, this policy will be reviewed at least annually and whenever significant changes occur in:
applicable federal or provincial legislation;
Ministry of Education and Child Care requirements;
school district policies;
privacy guidance;
accessibility requirements;
consumer wearable technology; or
artificial intelligence capabilities.
The School will seek to maintain a policy that protects privacy and safety without unnecessarily restricting legitimate educational, accessibility, and assistive uses of emerging technology.
Policy principle:
The issue is not simply whether technology contains a camera, microphone, or artificial intelligence. The issue is how, where, why, and by whom that technology is being used, what information it collects about others, and what happens to that information after it is captured.
We also believe that having clear, visible signage that reflects and reinforces the policy is an important part of putting the policy into practice. A policy buried on a school or district website is of limited value if students, parents, caregivers, staff, contractors, and visitors are unaware that it exists.
Signage placed at public entrances provides notice before someone enters the school that smart glasses, wearable cameras, and other recording technologies are subject to specific rules while on school property. Additional signs placed strategically throughout the school, particularly near classrooms, counselling areas, change rooms, gym facilities, administrative offices, and other higher privacy locations, can provide an ongoing visual reminder of those expectations.
This is particularly important with smart glasses because, unlike pulling out a phone to take a photograph or record a video, the act of recording may not be obvious to those nearby. Clear signage helps remove ambiguity by communicating that the school has established expectations surrounding wearable recording technology, regardless of how discreet the device may be.
Signage should not replace education about the policy, and it should not attempt to reproduce the entire policy on a wall, its purpose is much simpler, that being notice, awareness, and reinforcement. People should be able to look at the sign and immediately understand that they are entering a space where privacy is taken seriously and where the use of wearable recording technology is regulated.
We would therefore recommend placing signage at all primary public entrances to the school, with additional signs positioned in appropriate locations throughout the building. The wording and imagery should be simple, highly visible, and consistent with the language used in the school’s actual policy.
Here is an example of a design we created, based on several that we saw online, to accompany the policy template above. It is intentionally uncomplicated so that its message can be understood at a glance rather than requiring someone to stop and read several paragraphs of policy language.
Please consider sharing this article with the schools, administrators, principals, educators, and district leaders in your community. The more schools that begin having informed conversations about smart glasses, wearable recording devices, privacy, accessibility, and AI enabled technology before these devices become a significant issue, the better prepared they will be to respond when they inevitably appear in classrooms and on school property.
Having a policy in place before an incident occurs is far better than trying to develop one in response to a privacy breach, inappropriate recording, accessibility dispute, or other unexpected situation.
Digital Food For Thought
The White Hatter
Facts Not Fear, Facts Not Emotions, Enlighten Not Frighten, Know Tech Not No Tech
Post Script:
If your school or school district is also looking for multi award winning social media safety, digital literacy, and AI literacy presentations and programs for students, parents, caregivers, educators, or professional development, we invite you to learn more about The White Hatter at www.thewhitehatter.ca. Our programs are continually updated to reflect emerging technology, current evidence based research, evolving online trends, and the real world experiences of the students, families, educators, and professionals we work with across Canada.
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