Response from Google to data protection authorities regarding Google Glass

Google Inc. has provided the following response to a joint letter from Privacy Commissioner of Canada Jennifer Stoddart and other provincial and international data protection authorities about Google Glass, the company’s Internet-connected glasses.

June 27, 2013

Google France SARL
38, avenue de l’Opéra
75002 Paris
France

Jennifer Stoddart,
Privacy Commissioner of Canada

Jacob Kohnstamm,
Chairman of the Article 29 Working Party, EU

Timothy Pilgrim,
Privacy Commissioner of Australia

Marie Shroff,
Privacy Commissioner, New Zealand

Alfonso Oñate Laborde,
Secretary for Data Protection, Mexico

Rivki Dvash,
Head of the Israeli Law, Information and Technology Authority

Hanspeter Thür,
Swiss Federal Data Protection and Information Commissioner

Jill Clayton,
Information and Privacy Commissioner of Alberta

Jean Chartier,
Commission d’accès a l’information du Québec

Elizabeth Denham,
Information and Privacy Commissioner of British Columbia

Dear Commissioners:

Thank you for your recent letter regarding Google Glass. Protecting the security and privacy of our users is one of our top priorities. We recognize that new technology is going to bring up new types of questions, so we have been thinking carefully about how we design Glass from its inception. Glass continues to be reviewed for privacy considerations as part of Google’s comprehensive privacy program, including designing Glass with privacy in mind and ensuring Google has appropriate consent from Glass users.

Although Glass is not yet in full consumer release and it is still early days for the product, we believe that first-hand experience with Glass will continue to help shape discussions in a positive direction for users and the public. That is why we launched the Google Glass Explorer program to our Explorers in the United States, which includes a diverse group of individuals participating in early field trials of the product. We are thinking carefully about their feedback as we consider next steps.

We’ve provided some information below about some of the features of Glass that should help further your understanding.

  • To begin, we have built Glass to put users in control of when and how to engage with Glass. For example, similar to mobile devices, Glass requires specific user actions to do things like search the Internet, find directions, or take a photo or video. Users say “OK, Glass” and then state commands like “Google” to search the Internet or “Get directions to” in order to chart a path to their destination. For photos and video, users press a button on the frame of Glass or say “Take a photo” or “Record a video.” This video provides a good introduction to some of the basic functionality of Glass: https://www.youtube.com/watch?v=4EvNxWhskf8.
  • Users will have access to their own “MyGlass” site (www.google.com/myglass) and MyGlass mobile application, which will give them a place to monitor the status of their Glass, manage settings, and decide which items or applications will display information on Glass.
  • Our commitment to putting users in control extends to the policies we’ve created for developers making applications for Glass, also called Glassware. For example, Google has said for several years that we won’t add facial recognition features to our products without having strong privacy protections in place. With that in mind, we won’t be approving any facial recognition Glassware at this time. We also prohibit developers from disabling or turning off the display when using the camera. The display must become active when taking a picture and stay active during a video recording as part of any Glassware.
  • While we ask participants in our Explorer program not to sell or transfer their Glass, users who someday transfer Glass to others will have options for removing their content from the device. Glass displays items like photos, videos, and text messages in a timeline, along with a “delete” option to remove them from that timeline. The “delete” function is one way to remove content from Glass. Also, the MyGlass site and app mentioned above will give users the ability to disable specific items (including Gmail, Google+, and Now) from Glass and to perform a factory reset, which will wipe all of their data from the device. Users who lose their Glass can likewise make use of these MyGlass site and app features.
  • We have also built some signals into the way Glass is used, with users and non-users in mind. In addition to Glass requiring spoken commands, users touch Glass to scroll through items or press a button on the arm to take a photo or record video — actions that also cause the Glass screen to activate, which is visible to others. These serve to both give Glass users means for employing etiquette in any given situation, and help people understand what Glass users are doing. As you know, some parties may in fact take their own measures to address the use of existing technology — such as cell phones, laptops or cameras — in certain circumstances. We expect these types of rules to continue to evolve as more wearable technologies come to market.

Please note that we are still actively working on Glass. The information provided here may change prior to our full consumer release of the product. As you know, in most of your countries, we have local and regional Google privacy, legal and policy experts, and they will serve as your points of liaison going forward.

Respectfully,

Original signed by

Peter Fleischer
Global Privacy Counsel

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