The impact of the Internet of Things revolution continues to accelerate into our daily lives through the use of wearable devices such as sleep trackers, weight or pulse monitors and domotics (home automation) and with it comes the potential for the use of data collected through such devices.
The exponential growth of connected or ‘smart’ devices has increased the level of scrutiny of this area by data protection watchdogs. A recent Article 29 Working Party Opinion acknowledges the benefits that can be derived from such products by the end user and provides guidance to innovators and developers in this field. However, many questions remain around the vulnerability of such devices and the risks associated with data loss, infection by malware, unauthorised access, intrusive use of wearable devices or cybercrime related attacks.
Businesses that collect and share personal information gathered through wearable devices face a risk of increased data security related breaches. This means that risk-management should be a top priority for organisations that utilise the benefits of the IoT. Additionally, the compulsory obligations organisations will be under by virtue of the proposed new EU Data Protection Regulation, in relation to privacy by design, privacy impact assessments and increased sanctions for non compliance, will also have a significant impact in this area.
While the increased adoption of smart technology offers great opportunities for companies operating in this area, it is important that data protection issues are also considered. Organisations should ensure that a full privacy impact assessment is carried out at the earliest possible point of product or service development. This will help identify all risks associated with the smart device and ensure the appropriate controls to protect the business are implemented. The additional benefits to such an approach is that the device can be designed with privacy and data protection controls in place to ensure the individual remains in control of their personal information throughout the product lifecycle, thereby increasing customer satisfaction and experience.
Contributed by: David Cullen and John Farrell
