Smart Glasses and Covert Filming Devices

Policy

This policy outlines restrictions on the wearing or use of smart glasses and covert filming devices by students, staff, parents, carers, contractors, volunteers and other visitors on Victorian government school premises or at school-organised events and activities.

Summary

• Smart glasses and covert filming devices must not be worn or used on government school premises or at school-organised events or activities (offsite). This restriction applies to students, staff, parents, carers, contractors, volunteers and other visitors.
• Prohibited filming devices include smart glasses, wearable or clothing-integrated micro cameras and any other device that is a compact tool disguised as an everyday accessory to secretly record images or video.
• Any person who brings prohibited filming devices specified in this policy to a school must switch the device off and securely store it while they are onsite, or at offsite school-organised events or activities. If a person (other than a student) refuses to do that, the principal (or their delegate) may ask them to leave the school premises or the school-organised event or activity. For student refusal to comply, go to Implementing the ban.
• Exemptions to restrictions on the use of smart glasses may be granted only where their use is a reasonable adjustment for persons with disability (for example, vision impairment) and where the adjustment cannot be achieved through another device or approach.
• Where schools have entered into hire, licence or joint use arrangements with third party organisations or businesses for the use of school premises, including outside of school hours and on weekends, those organisations will need to be aware of the ban and manage any issues, including any requests for exemptions, related to smart glasses at the events or activities connected to their use of school facilities.
• Schools must share information about this policy and the restriction on the use of smart glasses and covert filming devices with their school communities, for example, by including a link to this page on their school website.

Details

Policy rationale

To maintain safe, respectful, secure and effective learning environments, smart glasses and covert filming devices must not be worn or used on school premises or at offsite school-organised events or activities.

All school community members have a shared responsibility to keep children safe. Smart glasses raise significant child safety, wellbeing, privacy, data security and student learning risks. They can film people and their surroundings without their knowledge or consent. It is often difficult to tell if someone is wearing smart glasses. Indicators that a camera is recording, such as a light, may be also disabled or covered.

Some smart glasses can live stream footage and can be tracked by other devices. The location of smart glasses and recordings made by them are likely to contain information about the time and location the recording was made. This may create personal safety risks for both students and staff.

Smart glasses and some covert filming devices can also connect users to AI assistants and other information and are at risk of being hacked, with the information they are capturing becoming available to hackers.

Banning the use of smart glasses and covert filming devices on school premises and at offsite school-organised events and activities supports compliance with Child Safe Standard 9: Keeping children safe in physical and online environments in schools.

With smart glasses designed to closely resemble ordinary eyewear, visibility relied upon in traditional physical child safety practice is compromised. While holding a mobile phone or camera provides a visible cue that filming may be occurring, smart glasses and other wearable covert filming devices remove this cue entirely. Restricting use of smart glasses on school premises and at school-organised events and activities reduces this risk.

Implementing the ban

Smart glasses or covert filming devices must not be worn or used by any person attending school premises or attending offsite school-organised events or activities (for example, camps, excursions, school concerts and sporting events). This includes students, staff, parents and carers, volunteers, contractors and any other visitors.

If any person is wearing or using smart glasses or a covert filming device in contravention of this policy, school staff must explain this policy to them and ask them to remove or securely store the device.

Schools must also:

• request that the person provide details of the period of time they have been wearing the smart glasses or covert filming device on school premises or the event/activity, and if recordings have occurred
• remind the person of the requirements of this policy, including the process for seeking an exemption for the use of smart glasses where that is a reasonable adjustment for a person with disability
• report the incident to the department’s Incident Support and Operations Centre (ISOC) if there are concerns about students or staff being recorded in a way that might compromise their privacy or safety.

If a student refuses to comply with an instruction to remove their smart glasses and securely store them, schools can apply behavioural consequences outlined in their existing Student Wellbeing and Engagement policies.

If a person (other than a student) refuses to remove and securely store their smart glasses as required by this policy, school staff may ask them to leave the school premises or the offsite school-organised event or activity.

Schools are not public places and a principal can require that visitors to school sites (including parents, carers, volunteers, contractors and others) comply with this policy. If a person refuses to leave the school grounds principals can refer to the Trespass policy to manage the situation.

Third party use of school premises

The ban applies on school premises at all times.

Where schools have entered into hire, licence or joint use arrangements with third party organisations or businesses for the use of school premises, those organisations will need to be aware of the ban and ensure that their staff, volunteers and others attending their events or activities are also aware.

Schools will not be required to enforce the ban outside of their own school operations and it will be up to the third party organisations and businesses using school premises to manage any issues, including any requests for exemptions, related to smart glasses at the events or activities connected to their use of school facilities.

For more information about third parties using school premises go to: Community Use of Schools – Hiring and Licensing.

Communication requirements

Schools must share information about this policy and the restriction on the use of smart glasses and covert filming devices with their school communities. It is recommended that information about this restriction be included:

• for students, parents and carers, volunteers, contractors and visitors: on the school’s website
• for staff: in staff handbook and induction materials.

Note that under Ministerial Order 1515 and the Mobile Phones and Personal Electronic Devices – Student Use policy, schools must have a local policy that sets out the restrictions on the use of smart glasses for students.

Template communications are available on the Resources tab.

Exemptions

For some people with disability, smart glasses can make a meaningful difference as an accessibility device.

Principals, including assistant and/or campus principals, may grant an exemption for students, staff or visitors to use smart glasses in limited circumstances.

An exemption to use smart glasses must only be issued where:

• it is for the purpose of providing a reasonable adjustment for a person with disability (for example, a vision impairment)
• the reasonable adjustment cannot be reasonably provided for by another device or approach
• the request is supported by evidence.

Before granting an exemption to students, staff or visitors, decision-makers must consider:

• their proposed use
• whether smart glasses are the only adjustment that can meet the person’s needs (for example, consider whether there is other assistive technology available)
• the risks associated with the proposed use of smart glasses, including child safety, privacy and data security risks
• what safeguards could be implemented to manage identified risks if an exemption is granted and whether those safeguards could adequately address the identified risks.

If an exemption is granted, principals must document, in writing, the permitted uses of the smart glasses and any conditions or restrictions on use, including the time period for which the exemption applies.

For more information on exemption considerations and for templates to support the process, refer to the Guidance tab and the Resources tab.

Definitions

Covert filming devices
A compact, wearable tool disguised as an everyday accessory to secretly record images or video data. May include smart glasses, wearable or clothing integrated micro cameras and any other device that is a compact, tool disguised as an everyday accessory to secretly record images or video data.

School organised events and activities
Any activity, program or event that is a school-led and organised activity or event, regardless of whether or not it takes place on or off school premises, during or outside the school day or school term. This may include camps and excursions, sporting events, performances, school-organised student social events (for example, school formals or discos), fetes and other school fundraising events, ceremonies, assemblies or school council or other school-run meetings.

Smart glasses
A device that is designed to be worn as spectacles and has the capability to send, receive, store, record or process digital information.

Related policies

• Child Safe Standards
• Community Use of Schools – Hiring and Licensing
• Managing and Reporting School Incidents (Including Emergencies)
• Mobile Phones and Personal Electronic Devices – Student Use
• Photographing, Filming and Recording Staff and Other Adults
• Photographing, Filming and Recording Students
• Privacy and Information Sharing
• Weapons and Other Harmful Items – Banning, Searching and Seizing

Relevant legislation

• Education Training and Reform Act 2006 (Vic)(opens in a new window)
• Surveillance Devices Act 1999 (Vic)(opens in a new window)