The Pulse
Hamburg regulator issues privacy checklist for AI glasses influencers
Hamburg’s privacy regulator has issued a checklist for influencers using first-generation Ray-Ban Meta AI Glasses. It advises informing people before filming and objecting to the use of data for AI training.
Influencers using first-generation Ray-Ban Meta AI Glasses have a new privacy checklist from Hamburg’s data protection regulator, which advises them to tell people before filming and object to the use of data for AI training. The Hamburg Commissioner for Data Protection and Freedom of Information says the steps are intended to help users comply with the General Data Protection Regulation (GDPR) and protect the rights of people being filmed.
The regulator announced the checklist on November 13, 2026. It follows an audit presented at the beginning of September that examined the first generation of the glasses.
Training and transparency
The regulator found that the glasses’ settings and their connection to the Meta AI app made compliance with data protection requirements difficult, though not impossible. Its checklist is aimed at influencers who use the glasses to record content.
The office says an objection to AI training is essential because, without one, it cannot be ruled out that other people’s personal data will be incorporated into the training of AI models. It also places advance notice and transparency at the center of its advice.
Recognizing a recording
In an earlier commentary, Hamburg data protection commissioner Thomas Fuchs said the glasses’ small white LED was the only feature indicating that a recording was in progress. The light is designed to be visible within a narrow field of vision, at short distances and in suitable lighting, he wrote, citing the office’s technical examination.
Those limits mean the indicator cannot ensure in many cases that people notice a recording, according to Fuchs. He also said that a person tolerating a visible recording should not, by itself, be taken as consent.
Legal basis for filming
In his commentary, Fuchs said users need a legal basis to record identifiable people outside their family or close circle of friends. He said consent was required apart from situations where an overriding legitimate interest could be assumed, such as self-defence or use by visually impaired people.
He also wrote that responsibility under data protection law lies with the people using the glasses. Separately, he said a ban could be possible for specific products if Germany’s Federal Network Agency shared the office’s view that the LED indicator was not sufficiently recognizable; that would not be a general ban on AI-glasses technology.