Fragment – Product Privacy Labelling For Electronic Devices

Many consumer items have specific labelling requirements associated with them: children’s products, food, tobacco products, for example.

Manufactured products, including but in now way limited to toys, electrical products nad telecommunications equipment, also need to be safe (Product safety for manufacturers).

The labels typically identify things that can cause harm or act as a way to allow the consumer to manage risk. Labels may also be used to try to regulate a means of production through the market (e..g certification schemes, “free range eggs”, etc).

So do our new electronic devices also need to labelled with the environmental sensors they incorporate based on the potential for privacy breaking harms?

This post is a stub for examples where such sensors have not been clearly identified (please let me know via the comments if you come across further examples):

• Nest Secure had a secret microphone, can now be a Google Assistant

So what sensors should be identified?

• cameras
• microphones

Obviously…

Location sensing would be harder to label, because this may be done by the device itself (eg GPS), with help from other services (eg looking up location by cell tower or wifi hotspot localisation), or identified from your device by a remote service (eg IP address based localisation).

So maybe radios should also be clearly identified on the label (i.e. any wireless means by which a device can connect to a communications network). (Radios already have to comply with regulations around electromagnetic interference.)

Is this something the Lords Communications Committee, perhaps, or the Commons Science and Technology Committee has looked at, perhaps?

Tangentially related: Surveillance Camera Commissioner Guidance on the use of domestic CCTV on the one hand, and domestic video surveillance on the other.

Another thought: what starts out as spyware, eg USB cable with hidden microphone may also end up being commoditised as security devices: light bulbs with cameras/microphones for example; then just everyday: of course your music speaker needs to have a microphone in it, and your telly must have a microphone AND a camera, because, well, obvs…

PS  an example UK privacy opinions survey.

PPS internet harms, eg fake news? House of Commons Digital, Culture, Media and Sport Committee — Disinformation and ‘fake news’: Final Report