Meta is building facial recognition into its Ray-Ban smart glasses. The feature, internally called “Name Tag,” would let wearers identify people in their field of view and pull up information about them through Meta’s AI assistant. They’re also developing “super sensing” capabilities that would run cameras and AI continuously for hours, keeping a rolling record of the wearer’s day.
From a product design perspective, this sounds like ambient computing’s logical next step. From a legal perspective, it’s a structural impossibility that reveals fundamental flaws in how we approach privacy in wearable technology.
- The Compliance Paradox
- Why Technical Solutions Fail
- The Actual Knowledge Problem
- Where Design Responsibility Actually Lies
- The Super Sensing Amplification
- The Timing Question
- What Responsible Design Would Actually Look Like
- The Precedent Problem
- The Mixed Audience Trap
- Beyond Compliance Theater
- The Design Question We’re Not Asking
The Compliance Paradox
In January 2025, the FTC finalized sweeping updates to the Children’s Online Privacy Protection Act. The amended rule expanded the definition of “personal information” to explicitly include biometric identifiers: fingerprints, retina patterns, voiceprints, gait patterns, and facial templates. Facial geometry is now unambiguously classified as biometric data. A face scan is personal information. Collection from children under 13 requires verifiable parental consent.
To determine whether COPPA applies to a particular face, the system must first process that face. However, processing the face involves collecting biometric data, which creates a paradox.
Now imagine someone wearing Meta’s Name Tag-enabled glasses walking through a playground. The camera captures every face in its field of view. The AI processes those faces against Meta’s social graph. For every face it processes, it collects facial geometry. For every match it finds, it pulls profile information. Some of those faces belong to children.
Here’s where responsible design confronts an impossible problem: to determine whether COPPA applies to a particular face, the system must first process that face. But processing the face means collecting biometric data. If the face belongs to a child, the collection has already violated COPPA. The device must break the law to determine whether it’s breaking the law.
Why Technical Solutions Fail
Every proposed workaround collapses under scrutiny. Edge processing—running facial recognition locally on the glasses rather than in the cloud—doesn’t solve anything. COPPA regulates the operator who provides the collection mechanism, not the server location. Meta’s models, Meta’s social graph, Meta’s liability. The geography of computation is irrelevant to the geography of obligation.
This is not a design challenge that better UX can solve. It’s a structural incompatibility between ambient facial recognition and children’s privacy law.
What about age estimation as a gatekeeping step? Process faces just enough to determine if someone appears under 13, then only run full identification on adults. This fails immediately. Age estimation from facial features requires extracting a facial template, which is itself a biometric identifier under the amended rule. The gatekeeper is the gate. Every technical solution requires performing the exact collection it’s designed to prevent.
This is not a design challenge that better UX can solve. It’s a structural incompatibility between ambient facial recognition and children’s privacy law.
The Actual Knowledge Problem
Meta will argue they lack “actual knowledge” of a child’s presence until after the scan cross-references with their database. But Meta owns the database. They built the social graph. They control both sides of the transaction. The microsecond the system matches a face to an Instagram account belonging to a 12-year-old, Meta possesses the biometric data and the knowledge that it belongs to a child simultaneously. There is no temporal gap to hide in.
Meta will argue they lack “actual knowledge” of a child’s presence until after the scan cross-references with their database. But Meta owns the database. They built the social graph. They control both sides of the transaction.
And Meta already has actual knowledge that children use their platforms. Despite minimum age requirements of 13, studies consistently show that roughly 38 percent of children aged 8 to 12 use social media. Meta settled with the FTC over children’s privacy on Instagram in 2023 for 1.4 billion dollars. They know children are in their ecosystem. They know children exist in public spaces where their glasses operate. This knowledge cannot be compartmentalized away through clever information architecture.
Where Design Responsibility Actually Lies
The Ray-Ban glasses already shipped with inadequate privacy indicators—a small LED light that reviewers consistently describe as too subtle to notice in daylight. This represents the first design failure: prioritizing device aesthetics over bystander consent. When Harvard students demonstrated how easily these glasses could enable real-time facial recognition and personal information lookup just by looking at strangers, the response should have been an immediate design overhaul.
Instead, Meta updated their privacy policy in April 2025 to enable AI features by default and expand their rights to store and analyze photos, videos, and voice recordings for training data. Users photographing family members may unknowingly contribute those faces to AI training datasets. This is the opposite of responsible design.
When Harvard students demonstrated how easily these glasses could enable real-time facial recognition and personal information lookup just by looking at strangers, the response should have been an immediate design overhaul.
Responsible design in ambient computing requires accepting that some theoretically possible features should remain unbuilt. Name Tag is such a feature. No amount of consent architecture, privacy indicators, or parental controls can reconcile continuous facial recognition with COPPA compliance when the collection happens to bystanders.
The Super Sensing Amplification
Standard camera operation at least requires the wearer to activate recording. Super sensing mode means collection never stops. Every child who passes within range of someone wearing these glasses has their facial geometry processed without their knowledge, without their parents’ knowledge, and without any mechanism for consent.
This transforms public space into an involuntary biometric collection zone. The power asymmetry is profound: an adult wearing recording glasses holds power over every person in their field of view. That power becomes particularly concerning when directed at children who cannot meaningfully consent.
Every child who passes within range of someone wearing these glasses has their facial geometry processed without their knowledge, without their parents’ knowledge, and without any mechanism for consent.
From a design ethics standpoint, continuous sensing represents an abandonment of the principle that users should control when data collection occurs. It shifts the default from “off until activated” to “always on unless disabled.” This inversion matters. Defaults shape behavior at scale. When surveillance is the default, surveillance becomes the norm.
The Timing Question
Internal documents obtained by the New York Times reveal Meta’s strategy for managing backlash. The company planned to launch Name Tag during “a dynamic political environment where many civil society groups that we would expect to attack us would have their resources focused on other concerns.”
The document doesn’t discuss how to address concerns through design. It discusses when to launch while those concerns receive less attention.
This is not a compliance plan. This is not a risk mitigation strategy. This is a calculated decision about when to deploy a product the company expects will generate opposition from privacy advocates. The document doesn’t discuss how to address concerns through design. It discusses when to launch while those concerns receive less attention.
Responsible design involves stakeholder engagement before launch, not strategic timing to avoid stakeholder attention. When your go-to-market strategy depends on advocates being distracted, you’re not building a product that serves user needs—you’re deploying one that serves company interests at user expense.
What Responsible Design Would Actually Look Like
If we take children’s privacy seriously, ambient facial recognition in consumer devices cannot exist in its current conception. But that doesn’t mean smart glasses have no legitimate future. Responsible design would involve:
Explicit mode switching: Recording and AI features should require deliberate activation that produces unmissable visual and audio indicators to bystanders. Not a subtle LED—something that makes recording status obvious from ten feet away in direct sunlight.
Local processing without identification: Assistive features like reading text, identifying objects, or navigating spaces can run on-device without matching faces to identities. The glasses can describe “a person wearing a red jacket” without determining whose face that is.
Zero retention architecture: Systems designed so that processed information never persists. The AI describes what it sees in the moment, then forgets completely. No cloud storage, no training data contribution, no social graph matching.
Functional limitations by design: Accept that some features—like facial recognition against social media databases—are incompatible with operating in public spaces where children are present. Design constraints aren’t limitations. They’re choices about what kind of future we’re building.
The Precedent Problem
Meta already settled for 650 million dollars under Illinois’s Biometric Information Privacy Act for collecting facial templates without consent through Facebook. BIPA provides a private right of action, meaning individuals can sue directly. Meta is now building a product that would repeat the same violation, on the same biometric data, in the same state, on an entirely new device category.
From a design history perspective, this pattern matters. It suggests that massive settlements are treated as a cost of doing business rather than a signal to fundamentally rethink product direction. When legal penalties don’t change design practices, the penalties are too small or the practices are too profitable.
The Mixed Audience Trap
Meta will point to their Family Center and existing parental controls. These tools govern screen-based interactions where a parent can configure settings before a child uses an app. They have no mechanism for a bystander child whose face is scanned by a stranger’s glasses in a grocery store.
This is the mixed audience trap that plagues ambient computing. Unlike websites that can gate access with age verification screens, wearable devices capture everyone in their field of view. The design challenge isn’t building better parental controls. It’s acknowledging that parental controls cannot solve involuntary data collection from non-users.
Responsible design for mixed audience environments means assuming the most vulnerable person is always present and designing protections accordingly.
Responsible design for mixed audience environments means assuming the most vulnerable person is always present and designing protections accordingly. If your product cannot operate safely around children, it cannot operate in public space. Public space is where children exist.
Beyond Compliance Theater
The April 2026 COPPA compliance deadline is approaching. Meta faces a choice: fundamentally redesign Name Tag and super sensing to eliminate biometric collection from bystanders, or launch features that federal law prohibits and dare regulators to act.
Based on the internal documents about strategic timing, the latter seems more likely. This reduces privacy protection to enforcement theater—companies build whatever they want, regulators react after harm occurs, settlements get paid, and the cycle repeats.
Responsible design breaks this cycle by treating legal requirements as minimum thresholds, not maximum constraints.
Responsible design breaks this cycle by treating legal requirements as minimum thresholds, not maximum constraints. It means involving privacy experts, child development specialists, and civil liberties advocates in product design from conception, not during damage control. It means building products that distribute power more equitably rather than concentrate it in device owners and the platforms they feed.
The Design Question We’re Not Asking
The smart glasses conversation focuses on how to build ambient facial recognition responsibly. We should be asking whether to build it at all. Not every technically possible feature serves human flourishing. Not every market opportunity should be pursued. Some innovations create more harm than value, even when executed with the best privacy indicators and consent flows.
Name Tag fails this test. The benefit—remembering names at social gatherings, perhaps—does not justify transforming every public space into an involuntary biometric collection system. The harm scales infinitely while the benefit remains marginal.
Responsible design requires accepting that children’s right to exist in public without being catalogued in corporate databases is more important than Meta’s ambition to identify every face on earth.
Responsible design requires the courage to say no to features that serve company growth at the expense of human dignity. It requires accepting that children’s right to exist in public without being catalogued in corporate databases is more important than Meta’s ambition to identify every face on earth.
The glasses that can’t legally look at your kids are already on shelves. The facial recognition feature that makes them even less capable of COPPA compliance is being developed right now. And the design question remains unanswered: not how to build this responsibly, but whether we should build it at all.
