The ‘smart mirrors’ that are already on the market today can display news and traffic updates, play music, etc. The next generation of ‘smart mirrors’ currently being developed will contain many more applications that will challenge the industry, including in the food (supplements) sector, to radically reconsider the functionality of the mirror as a household item.

These ‘next generation’ mirrors will be using 3D scanners, cameras, face recognition technology and gas sensors. The face recognition technology will be able to measure anxiety and stress, monitor skin ageing, and detect vitamin deficiencies. Cameras will monitor heart rate and blood condition, gas sensors will detect alcohol or cigarette usage, and 3D scanners will identify weight gain or loss. A combination of all this data can then be used to compile big data statistics, to provide certain health/beauty tips, or even to send targeted advertising, e.g. for health or beauty products, for food supplements (based on skin condition), for alcoholic beverages (based on average alcohol consumption), or for certain types of food (based on weight gain or loss).

As ‘smart mirrors’ will be able to collect vast amounts of personal data, including “sensitive” data, particular attention will of course have to be paid to compliance with data protection laws.

For example, the processing of health data is only permitted in limited circumstances. Adequate safeguards should also be implemented in order to protect the security and integrity of such data, and due regard should be given to the liability risk that could arise from the provision of erroneous or imprecise information. As recent cases have shown, a data breach may not only trigger civil and criminal liability claims, but may also involve important reputational damage and negative publicity.

Adequate information should also be provided to the relevant users through general terms and conditions and an accessible and easily readable privacy policy. Additionally, when the use of the collected data is intended for personalised and targeted advertising based on data profiling techniques (discounts on food supplements, advertising for particular products), the prior express consent of the individuals concerned will be required.

All in all, if and when ‘smart mirrors’ will actually become available to consumers, the balance between technological innovation and legal compliance will undoubtedly – again – be a difficult one to strike.

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