Set up by the government in 2018, the CDEI has a unique remit: to help the UK navigate the ethical challenges presented by AI and data-driven technology. We are led by an independent board of experts from across industry, civil society, academia and government. CDEI publications do not represent government policy or advice.
This week we’re continuing our introductory series by looking at the use of social distancing wearables for the workplace. As a reminder, this blog is not designed to be exhaustive, and is based on a rapid review rather than the results of an in-depth research project by the CDEI. Our intention is to introduce readers to some of the ethical questions and considerations our rapid review has identified. Social distancing wearables are devices that can be worn by a user (e.g. wristbands, watches) and alert wearers when they are in close proximity to another employee.
As the government continues to lift lockdown, some have claimed that individuals could be supported to safely return to work by encouraging the use of wearables that promote social distancing. Manufacturers of these devices say they could help people change their behaviour and therefore limit the spread of infections in the workforce, and, as part of a package of more traditional measures (e.g. PPE and room dividers), could allow some industries and organisations to return to relatively normal working arrangements.
In recent years, wearable technology has become ubiquitous with the invention of activity trackers, step counters and fitness watches. Some fitness trackers (e.g. Fitbit) have already released several updates aimed at helping their wearers lower their risk exposure to COVID-19. Wearables designed specifically for social distancing are a variant of this existing technology, although they present very different risks and benefits to those used for personal fitness.
Aside from potentially limiting the spread of COVID-19, it has been claimed that social distancing wearables could help employers understand whether the measures they have implemented are working, and therefore where and what to improve. They may also offer reassurance to workers, who could be more at ease knowing that they will be immediately notified if they are in close proximity to another worker, rather than always needing to remain vigilant.
However, there is limited evidence as to whether or not these devices significantly contribute to limiting the spread of COVID-19 - something that should be kept in mind as we look at their ethical implications. Data-driven technology could play an important role in mitigating the effects of COVID-19, but it is not a panacea. Depending on the type of workplace, these kinds of devices may add little value above employers offering simple guidance to their staff about maintaining distance from others, or putting physical markers on the floor.
Production and deployment
Wearables for social distancing are reportedly being trialled in multiple different industries and countries, and manufacturers seem to be working under the assumption that these kinds of wearables will become commonplace: several companies globally are already offering solutions. These have been in the form of both pivots of existing wearable technologies (e.g. Samsung have added social distancing management and monitoring features to their existing solutions), as well as novel wearables produced specifically for this application (e.g. British company Tharsus has designed an original system that will be available for commercial use from this month).
Despite this, there are several technical and ethical complications that could mean social distancing wearables provide zero benefit to some workplaces, or in fact cause harm.
Each type of wearable comes with its own technical limitations. There has been substantial coverage of the fact that Bluetooth, which powers some devices, may not be accurate at the kinds of distances required for this use-case. This is because objects - including humans - absorb and reflect the radio waves that make up Bluetooth. Environmental factors will therefore make a considerable difference to the efficacy of some social distancing wearables, suggesting they will not provide an advantage to more traditional measures. But alternatives to Bluetooth have their own issues. As one example, wearables based on other methods may be prohibitively expensive (prices can go above £100 per unit), excluding employers with smaller budgets. This poses a challenge for the likes of care homes, which may feel they have an ethical imperative to use the technology (assuming it works) but who cannot afford to do so.
Again, all of this must be framed with the caveat that there is limited evidence that wearables can assist with social distancing. Were the technology to work, however, a balance of trade-offs would still be required to ensure that there is an overall societal benefit from implementing them. As the latest ICO guidance on surveillance in the context of COVID-19 states: “employees have legitimate expectations [...] that they are entitled to a degree of privacy at work.” Weighing this against the potential benefits of wearables should be a fundamental part of the decision-making process for employers, as should considering any alternative methods that may be less obtrusive. Some manufacturers claim their devices do not log data in a central server, but instead connect to each other and log events on the devices themselves. This could help to preserve the privacy of workers, but such solutions may generate fewer insights and make it more difficult to know how well the system is working. At the other end of the scale, the solutions that provide the most insights may expose workers to high levels of surveillance and lead to the erosion of individual privacy.
There are also core issues of trust relating to the implementation of social distancing wearables: if the tools aren’t built in a way that allows employees to have a say, there will be limited engagement that may undermine their use, rendering them ineffectual. In a 2018 survey from the TUC/Britain Thinks, 67% of worker respondents said that wearable location trackers are “fairly or completely unacceptable”, demonstrating that employees are likely to be wary of any solution of this type. A sensible starting point would be to consult workers before implementing wearables, as well as conduct an impact assessment. If personal data is collected, employers should be transparent with their employees about what data is collected, how it will be used, and how long it will be kept (alongside meeting other obligations under the Data Protection Act). However, there is already concern - particularly from unions - about the level of employee consultation in low wage, low skilled sectors, and social distancing wearables will only add further to that conversation. Whether employees could ever feel comfortable enough to use the technology - i.e. rather than leaving it on their desk, or turned off - remains an open question.
It’s not yet clear how these ethical trade-offs will be managed given that these are solutions implemented by individual employers, of which there are thousands in the UK. Nor is it clear how comfortable employees may be with their employer’s choices.
Repurposing of social distancing wearables
Depending on the solution chosen there may be some opportunity for abuse, with employers able to repurpose the devices for other forms of worker surveillance. This could include monitoring which employees are meeting most regularly and where they’re spending their time. Even if a solution is chosen in which data is anonymised and not linked back to an employee’s name or contact information, the potential for these kinds of practices would not be eliminated, as blanket changes could be made based on the monitoring of wider workforce behaviour.
The potential for this kind of surveillance may lead to workers changing their behaviour more than is necessary - e.g. socialising less with colleagues - for fear of the ramifications, thus reducing their quality of life at work and potentially impacting on mental health.
Workplace surveillance technology has been increasing since well before the COVID-19 pandemic, and some of the wearable technology that is being repurposed for social distancing is part of a suite of solutions that allow employers to monitor their employees in different ways. In the same TUC/BritainThinks survey as above, 23% of employees surveyed said that wearable devices were very or fairly likely to already be used in their workplace. This suggests that social distancing wearables should be considered as part of a wider conversation around workplace surveillance, rather than as a standalone issue. As with any form of worker surveillance, there should be regular reviews of any social distancing monitoring in use to ensure that it is achieving the intended purpose.
In some professions where there are critical safety risks - such as mining and HGV haulage - this type of surveillance has the potential to improve conditions and save lives. But the benefits of workplace monitoring are less obvious for other professions, and employers should be clear about the purpose of any technology being implemented, so as to avoid creating infrastructure that can be used to heighten surveillance without taking full account of the impact on worker well-being.
For further reading on this issue please see:
- High visibility and COVID-19: returning to the post-lockdown workplace - Ada Lovelace Institute
- Monitoring at Work - WorkSmart
- Surveillance in the ‘data-driven’ workplace: is this the new norm? - CIPD