On January 27, 2015 the Federal Trade Commission (the “FTC”) issued a report detailing best practices and recommendations that businesses engaged in the Internet of Things (“IoT”) can follow to protect consumer privacy and security. The IoT refers to the connection of everyday objects to the Internet and the transmission of data between those devices. According to Gartner estimates the IoT services spending will reach $69.5 billion in 2015. The potential benefits of IoT growth include enhanced healthcare through connected medical devices, convenience and cost savings through home automation and improved safety and convenience through connected cars.

The Article 29 Working Party, which is composed of representatives of DPA’s from every European country, has recently rendered an opinion (http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2014/wp223_en.pdf ) on data privacy issues surrounding the development of the “Internet of Things” (IoT), which includes wearable computing, quantified self devices, and domotics. Although such data is generated by “things” or devices, it is considered personal data because it may enable the life pattern of a specific individual to be discerned. After identifying the major privacy issues raised by such devices, the Article 29 Working Party made a series of recommendations to IoT stakeholders.