Consortium Smart Doorbells
The Smart Doorbell Consortium is committed to the responsible use of smart doorbells. It explores the needs and concerns of citizens and investigates both regulatory and design-based solutions to address privacy and security risks. The initiative also aims to establish an international consortium to create a comprehensive list of functional requirements for manufacturers to design safer products.
Smart doorbells are everywhere—just in the Netherlands, there are 1.2 million in use. Equipped with cameras and in some cases even able to record audio, smart doorbells are becoming increasingly sophisticated. These devices serve various purposes, such as managing package deliveries when you're not home and enhancing the sense of security.
However, alongside these benefits, concerns about privacy, surveillance, and legal implications are growing. The Smart Doorbell Consortium studies how people experience these devices to understand their needs and worries. It also evaluates necessary regulations and explores design solutions to make usage more transparent. Lastly, the consortium develops a wish list of new features to present to manufacturers to encourage safer and more efficient product designs.
Interested in contributing? Please contact Responsible Sensing Lab via rsl@ams-institute.org.
What are smart doorbells?
Smart doorbells are innovative devices with features such as two-way communication and image recognition. They can detect people—or even packages—and allow homeowners to see who is at the door via their smartphones.
A smart doorbell is, in essence, a doorbell and security camera combined. It allows the owner to be ever-present at their front door through their phone. Unlike traditional security cameras, smart doorbells notify owners about visitors and enable real-time communication via intercom systems.”
— Sofie-Amalie Torp Diedrikson, Designer, PhD student at the faculty of Industrial Design, TU Delft
According to the consumer television program Kassa, there are currently 1.2 million smart doorbells in the Netherlands (Multiscope survey, 5,000 panelists). The National Police has registered 55,000 smart doorbells (source: Tweakers, March 2023). To provide an illustration, the Data Visualization team at AMS Institute created the two images below, showcasing two areas in Amsterdam.
Why do people install smart doorbells?
A small-scale study by AMS Institute shows that people install smart doorbells for various reasons, such as remote door answering, managing deliveries, or enhancing a sense of safety. Interestingly, these devices can also lead to neighborhood conflicts and privacy concerns. For instance, residents have appreciated their neighbor's smart doorbells for identifying who scratched their car, but others feel uneasy about the surveillance.
Due to the rise of 'smart doorbells,' our society is at risk of turning into a world where everyone is constantly spying on each other. A solution to this problem requires collaboration for enforcement, regulation, and adaptation of technology. The 'Smart Doorbell Consortium' brings together the necessary knowledge, experience, and visions for this purpose.”
— Vincent Böhre, Director, Privacy First
Rising concerns about smart doorbells
Despite their convenience, smart doorbells raise significant concerns, particularly around privacy and surveillance due to cloud systems and potential data breaches. Key issues are:
- In-household privacy
- Intra-household privacy / privacy in communities
This concern is particularly relevant in settings where the front door of a home directly faces public space, especially in crowded urban or town environments. - Big-tech power concentration & surveillance
Most popular smart doorbells are connected to the cloud, leading to the uploading of metadata and video footage to the manufacturer. Popular brands store data in the cloud, often outside the EU, bypassing GDPR protections and risking sensitive information exposure. When purchased from vendors outside the EU, the liability lies with the buyer. - Police and government access
Some American State Police Departments access footage from smart doorbell vendors without user consent, raising serious privacy concerns. In the Netherlands, initiatives like the Camera in Beeld by the Dutch Police require permission to retrieve and use footage. However, a poll conducted by Dutch radio station BNR Nieuwsradio indicates smart doorbell owners are often forced to hand over their video footage to the police. Lawyers warn that this is how unsuspecting citizens get into criminal records. - Increased sense of insecurity
Marc Schuilenburg (Vrije University Amsterdam (VU)) suggests that while smart doorbells may lead to increased feelings of insecurity, they do not necessarily improve objective safety. Namely, people see everything that happens around their house and then discuss this in neighborhood WhatsApp groups. Their subjective sense of security decreases, while objectively it does not change. - Legal issues
Installing a doorbell containing a camera that points towards public space is illegal according to the General Data Protection Regulation (GDPR). In this article, De Volkskrant outlines the case of a neighbor who installs a camera above his window aimed at public parking lots due to car vandalism and theft. The other neighbor argues that his privacy is infringed upon because the camera operates at other times as well. Eventually, the court rules on this matter, ordering the removal of the camera due to privacy infringement. The court of appeal confirms this decision, stating that protecting one's property does not justify infringing on the privacy of others on public roads.
‘The Snitch Society’: A New Normal?
A new normal seems to be emerging as camera doorbells equipped with facial recognition become commonplace despite initial protests. The fear of crime often overrides concerns about privacy, leading to a normalization of surveillance practices. Privacy First, one of the partners in the Smart Doorbell Consortium, published an article highlighting the complexities and implications of mass surveillance technologies in society. Here's a summary of the key points:
- Storage and use of footage: All footage captured by smart doorbells is stored in the manufacturers' cloud systems. The question arises: what do manufacturers or authorities do with this data?
- Owner's obligation to inform: While camera owners are obligated to provide information, most cameras lack this sticker. If you've been recorded, the owner must share or delete the footage upon request.
- Privacy and security: The doorbells are susceptible to hacking, and police can requisition the footage, potentially implicating individuals in criminal cases.
- Privacy infringement: Systems like drones and smart doorbells can create a constant sense of surveillance, even when not actively recording.
- Physical shielding as a solution: ‘Shutterring’, a concept for physical covers on doorbell cameras developed by Responsible Sensing Lab, is proposed as a potential solution to privacy concerns, providing assurance to others that they are not being recorded.
- Data sovereignty as a long-term solution: Even if all camera doorbells have a 'shutterring', footage will still be stored in cloud systems. Therefore, the concept of data sovereignty suggests transferring all footage and data to a personal, secure environment controlled by the camera owner. Achieving data sovereignty and redefining the role of manufacturers requires an obligation on their part to facilitate this in a user-friendly manner.
To address these issues, enforcement, regulation, and technological adaptations are essential.
Why are current legal frameworks ineffective in terms of enforcement?
Existing legal frameworks, such as the GDPR, are not specifically tailored to address the challenges posed by smart doorbells. Moreover, enforcement by authorities like the Data Protection Authority is limited due to capacity constraints.
The GDPR is a legal framework aimed at protecting personal data and is not tailored for camera surveillance, such as smart doorbells. Whether the GDPR allows the use of smart doorbells depends on factors such as the purpose for which they are used, the availability of alternative methods to achieve that purpose, the camera's positioning (whether or not it captures public spaces), and other potential installation or mounting options.
In addition to the GDPR, Article 8 of the European Convention on Human Rights (ECHR) may also apply. Regarding enforcement, the AP is responsible for GDPR compliance in the Netherlands. However, the AP has limited capacity and a broad mandate to oversee and enforce regulations. The use of smart doorbells by private individuals is not high on their priority list. Despite their links to companies like Amazon and Google, households are legally responsible for data processing.
The AP is working on a risk-based approach and is unlikely to prioritize the regulation of smart doorbells in the near term. That said, the AP intervenes in specific cases and sends letters to those involved. Additionally, the AP has published some guidelines on its website.
Smart Doorbells Consortium goals
To effectively address the concerns mentioned above, Responsible Sensing Lab collaborates with cities, privacy advocates, academic researchers, and designers through the Smart Doorbell Consortium, focusing on three key goals:
- Conducting national research to understand citizens' experiences with smart doorbells.
- Exploring regulatory and practical design solutions to address concerns related to smart doorbells.
- Developing an international coalition to agree on a list of functional requirements for manufacturers.
1. Conducting national research to understand citizens' experiences with smart doorbells
The primary goal of the consortium is to gain insight into how people use smart doorbells and how they respond to them. For example, research conducted in Amsterdam (890 participants, 2023) revealed that 17% of respondents expressed objections to smart doorbells. To comprehensively understand public perceptions, it is crucial to investigate both the benefits and drawbacks of these devices.
For instance, has the perceived sense of security increased or decreased due to smart doorbells? Are there individuals who feel uncomfortable with cameras around them? Do they feel empowered to discuss this with their neighbors? Are people aware of potential hacks and the fact that recorded footage can fall out of their control? What are the latest legal and jurisprudential developments? Are there ongoing court cases related to this issue?
Additionally, special attention must be given to vulnerable groups such as delivery drivers, children, and cleaners.
To address privacy concerns within neighborhoods, the consortium plans to conduct surveys, focus groups, and design research, with a particular focus on urban areas where front doors face public spaces.
2. Exploring regulatory and practical design solutions to address concerns related to smart doorbells
The consortium aims to explore a range of solutions, both regulatory and non-regulatory, to address concerns related to smart doorbells:
- New local regulations: Given the limited enforcement of the GDPR, alternative regulations tailored to municipal contexts are necessary. Collaboration with the Dutch Association of Municipalities (VNG) and advice from the "Responsible Data Usage Advisory Function" (Pels Rijcken) are critical in this process.
- Design Solutions (non-regulatory): The consortium will investigate various design solutions, prioritizing them based on feasibility and impact. Examples include:
Neighborhood behaviour
Could installing a smart doorbell automatically include informing neighbors? Initiating this conversation can be uncomfortable, so simple slogans—similar to those used in safe driving or health campaigns—could facilitate discussions. A national campaign could play a crucial role in fostering these conversations.
Facilitating neighbourhood dialogue
When conflicts or communication issues arise between neighbors due to smart doorbells, municipal intervention may be necessary. For example, city initiatives could employ "neighborhood coordinators" familiar with the community's people and sentiments to act as mediators. Additionally, larger-scale Socratic discussion sessions could provide a platform for open dialogue, helping communities better understand the implications of smart doorbells and potential solutions.
City Talks
In instances where conflicts or communication breakdowns arise between neighbors due to smart doorbell installations, municipal intervention becomes necessary. For example, city-led initiatives, facilitated by ‘neighborhood directors’ (i.e. buurtregisseur) who have knowledge about the people and sentiments in the area, can serve as mediators. Additionally, organizing socratic discussion sessions on a larger scale can provide a platform for comprehensive community dialogue, fostering a deeper understanding of the implications of smart doorbells and potential solutions.
Best-practice in privacy settings
A campaign focused on properly configuring the privacy settings of smart doorbells could encourage responsible use. Highlighting available features on platforms like Eufy and Ring could motivate users to actively implement these protective measures.
It's not visible from the outside whether a privacy mode is active on a doorbell. Smart doorbell owners should proactively demonstrate the privacy settings to their neighbors. While this may not eliminate all privacy concerns, it could foster trust between neighbors.
Open communication about these settings can also act as a deterrent against misuse (e.g., unnecessary playback or storage of footage), provided users don't revert the settings after demonstrating them to neighbors.
Data Protection Impact Assessment (DPIA)
Every smart doorbell owner is responsible for sensitive personal data collected by their device. Due to the variety of smart doorbells available, a customized DPIA is necessary. By considering factors such as brand, model, connectivity, and storage options, each owner can tailor their DPIA to their privacy preferences and requirements.
Shutters and modifications
Developing and testing low-tech modifications, such as ‘Shutterrings’, to limit the field of view or adjust the timing of the doorbell sensor, could improve user privacy. These modular solutions, suitable for various smart doorbell designs, could be distributed through campaigns or made available for purchase, giving users greater control over their surveillance capabilities.
Dystopian designs
Creating prototypes of potential future designs or features that challenge conventional norms—and that most people would strongly oppose—can raise awareness. For instance, simulating systems that grant third-party access to footage (e.g., "juice channels") or enable tracking across multiple doorbells could draw attention to the risks of unchecked surveillance practices.
Consumer guidance
A dedicated website to help individuals select smart doorbells with minimal privacy implications could empower consumers to make informed choices. Offering guidance on features such as audio capabilities, storage options, and privacy settings can assist users in navigating the market landscape. For example, Bits of Freedom has launched a campaign to promote 'dumb doorbells' to highlight privacy issues. These are basic doorbells without the advanced features of smart doorbells.
Smart doorbells connect Dutch street images with tech giants like Amazon and Google. Ring is known for its privacy risks, such as storing deleted footage and collaborating with the government. The government should inform the public about these risks and consider local regulations to protect citizens from intrusions by smart doorbells.”
— Thijs Turèl, Cofounder Responsible Sensing Lab and Program Manager, Responsible Sensing Lab and AMS Institute
3. Developing an international coalition to agree on a list of functional requirements for manufacturers
Eventually, the design of smart doorbells will need to change, and this can only be achieved in collaboration with manufacturers. To bring about meaningful change, the consortium will work with other cities to draft a list of desired modifications to present to both manufacturers and regulatory bodies.
- Formulating guidelines or feature requests: inspired by successful models like Apple AirTags, the consortium will create clear guidelines and feature requests addressing aspects such as design, app functionality, data processing, and user privacy.
- Building a global network of concerned cities: establishing a coalition of cities with shared concerns will amplify the consortium's influence and facilitate constructive dialogue with leading manufacturers. Initial discussions have already begun with cities across Europe (Berlin, Hamburg, Copenhagen, Stockholm, Gothenburg, Linköping), South Korea (Daegu), and the United States (Boston).
- Collaborating with regulatory bodies: exploring certification processes and advocating for EU regulations is critical to ensuring market compliance and that smart doorbells meet stringent standards. Currently, the consortium is in talks with representatives of the European Parliament to place this issue on the EU agenda.
Are you going to install a smart doorbell? Then pay attention to this:
Planning to install a smart doorbell at home? The Dutch Consumers' Association (Autoriteit Persoonsgegevens) provides tips on this page for privacy-friendly settings, such as setting activity zones, motion detection and privacy zones, so that your smart doorbell or security camera doesn't capture just about everything on the street.
In addition, the Data Protection Authority (i.e. Autoriteit Persoonsgegevens) has put together a guide on what to look out for and how to install your smart doorbell in the most privacy-friendly way possible.
Consortium and Coalition Participants
The Consortium includes various stakeholders, such as municipalities, academic institutions, and advocacy groups.
Consortium members:
- Municipality of Amsterdam
- Municipality of Breda
- Municipality of The Hague
- Municipality of Groningen
- Privacy First Foundation
- Dutch Association of Municipalities (VNG)
- TU Delft, Industrial Design Engineering
- AMS Institute
Advisor:
- Prof. Gerd Kortuem, TU Delft
Interested in contributing? Please contact Responsible Sensing Lab via rsl@ams-institute.org.
News (in Dutch)
NRC: 12 million smart doorbells record you, taking away your privacy (URL)
In the Netherlands, the use of smart doorbells with cameras is soaring, with over 1.2 million in use. While they offer convenience, they raise concerns about privacy, as they can inadvertently capture public spaces and compromise the privacy of passersby. The popularity of these devices highlights the need for clearer regulations and discussions about their impact on privacy and security.
EenVandaag: Police can compel sharing of doorbell camera footage: 'You really need to be aware of this' (URL)
If you own a doorbell camera, the police can demand your footage to aid in an investigation. Lawyers warn that this could result in your address being included in legal documents and accessible to others.
BNR Nieuwsradio: Doorbell cameras make citizens subject to police enforcement measures (URL)
Owners of doorbell cameras often have to surrender their video footage to the police under duress, according to a survey by BNR. Lawyers warn that unsuspecting citizens could thus end up in legal proceedings.
Trouw: Smart doorbells pose a danger to our society (URL)
Who else is watching with smart doorbells? Provide more information about this concerning phenomenon, argues Thijs Turèl of the Amsterdam Institute for Advanced Metropolitan Solutions.
NPO Radio 1: Podcast 'Dit is de Dag': Are doorbell cameras actually legal? (URL)
A doorbell camera can be very useful to see who is at the door, but can you just record everyone passing by? Indeed, many people are unaware that filming public streets - which a doorbell camera often does - violates privacy laws. But could such a device also make the neighborhood safer?
Joram Kaat discusses this with Thijs Turèl, responsible for urban digitalization at the Amsterdam Institute, and Karel van Engelenhoven, project leader Camera in Picture at the police.
Het Parool: Green Party councilor Elisabeth IJmker wants to stop Amsterdam's data hunger: 'Were people aware they were being filmed on the Marineterrein?' (URL)
The City must become digitally independent and stop its hunger for data from Amsterdammers. On Thursday, Green Party councilor Elisabeth IJmker will debate this issue with the council. 'Do you really want to be followed more and more? I don't think so.'
NRC: The neighbor doesn't want to be filmed every time he walks down the street (URL)
A man has hung a camera above his window to monitor his car. But the neighbors don't want to be filmed when they walk down the street. Can the camera stay?
De Volkskrant: 'Indeed, shady characters!' The neighborhood app is filled with cheerful suspicions (URL)
Column by Merel van Vroonhoven: In neighborhood apps, suspects are quickly identified without evidence, often based on footage from smart doorbells. This growing surveillance culture, fueled by technology companies like Google and Amazon, raises privacy concerns. Although there appears to be a growing fear of insecurity, it is not always proportional to actual crime rates, making the rise of surveillance practices and the lack of democratic control concerning.
AT5: GroenLinks is concerned about growing number of smart doorbells in the city (URL)
The Amsterdam faction of GroenLinks is concerned about the increasing number of doorbells with a camera, known as 'smart doorbells'. According to the party, the consequences of these doorbells for the privacy of Amsterdammers and the cohesion in the city are being overlooked. GroenLinks wonders if regulations can be implemented.
Smart doorbell leads to surge in privacy complaints (URL)
The surge in complaints to the Dutch Data Protection Authority (AP) regarding smart doorbells and other private cameras has overwhelmed the independent regulator. With over 1,050 calls from concerned citizens last year alone, and the number of video doorbells in the Netherlands soaring to 1.2 million, issues of privacy violations are rampant. The AP, however, lacking enforcement capacity, cannot adequately address these concerns, resulting in numerous neighborhood disputes escalating to legal battles, adding strain to both individuals and society at large.
De Volkskrant: How to prevent your video doorbell from filming too much (URL)
About one in seven households in the Netherlands has a doorbell with a camera, which often films more than legally allowed. Five tips to stay within bounds: 1) Use the bell for its intended purpose, 2) Ensure it doesn't record continuously, 3) Inform people that they are being filmed, 4) Don't store images for too long, if at all, 5) Consider the potential consequences of the footage.
Omroep West: Aantal 'gluurders' met deurbel blijft maar stijgen: 'Actie nodig' (URL)
DEN HAAG - Het aantal klachten over deurbellen of camera's die zaken filmen die niet de bedoeling zijn, blijft stijgen. Dat zegt de Autoriteit Persoonsgegevens (AP) tegen Omroep West. Vorig jaar waren dat er al ruim 1050, een jaar eerder 800.