Consortium Smart Doorbells
The ‘Smart Doorbell Consortium’ conducts research on citizen experiences with smart doorbells, explores regulations and solutions to improve transparency in their usage, and develops guidelines and feature requests.
Smart doorbells have become ever-present in the Netherlands, with up to 1.2 million currently installed across the country. These devices serve multiple functions, from facilitating package deliveries to enhancing security. Equipped with cameras and microphones, smart doorbells are becoming increasingly sophisticated. However, along with their benefits, concerns about privacy, surveillance, and legal issues are on the rise. The ‘Smart Doorbell Consortium’ conducts research on citizen experiences with smart doorbells, explores regulations and solutions to improve transparency in their usage, and develops guidelines and feature requests.
What are smart doorbells?
Smart doorbells offer various functionalities, including two-way communication and image recognition. They can detect individuals and even packages.
A smart doorbell is, at its essence, a doorbell and security camera combined. It allows the owner to be ever-present at their front door through their phone. Unlike a classic security camera, the doorbell can inform the owner when a visitor is present and allows communication between the two through the phone and an intercom.”
— Sofie-Amalie Torp Didrikson, 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 (Onderzoek Multiscope 5000 panelists). The National Police registered 55.000 smart doorbells (Tweakers website March 2023, link). To illustrate, the Data Visualization team at AMS Institute created the two images below showing two areas in Amsterdam.
Why do people install smart doorbells?
Small scale research by AMS Institute showed that people install smart doorbells for diverse reasons, such as remotely answering the door, guiding package deliveries, or enhancing security. However, conflicts with neighbors and concerns about privacy are also driving factors. Many people indicate to have at one point been happy by their neighbors smart doorbell because they wanted to look at the footage to see who made a scratch on their car.
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
Growing concerns associated with smart doorbells
Despite their convenience, concerns about privacy and surveillance arise due to their connection to cloud systems and potential data breaches:
- 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. Data leaving the EU is no longer protected under the GDPR, posing significant privacy risks. When purchased from vendors outside the EU, the liability lies with the buyer. - Intelligence / police
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 information obligation: 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.
- Shuttering as a physical solution: ‘Shutterring’, a concept for physical covers on doorbell cameras developed by the Responsible Sensing Lab, is proposed as a potential solution to privacy concerns, providing assurance to others that they are not being filmed.
- 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.
Addressing these issues necessitates enforcement, regulation, and technological adaptation.
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.
In short, GDPR is the framework, made for personal data, and not specific for the use of camera surveillance, such as smart doorbells. Whether or not the GDPR deems smart doorbells allowable depends on the goal that people have,on what other means they have available to reach that goal and the positioning of the camera and the other ways of positioning or mounting that were available.
Next to GDPR the Convention for the Protection of Human Rights and Fundamental Freedoms, in the Netherlands known as the EVRM, art. 8 can be applicable.
In terms of enforcement, in the Netherlands the Data Protection Authority (i.e. Autoriteit Persoonsgegevens (AP)) is responsible for enforcement of GDPR. This entity has limited capacity and a huge domain to oversee and enforce. Use of smart doorbells by private homes is not high on the priority list. (Despite the fact that they are connected to Amazon and Google, legally seen there are many households who are responsible for the data processing). AP is working on a risk-based approach and will in all practically not get to work on smart doorbells. Having said this; AP does intervene in some specific cases and sends out letters to the persons involved. And at this moment AP has put some guidelines on its website.
3 goals to work towards by Smart Doorbells Consortium and Coalition
In order to effectively address the aforementioned concerns, Responsible Sensing Lab is collaborating with cities, privacy watchdogs, academic researchers, and designers in the 'Consortium Smart Doorbells' (in Dutch: Consortium Slimme Deurbellen) towards three objectives.
- National research to understand citizen experiences with smart doorbells
- Exploring regulatory and non-regulatory solutions to address concerns related to smart doorbells
- Developing national and European guidelines and feature requests for manufacturers National research to understand citizen experiences with smart doorbells
1. National research to understand citizen experiences with smart doorbells
The primary goal of the consortium is to gain insights into how people use smart doorbells and their associated emotional responses. For instance, research conducted in Amsterdam (890 participants, 2023) revealed that 17% of individuals objected to smart doorbells. To comprehensively understand public perceptions, it is essential to explore both the benefits and drawbacks of smart doorbells.
For example, in terms of perceived safety, has this increased or decreased because of smart doorbells? Are there people who feel uncomfortable with cameras around? Do they feel they are able to raise this with their neighbors?
Are people aware of hacks and the fact that captured footage might be beyond their control? What is the latest legal and jurisprudential information? Are there any cases in court right now?
Moreover, particular attention should be given to vulnerable groups such as delivery persons, teenagers, and cleaners.
To investigate intra-household privacy concerns, the consortium plans to conduct surveys, focus groups, and design probe research, with a focus on urban areas where front doors face public spaces.
2. Exploring regulatory and non-regulatory solutions to address concerns related to smart doorbells
The consortium aims to explore a range of solutions, both regulatory and non-regulatory, to mitigate concerns associated with smart doorbells:
- New Local Regulations: Given the limited enforcement of the General Data Protection Regulation (GDPR), alternative regulation tailored to municipal context are needed. For this, collaborating with the Association of Dutch Municipalities (VNG) and seeking advice from the 'Adviesfunctie Verantwoord Datagebruik' (Pels Rijcken) is crucial.
- Design Solutions (Non-regulatory): The consortium will investigate various design solutions, leveraging resources from universities and prioritizing projects based on feasibility and impact. Such as:
Neighborly conduct
Is it possible to inform your neighbors directly when installing a smart doorbell from now on? Initiating this conversation can be awkward. To make conversations easier, simple slogans can be introduced, similar to those used in campaigns promoting safe sex or responsible driving. A national campaign can play a crucial role in facilitating these discussions.
Campaign for the general public
A nationwide campaign, encompassing TV and radio advertisements, street advertisements can effectively raise awareness about privacy issues associated with smart doorbells. Such initiatives not only educate but also encourage dialogue and engagement among community members.
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 focusing on correctly setting your smart doorbell's privacy settings can promote responsible usage of smart doorbells. Highlighting features available on platforms like Eufy and Ring can encourage users to actively implement these safeguards.
From the outside of the doorbell, it is not visible whether a privacy block is active. People installing a smart doorbell should always proactively show their neighbors the privacy mode setting. Although such a measure does not completely alleviate privacy concerns, it can promote trust among neighbors. Just as open communication about this can serve as a deterrent against misuse (unnecessary viewing or storing of images) as long as the neighbor does not reset the setting to the non-privacy-blocking mode after showing a privacy-blocking setting.
Data Protection Impact Assessment (DPIA)
Each owner of a smart doorbell is responsible for all the privacy sensitive data collected by such a device. Recognizing the diverse landscape of smart doorbell owners, implementing a tailored Data Protection Impact Assessment (DPIA) becomes necessary. Considering factors such as brand, model, connectivity, and storage options, each doorbell owner can customize their DPIA to align with their privacy preferences and requirements.
Shutters and modifications
Developing and testing low-tech modifications, such as ‘Shutterrings’, to limit the field of vision or adjust the timing of the doorbell lens can enhance user privacy. These modular solutions, compatible with various smart doorbell designs, can be distributed through campaigns or made available for purchase, offering users greater control over their surveillance capabilities.
Adversarial design
By prototyping potential future adversarial designs or features that challenge conventional norms, and most people will likely strongly disagree with, awareness can be raised. For example, simulating doorbell systems allowing third-party (like ‘juice-channels) access to footage or enabling cross-doorbell tracking can highlight the risks associated with unchecked surveillance practices.
Choice-help
Creating a dedicated website to assist individuals in selecting smart doorbells with minimal privacy implications can empower consumers to make informed choices. Providing guidance on factors such as audio capabilities, storage options, and privacy features can help users navigate the market landscape. For example, Bits of Freedom launched a campaign to sell 'dumb doorbells' to raise attention about privacy concerns. These are regular doorbells without all the features a smart doorbell has.
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 national and European guidelines and feature requests for manufacturers
Ultimately, the design of smart doorbells will need to change. And this can only be done in collaboration with manufacturers. To bring about meaningful change, the consortium will, in consultation with other cities, compile a list of desired changes to present to both manufacturers and regulatory authorities. Overall our aim is to:
- Formulate guidelines or feature requests: Inspired by successful models like Apple AirTags, the consortium will articulate clear guidelines and feature requests regarding appearance, app functionalities, data processing, and user privacy.
- Build 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 top manufacturers. Initial discussions have commenced with cities across Europe (Berlin, Hamburg, Copenhagen, Stockholm, Goteborg, Linkoping), South Korea (Degu), and the USA (Boston).
- Engage with regulatory bodies: Exploring certification processes and advocating for EU regulations will be pivotal in fostering industry compliance and ensuring smart doorbells meet rigorous standards. Discussions with representatives of the European Parliament are underway to elevate the issue on the European 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, including municipalities, academic institutions, and privacy advocacy groups. The Coalition consists of advisors, friends, and sympathizers who support the objectives of the Consortium. Additionally, an Advisory Board comprising experts provides guidance and oversight.
Consortium participants
- City of Amsterdam
- City of Breda
- City of The Hague
- City of Groningen
- Privacy First Foundation (i.e. Stichting Privacy First)
- VNG (Association of Dutch Municipalities)
- TU Delft, industrial design engineering
- AMS Institute
Those who can’t join the consortium will participate in the Coalition Smart Doorbells.
Coalition (advisors, friends, sympathizers)
- Dutch Data Protection Authority (i.e. Autoriteit Persoonsgegevens)
- Sofie Dideriksen, PhD candidate TU Delft
- The Incredible Machine
- Institute for Information Law, University of Amsterdam
- City of Rotterdam
- City of Utrecht
- City of Eindhoven
- City of Hilversum
- City of Amersfoort
- City of Arnhem
Advisory Board
- Prof. Gerd Kortuem, TU Delft
Gerd Kortuem
Professor of Internet of Things, TU Delft
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.
Shutterring
The Shutterring project aims to make smart doorbells more responsible by ensuring the privacy of bypassers and owners while keeping the main functionality of the device intact.
Challenging the design of smart doorbells
Our graduation student Sofie-Amalie is creating alternative smart doorbells through speculative design to challenge the current design of smart doorbells (IoT doorbells with integrated cameras).
Hein Wils
Program Manager Digitisation & Innovation, city of Amsterdam
Thijs Turèl
Initiator Responsible Sensing Lab and Program Manager at AMS Institute
Silke Snijder
Graduation student Design for Interaction at TU Delft