As IoT devices collect ambient and biometric data, businesses must understand how the General Data Protection Regulation (GDPR) governs consent, design, and accountability. Learn how Curated Privacy LLC can help—with a FREE consultation.

Smart speakers that listen. Office sensors that detect motion. Wearables that monitor heart rates. This is the era of the Internet of Things (IoT)—devices everywhere, quietly gathering vast amounts of data. While this can streamline operations and enhance efficiency, it also poses serious privacy challenges. Under the General Data Protection Regulation (GDPR), businesses using IoT must navigate a strict framework centered on design, consent, and risk.

What the GDPR Requires for IoT Devices

1. Privacy by Design & Default

The GDPR mandates that data protection measures must be built into the very architecture of devices. Under Article 25, technologies must be designed to minimize data collection and ensure personal data is anonymized or pseudonymized wherever feasible. Controllers must also demonstrate that these privacy safeguards are active by default—meaning no unnecessary data should be collected without explicit action or override. 

2. Lawful Processing & Explicit Consent

IoT devices often operate without users’ real-time input. Yet under the GDPR Article 6, data processing must have a lawful basis—most often explicit consent when sensitive or biometric data is involved. According to guidance, inactivity can no longer be presumed as consent; businesses must ensure users are fully informed and actively opt-in. Legal IT groupGDPR Advisor

3. Data Minimization & Purpose Limitation

The GDPR principles (Article 5) require organizations using IoT to collect only what is strictly necessary and to use data solely for the purpose communicated at collection. For instance, a sensor collecting temperature data should not be repurposed later for tracking employee behavior unless additional consent is obtained. GDPR Advisor

4. Data Protection Impact Assessment (DPIA)

The  GDPR’s Article 35 requires a DPIA when deploying new technologies like IoT devices that pose high privacy risks. Given the ambient or biometric data collected, most IoT implementations will trigger this requirement. A DPIA helps businesses identify, assess, and mitigate privacy risks throughout the technology’s lifecycle. Legal IT groupAdventures in Information Science

5. Security, Accountability & Breach Notifications

Controllers must adopt strong security measures—encryption, authentication, regular software updates—to guard against unauthorized access. Under the GDPR, controllers are accountable: breaches must be reported to relevant supervisory authorities within 72 hours when feasible, and affected individuals must be informed unless data is effectively encrypted. 

What SMBs Must Consider for the GDPR-Compliant IoT Use

• Conduct a DPIA before deploying IoT technologies to assess risks tied to biometrics, location tracking, or ambient data collection.

• Embed Privacy by Design: Work with vendors or design policies that ensure devices collect only essential data, anonymize data where possible, and default to restrictive settings.

• Obtain and document explicit consent, even for passive data collection—especially where sensitive data is concerned.

• Limit data collection and clearly define usage purposes. Avoid secondary, unanticipated uses without renewed consent.

• Maintain security and accountability with encryption, strong authentication, and incident-response protocols to enable timely breach notifications.

How Curated Privacy LLC Can Help

At Curated Privacy LLC, we specialize in making the GDPR compliance tangible for businesses integrating IoT. Our services include:

• DPIA services tailored to IoT risk scenarios

• Privacy by Design integration, guiding both internal audits and partner/vendor systems

• Consent strategy implementation for ambient and biometric data collection

• Security & breach preparedness, including encryption and notification frameworks

• FREE consultations to evaluate your IoT footprint and compliance posture

Let us help you navigate IoT’s “creep factor” and ensure that convenience doesn’t come at the cost of privacy—or penalty.

Book your FREE consultation today! Visit www.curatedprivacy.com or email info@curatedprivacy.com. Together, we’ll craft an IoT data strategy that respects users and aligns with the GDPR.