The use of Virtual Reality has expanded from gaming scenarios to less recreational immersive experiences including education, news reporting, advertising and training. Three key areas where VR is being considered for experimentation and implementation are:
- Education,
- Museums
- Cultural heritage
However, the use of these systems may lead to data protection issues, especially where off-the-shelf solutions are being sought rather than bespoke systems. Specifically, the data collected by many VR operators raise GDPR compliance issues through their collection of personal data as well as ethical issues in relation to immersive experiences.
Virtual Reality and Privacy
Current commercial VR tools often collect personal data to improve customer experiences and provide follow-on support. For example, the majority of current VR companies (Samsung, Oculus, Playstation, Google, etc.) have the following information collection frameworks:
- They use cookies to identify users and track their preferences
- They collect location-based info (personal data under the GDPR according to the Art. 29 DP WP)
- They share aggregate information with third parties (app developers, parent companies, business partners, etc.)
- They collect IP addresses, names, email addresses, DOB and information about users’ browser and device.
- They store all social communication within the system (e.g., messages between users)
- They use this information to supply customised and personalised advertisements
Some service providers also collect, store and process data about eye movements within the system, facial expressions and haptic data, which can provide information about people’s preferences or items that capture their attention.
According to a World Economic Forum report, these immersive technologies will introduce new risks to personal data, beyond the categories we are accustomed to thinking of as personal data, especially when they are used for advertising. The processing of this personal data makes the GDPR relevant, and the storage of communications undertaken within the system make compliance with the ePrivacy Directive (2002/58/EC) and proposed ePrivacy Regulation (Europa, 2017) relevant as well.
In order to ensure VR systems in any sector consider relevant European legislation and ethical principles, researchers need to develop new metrics to measure VR experiences.
The Positive Impact of Virtual Reality
Despite the potential privacy and data protection concerns, the use of VR and other technologies to make cultural heritage more widely accessible will result in significant positive impacts.
Research has found that the use of VR and other immersive technologies has significant impacts on people’s ability to empathise with what they are seeing, far beyond their experience of 2D television.
For example, in the context of NGOs, Deloitte has found that the use of VH has had a positive impact on donations to NGOs using these tools.
In addition, the use of VH has other positive social and environmental impacts like allowing donors to see how their funds have been used and providing an alternative to CO2-heavy site visits.
The Negative Impact of Virtual Reality
There are concerns about the potential impact on our happiness and psychological well-being as virtual social interactions replace (some) physical social interactions (see current debates around young people, depression and smartphone use).
At the extreme end, some argue there is a potential for addiction to Virtual Reality immersion.
In relation to cultural heritage specifically, there are questions around replicating the intangible aspects of cultural heritage (e.g., cooking) and the imperfections associated with attempting to capture and represent these intangible aspects as an experience.
Research on open access to data within the field of archaeology found that scholars were concerned about nuanced cultural representation and cultural appropriation when designing strategies to maximise access to archaeological data.
Recommendations for a Privacy savvy Virtual Reality
Researchers need to identify both positive and negative impacts of Virtual Reality systems, and consider indicators like user satisfaction, enhancement of well-being, quality of experience and learning outcomes in relation to cultural heritage access and education.
Developers, as well as procurement personnel, should undertake Data Protection Impact Assessments and Ethical Impact Assessments to ensure the responsible use of these new tools, especially when they are being used with children or those with disabilities to make cultural heritage more accessible.
Such an assessment will allow cultural and educational institutions to capture the benefits of VR while maintaining a responsible approach for students and visitors.
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