Smart Glasses at Work and on Business Premises: Recording Policies, Accommodations, and Privacy Exposure

Brittney K. Mollman, Counsel | Thompson Coburn LLP

Brittney Mollman is counsel in Thompson Coburn’s Business Litigation group, where she focuses her practice on privacy, data governance, and emerging technology issues. She advises organizations on complex legal and regulatory matters involving biometric data, artificial intelligence, workplace technologies, data governance, digital tracking tools, incident response, and evolving state, federal, and international privacy requirements. Her work is informed by extensive experience helping clients navigate regulatory investigations, enforcement matters, and high-stakes litigation.

• Education & Credentials

Brittney earned her J.D., cum laude, from Washington University School of Law and her B.B.A. from Emory University. She is admitted to practice in Texas and Missouri and holds the CIPP/US certification.

• Recognition & Leadership

In addition to her counseling practice, Brittney is a frequent author and commentator on emerging privacy and technology issues, including biometric privacy laws, wiretap and website-tracking litigation, AI regulation, privacy enforcement trends, and evolving state privacy requirements. Her litigation-informed perspective enables her to help clients anticipate how decisions involving data collection, monitoring technologies, and emerging technologies may be evaluated by regulators, courts, and enforcement agencies. She serves as Vice Chair of the Missouri Bar Technology and Innovation Law Committee.

• Professional Involvement

Brittney is a member of the IAPP St. Louis Chapter, the American Bar Association Section on Litigation, and the Women Lawyers’ Association of Greater St. Louis.

• Experience

Brittney helps companies make practical, defensible decisions at the intersection of technology adoption, data use, and legal risk. She regularly counsels clients on privacy program development, AI governance, vendor and platform assessments, technology implementation, and compliance strategies designed to withstand regulatory scrutiny and litigation challenges. She is frequently engaged during new product launches, business growth initiatives, and periods of regulatory change, helping organizations balance innovation with compliance obligations.

Her representative experience includes the following: Defended a non-profit organization in a class action lawsuit filed by former employees following a cyberattack on the organization’s IT systems. Represented a national health care data analytics company in a multi-state class action after a cyberattack and assisted in working toward a desirable settlement. Assisted a national health care data analytics company responding to state attorneys general investigating a cyberattack on the organization. Defended global privately held manufacturing company in complex shareholder litigation. The litigation team obtained a successful outcome when plaintiffs voluntarily dismissed their multiple lawsuits against the organization after years of litigation.

Stephanie C. Fredman, Associate | Thompson Coburn LLP

Stephanie Fredman represents employers in a broad range of labor and employment matters, helping organizations navigate workplace compliance, employee relations, policy development, and employment litigation. She partners with management teams to address complex workforce issues and delivers practical, business-focused guidance that aligns legal requirements with organizational objectives.

• Education & Credentials

Stephanie earned her J.D. from Washington University School of Law, her M.Ed. from the Harvard Graduate School of Education, and her B.A. from Emory University. She is admitted to practice in Missouri and Illinois.

• Recognition & Leadership

Stephanie is listed in Best Lawyers in America: Ones to Watch (by BL Rankings) for 2027. Her recent presentations include “The Federal Regulatory Update for Higher Education” at the Forvis Mazars Higher Education Summit (February 2026), “Navigating Legal Shifts in Education: Inclusion, Oversight, and Risk” for the Missouri Association of Student Financial Aid Personnel (November 2025), and “Navigating OCR Complaints: Practical Steps for Financial Aid Administrators” for the Midwest Association of Student Financial Aid Administrators (October 2025).

• Professional Involvement

Stephanie is a member of the National Association of College and University Attorneys (NACUA), where she serves on the Committee on Membership and Member Services.

• Experience

Stephanie counsels clients on matters involving discrimination, harassment, retaliation, wage and hour compliance, workplace investigations, and responses to EEOC and state agency charges. She also assists employers with developing workplace policies, managing compliance obligations, and addressing emerging employment law challenges. Her experience advising on human resources issues and resolving employment disputes enables her to provide strategic, solutions-oriented counsel to employers across a variety of industries.

SESSION 1 – Drafting Workplace Recording and Smart-Glasses Policies After the January 2026 NLRB Decisions | 12:00pm – 1:00pm

This session shows how to draft legally defensible workplace recording and smart-glasses policies in light of the January 2026 ALJ decisions, the still-binding Stericycle framework, GC Memorandum 25-07 on bargaining-session recordings, and the ADA accommodation issues illustrated by Bruno Cedeno v. Disney. Attorneys will learn the drafting structure that allowed a UPS policy to survive NLRA review and how to apply that model to wearable devices that older phone-era policies do not cover. Participants will leave with a checklist of required policy elements, an accommodation carve-out template, and dual-track guidance for a likely move from Stericycle back to a Boeing-style standard.

BREAK | 1:00pm – 1:10pm

SESSION 2 – Advising Customer-Facing Businesses on Smart-Glasses Recording and Biometric Privacy Risk | 1:10pm – 2:10pm

This session prepares attorneys who advise retail, hospitality, healthcare, and other customer-facing businesses to spot and manage the overlapping legal risks created by smart-glasses recording on their premises, whether the recording is done by patrons, employees, or the business itself. Attendees will review the regulatory patchwork of state biometric privacy laws (BIPA, CUBI, and similar statutes), all-party-consent wiretap laws, FTC enforcement precedent, and local rules restricting facial recognition in places of public accommodation. Attorneys leave with a practical advisory framework covering premises policy, employee-deployment protocols, vendor contract risk, and signage obligations in high-risk jurisdictions.