The text, diagrams, and content of this standard are licensed under a Creative Commons Attribution 4.0 International License.

Trademarks, logos, brand names, and any official branding are not licensed under Creative Commons.

PrivateEZ™ and QRCauseTM are trademarks of High Bit Security, LLC. QRCause is a patent-pending application from High Bit Security, LLC. All references to PrivateEZ™ or QRCause™ are to be considered trademarked, whether so noted or not. All rights reserved. Permission to use any trademark or logo must be obtained separately, in a written Trademark Licensing Agreement.

Trademarks and Brand Names Owned by Others - NOTICE
All other brand names, product names, platform names, and trademarks mentioned in this document (including but not limited to Amazon Alexa, Google Home, Apple HomeKit, Samsung SmartThings, Home Assistant, Nest, Ring, Philips Hue, Ecobee, Mozilla and similar examples) are the property of their respective owners. They are used solely for identification, illustration, and educational purposes to describe common smart home component categories and features. Their inclusion does not imply any endorsement, affiliation, sponsorship, approval, or relationship with this open standard or its authors. No trademark rights are claimed by this document other than those specifically claimed above. All content is an original synthesis and does not reproduce copyrighted material from any source.

PrivateEZ™ Home Privacy Standard and Framework v1.3


Contents

  1. Abstract
    1. Intent
    2. Background and Motivation
    3. Challenges
    4. Definitions
  2. Section 1. Information Delivery Framework
  3. Section 2. Control Subjects
  4. Section 3. Smart Home Use Case Categories
  5. Section 4. Privacy Concerns and Mitigation
  6. Section 5. Privacy Controls for Components – Mitigation Challenges
  7. Section 6. Facilities Privacy Concerns and Mitigation
  8. Section 7. Facilities Controls
  9. Section 8. Certifying the Home Itself
  10. Section 9. Knowledge-Based Certifications
  11. Section 10. Conclusion

Abstract

Intent

The overall purpose of this document is to create the standards necessary to ensure privacy in smart home deployments. The primary beneficiaries of this standard are Home Residents, Home Builders, Property Management Firms, Realtors, and Employers with remote or hybrid workforces. These are not the only groups, and the list continues to grow. All of these groups share increasing concerns over data leakage from the home, although for different reasons. This document aims to create a working standard and framework, flexible enough to grow as need arises, and that, when followed, will mitigate most or all of the concerns of these and related groups.

When used as intended, this document creates a single, reliable, and trustworthy standard that thoroughly covers all aspects of smart home privacy, which is then paired with a reliable trustmark. The trustmark is integral to the standard, and the two elements together are intended to ensure the home is working for homeowners, not spying on them — intentionally or not.

Contents

Background and Motivation

Privacy concerns surrounding smart home technology — particularly AI-powered voice assistants such as Alexa, Google Home, and Siri — have grown significantly in recent years. Homeowners worry about always-listening microphones, unintended recordings, cloud data processing, and potential third-party sharing. At the same time, companies with remote and hybrid workforces increasingly view employee smart-home components as uncontrolled attack surfaces that could leak sensitive business data. These rising concerns highlight the urgent need for a clear, open, and adoptable public standard that defines privacy-protective practices for smart home systems with and without AI voice interactions.

Evidence for agreement

Group 1: Homeowners (Consumers)

Homeowners show rising adoption paired with growing privacy worries, especially around voice assistants and AI features. Multiple independent surveys document this increase year-over-year (2024–2025 data):

Group 2: Companies with Remote Workers

Companies increasingly treat employees’ personal smart home components as enterprise security risks in the era of permanent hybrid/remote work. Key findings include:

Bipartisan Political Concerns (Additional Evidence)

In the US, recent 2025–2026 polling shows that both Democrats (and Democratic-leaning independents) and Republicans (and Republican-leaning independents) share high levels of distrust toward government handling of private data and major cloud providers / AI systems that power smart home voice technology. This rare political convergence creates broad, cross-party support for stronger privacy standards.

Conclusions

This evidence — spanning homeowners, employers, and all major political parties and independents — demonstrates a clear, accelerating demand for standardized privacy protections in smart home technology in general, and AI voice technology in particular. That demand spans almost every aspect of our lives, including our homes, our jobs, and our politics.

Anything that concerns homeowners also impacts the entire home owner market, including Realtors, Home Builders, Home Improvement, Property Management firms, the insurance market and other related industries. Those 'other industries' expand to almost everything when Employers with Remote workforces are considered.

It may seem odd that employers and home residents could share the same privacy concerns, but in most cases there is no conflict of interest and a great deal of shared interest. Most employers do not want — and take strong measures to avoid — collecting personal data from employees when it is unrelated to their job. Doing so would put them in jeopardy of a growing body of employer/employee privacy law. Employers worry about the unintentional leakage of data, in both directions: employer proprietary data leaking out, and employee private data leaking in. Both cause problems of different types and both occur through the increasingly broadening attack and leakage surface of smart homes. As the number of remote employees increases every year and the homes they occupy become more and more “leaky,” the problem grows very quickly.

So, Home Residents are concerned, and Employers with remote workforces are concerned. Fortunately, it turns out that most of the concerns of both groups are mitigated by the same expedient: making the home a private sanctuary for life and work. Getting control of the home is the critical first step for peace of mind, whether you are a CISO worried about smart mirrors capturing your employees login screens, or a home resident who wants to ensure that the same smart mirror isn’t sending private images to the cloud.

Taken all together, it seems unlikely that the current market vacuum for the actual service of those concerns will long be tolerated. From work to play, top to bottom and left to right, it may be hard to find a topic more universally demanded than privacy in the home, yet until now there has been no workable standard.

Why?

Contents

Challenges

A destination without a map.

Despite nearly universal concern, there is no road map. Instead, a few scattered standards, regulations, policies and frameworks from disparate governments, industries, and watchdog groups provide a patchwork of unverified controls, most of which are unusable or indecipherable to the average consumer. The traditional answer to such mass confusion has been political action. The data shows, however, and common sense suggests, that politics is an unlikely path to a solution.

What hasn’t worked.

Political Solutions. The problem has existed for quite some time, with no solution. History suggests that if and when politicians do act — no matter which country, region, or party they represent — the action will be a “compromise” with plenty of exceptions that enable and codify some privacy abuses as much as control them. The studies show that the public distrusts government with this issue as much as they distrust industry, regardless of party. Politicians are viewed as the root of half of the problem, deriving much of their funding from the other half of the problem. That either side could produce a solution without compromising with the other side of the aisle, or molifying their own funding providers with codified exceptions, is something we and the public view as unlikely at best. Any political solution is probably too little, too late and too compromised. The surveys suggest that this is not just our view, but a widely shared view.

Existing Standards. We do need a solution, but we have no wish to re-invent the wheel. One of our initial hopes was that we might find all of the requirements for smart home privacy already addressed in other standards, which we then might simply pull together by reference. To that end we conducted a thorough analysis of existing privacy standards, certifications and frameworks. As they relate to smart homes, we found that they range from nearly completely irrellevant to highly relevant, but they all lacked two major attributes:

  1. Thorough Coverage. None of them cover all of the neccessary factors, even when taken all together. There is no way to obtain full coverage by reference.
  2. Usability. None of them are actually useable for consumer or employer decision making, because:
    1. Consumers are not information security or privacy professionals who are accustomed to reading standards, and even if they were, most components require configuration, which means repeated, mind numbing research for every product to ensure correct configuration.
    2. Employers want to know that the home meets their requirements, and nothing else. The last thing they want is a long report containing private details about their employees home configuration.

So, political solutions are too little, too late and too compromised, if enacted at all. Existing standards are there, but they are all incomplete and lack mechanisms to make them usable to the public and employers.

Any workable solution must cover the entirety of the problem, be trusted, and be useable to the public and to employers with as little effort as possible. Those three concepts: coverage, trust and useability, are the backbone of this standard.

What can work

Coverage. This standard develops coverage requirements by analyzing the commonly used smart home components for privacy concerns, and then creating a control list that covers all of those concerns. It turns out to be a remarkably short and simple list, once your really analyze it. This control list is the coverage basis for the standard.

Trust. The public needs to know that the control list is well founded and the enforcement of those controls can be trusted. This standard creates a framework to do that. It builds on the controls by providing 'certification marks', backed by transparent USPTO rules, that anyone can look up on their own. This is crucial and integral to the standard. It will be discussed further in Section 1.

Useability. The control list, no matter how well founded, is no more than a 'wish list' if you can't use it. The biggest single innovation in this standard is the information delivery framework that allows all parties to benefit from the standard with minimal effort. Without this factor, even a thorough and trusted standard would be quite useless to the public or to employers. It is an absolute necessity, and we will cover it Section 1.

Sources (click to expand)

Links valid as of date of post, not monitored.

[1]: Copeland Study Reveals Increasing Concerns Around Data Privacy in Smart Home Products (January 2025)

[2]: AHS Smart Home Survey 2024: Adoption, Concerns, and ROI (May 2025)

[3]: CNET Survey Shows 73% of Voice Assistant Users Express Privacy Worries About AI (May 2025)

[4]: NIST Survey on Smart Home Users’ Security and Privacy Perceptions and Actions: component Category Perspective (December 2025)

[5]: Deloitte 2025 Connected Consumer Survey (September 2025)

[6]: Smart Home Growth Increases Enterprise Security Risks (October 2025)

[7]: Why 70% of Companies Fear Their Own Hybrid Employees - Insider Risk Report (October 2025)

[8]: YouGov: Vast majorities of Democrats and Republicans are concerned about technology’s effect on personal privacy (March 2026)

[9]: Pew Research Center: Republicans, Democrats now equally concerned about AI in daily life (November 2025)

[10]: Center for Democracy & Technology (CDT): Common Concern - Americans Worried About Personal Data Held by Public Agencies (March 2026)

[11]: Gallup/SCSP: Americans Prioritize AI Safety and Data Security (September 2025)

[12]: Fox News Poll: Voters see AI as a risk to privacy (April 2026)

[13]: Applicant is not engaged in the production or marketing of the goods or services to which the mark is applied, except to advertise or promote recognition of the certification program or of the goods or services that meet the certification standards of the applicant. (Trust Mark Applications, USPTO, April 2026)


Contents

Definitions

The following definitions apply throughout this Standard:

Account Holder
An entity with authorization to enter data into the Registry on behalf of itself or others.
Attestation
A formal statement by an entity (such as a component vendor, facility operator, or Knowledge-based licensee) describing how an Offering meets the requirements of this Standard. Attestation is a required step in the certification process but does not, by itself, constitute certification or authorize use of the PrivateEZ™ badge.
Badge
The specific visual implementation of the PrivateEZ™ Trust Mark. It consists of the PrivateEZ™ Certification Mark combined with a QR code that is unique to a specific Offering. The Badge displays the certification rating achieved (represented as 1 to 5 stars) and links directly to the Offering’s registry page. The specific meaning of each star level is defined in the Certification Policy.
Body of Knowledge (also referred to as the Standard)
The PrivateEZ™ Home Privacy Standard and Framework v1.0 (as amended from time to time).
Certification
The formal status granted to an Offering after successful completion of attestation, auditor review, and (where required) execution of a Trademark Licensing Agreement. Only Certified Offerings may use the PrivateEZ™ badge.
Certification Authority
By default, the owner of the Certification Marks. In this case, High Bit Security, LLC, or its designated appointee.
Certification Mark
A mark registered (or applied for registration) with the United States Patent and Trademark Office (USPTO) under the legal category of Certification Mark. As defined by the USPTO, the owner of a Certification Mark may certify that goods or services meet certain standards but may not itself produce or sell those goods or services under the mark.
Certified Offering
An Offering that has successfully completed the certification process and remains in good standing under this Standard.
Checklist
A document, or database structure, used to simplify and track compliance with this Standard.
Conformance Requirements
The rules (shall, must) and recommendations (should, may) set forth in this Standard that define the criteria an Offering must meet to achieve certification.
Control Subject
Any entity, system, or location subject to the controls defined in this Standard. Control Subjects include components, software, AI models, installers, real estate professionals, auditors, homes, and facilities.
Facility Certification
Certification of a data center, cloud provider, utility, or other facility that processes or stores smart home-related data. Facilities receive a certification rating as defined in the Certification Policy.
Home Certification
A review of a residential property conducted under this Standard. Homes receive a certification rating as defined in the Certification Policy.
Home Inventory Attestation
A review of a residential property focused on device inventory, fixture/chattel classification, and transfer readiness.
Home Resident
Any individual who lives in or regularly occupies a residential property. This includes homeowners, tenants, and other occupants.
Knowledge-based Certification
A certification granted exclusively to companies and legal business entities (not to individuals) that demonstrates organizational knowledge of this Standard.
PrivateEZ™ WorkZone™
A private, non-public report prepared for a specific third party (such as an employer) at the request of the homeowner.
Offering
A Control Subject that has been officially submitted for registration, attestation, or certification under this Standard.
PrivateEZ™ compliance Checklist
The standardized checklist that an entity must complete for each Offering submitted for certification. It records whether each applicable control is met by default (Yes), not met (No), or partially met (Partial), along with references to supporting documentation.
PrivateEZ™ compliance Manual
The supporting documentation (which may be an existing manual or a compiled document) that provides the detailed instructions, configuration steps, and references needed to verify compliance with the controls listed in the PrivateEZ™ compliance Checklist.
Registry
The centralized, publicly accessible system that stores and displays attestation information, compliance status, and certification rating for registered and certified Offerings.
Supplier, Vendor
An organization that produces an Offering under this Standard.
Trust Mark
A mark used to convey that an Offering, property, or entity has been reviewed and meets defined standards. In this Standard, the term refers conceptually to the PrivateEZ™ marks in their role of building public trust and enabling standardized information delivery. The specific visual form of the Trust Mark used in this program is the Badge.

Contents

Section 1. Information Delivery Framework

Why start with delivery? Shouldn’t that be the end of the process?

Yes, but it is also the root of the problem. That was not entirely clear, even to us, when we started this process, but in the end it became the central feature of the standard. There have been many privacy-oriented standards, policies, regulations and other attempts at control over privacy. Most have been helpful, but when it comes to consumers, they all fail for the same reason.

Anyone who has ever waded through dozens of pages of privacy policies, agreements and instruction manuals trying to understand the privacy footing for an interesting product knows for a fact that there is still no good answer.

There is no good answer because no one has asked the most important question. We didn't ask it right away either. When we started this project, we thought the important question was: "what information is necessary to ensure privacy in the home ?". We were wrong. That question, after careful analysis, actually turns out to have a fairly simple answer. The important, and difficult, question is "how do you deliver that information once you have it ?". That, it turns out, is the number one challenge.

To illustrate the problem, we will once again quote from someone other than ourselves: the Mozilla Foundation’s ‘Privacy Not Included’ project. This is an excellent example of good will and substantial effort on the topic of privacy, by an organiztion that is steeped in it. We encourage everyone to have a look at the project, but in this case we are interested in one small section: the comments they make about the effort required to make their ratings:

From https://www.mozillafoundation.org/en/privacynotincluded/about/

Time Spent on Research

We approach our research for Privacy Not Included from the viewpoint of you, the consumer. We don’t purchase the products and test them in a lab. Consumers can’t do that. Instead, we look at all the publicly available information we can find to try and understand the privacy and security concerns you should be aware of. We want to help you understand how long this takes us, in part so you know we’ve taken the time to get things right. But also to help you understand how ridiculous it is that consumers are expected to spend so much time researching connected products before they buy them just to hopefully protect their privacy. It shouldn’t be like this. Companies should do better by building privacy by design into their products.

(bold print is our added emphasis)

We can add one more observation to their comments here, and it couldn't be more important: Many companies do build privacy into their products by design.

In fact, many are trying very hard to be noticed in that regard, it is part of the their marketing plan because they also know that the market is hungry for it. Unfortunately, they face the same problem that consumers face.

The problem is that there is no standard way to deliver the information, so even if companies want to do better and disclose everything, they have no way to easily present it for consumption. They can put it on their website and even try to give as much direction as possible on their packaging and instruction manuals, but you still don’t know if it is complete, where to find it, or how to apply it once you do find it, unless you do the research. Even when a company is trying hard to do it right, and welcomes the opportunity to tell you about it, they all do it differently because there is no standard way to do it. You have to start your research from square one every time.

If an organization as dedicated to privacy as the Mozilla Foundation can’t find the needed information fast enough to make a real-time purchase decision on a product or service, how can we expect any normal consumer to do so? The privacy standards, laws, regulations, policies and procedures we have today are clearly not adequate to the task, and even well-meaning companies can’t fix it alone. In fact, some of the current statutes and regulations, around anti-trust laws in particular, make it nearly impossible for companies to collaborate between themselves to solve the problem even if they want to. They need an independant third party to recognize, organize and facilitate the flow of information.

So, the most important question is: how can the information be organized to present an easy solution for vendors and employers, and allow a consumer to know what they are buying or using before they buy or use it? If this standard fails to answer that question, it will leave the essential problem again unsolved.

That’s why we are starting with information delivery, because it is the heart of the problem. The information delivery solution begins with Trust Marks.

1.1. Structure, Trust Marks, Registries and QR Codes

Structure

Before we can get to Trust Marks, we need a brief note about structure. This Standard defines the technical privacy and security controls and basics of the information delivery framework. It does not define operational rules or trade mark licensing. These are in separate documents.

The PrivateEZ™ program uses an incremental rating system, visually represented by a designation of one to five stars. The operational rules of the program are defined in the Certification Policy.

The legal right to use the PrivateEZ™ marks and Badges is critical to the success of the Standard, and is governed by the Trademark License Agreement (TMLA). All use of the PrivateEZ™ certification marks and associated QR codes must comply with both the TMLA and the Certification Policy.

Trust Marks

High Bit Security produced and maintains this standard and owns the trademarks associated with it. That may not at first seem trustworthy at all, until you know that they are not ordinary trademarks. We have fenced ourselves out of the very market we certify by registering our Trust Marks as USPTO ‘Certification Marks’ (instead of standard ‘Word Marks’). One of the stipulations to registering a Certification Mark in the U.S. is that the owner of the marks may only certify. The owner of the marks cannot produce products or provide services that are also branded with the marks.

That concept, we believe, is critical to public trust and is the first caveat for information delivery: Our Trust Marks may only be used on products or services produced by others and certified by us. They may never be used to represent certification of our own products or services.

The Registry

Establishing trustworthy marks to indicate privacy compliance is a good first step. However, it is not very useful if it leaves consumers uninformed about what the component or software dependencies are, whether it is compliant by default, or what configuration steps are necessary to achieve the desired privacy. Experience shows that finding that kind of information can take consumers hours or days of research, even if the vendor intends to make it easy.

Vendors have no standardized way to present the information, even when they want to do so. That is where the registry comes in. The registry allows consumers to see all of the required information for any certified Offering, in one standardized location, organized the same way every time.

That is helpful, especially when purposely conducting research, but to use it the consumer still needs to remember or have access to a web address and then look up a product or entity in the registry. That is not always practical and certainly not intuitive.

The QR Code and Badge System

Ideally, a Trust Mark would automatically expose the registry information required for decision making and correct implementation. Much more than a mark, that kind of intuitive answer could be quite useful to everyone involved, but really helpful to consumers and installers. That is exactly what QRCauseTM (patent pending) is designed to do. QRCauseTM was specifically developed by High Bit Security to create the Badge that supports this standard (https://qrcause.com).

The Badge combines

  1. the PrivateEZ™ Certification Mark,
  2. a unique QR code,
  3. the star rating achieved by the Offering, and
  4. a link to the detailed registration page.
This system allows any party to immediately view the certification status, plus quickly access detailed, standardized setup and configuration information about an Offering simply by scanning the QR code with a smart phone.

Displayed on packaging and marketing material for certified products and services, this Badge can be available virtually everywhere, including in-store. Here is a working example of a completed Badge pointing to a sample registry page:

Fig-1 — A working Badge for a sample Offering from a sample certified licensee using the PrivateEZ™ brand, produced by the QRCauseTM application from High Bit Security, Patent Pending (https://qrcause.com)

Unlike most QR codes, which lead to infinitely varied content provided by those who create them, the code above is integrated into a certification Badge and leads to a standardized registration page that is formatted the same way for every licensee of the same category.

Hopefully it is now clear why we started with information delivery — it is the heart of the framework. There is limited value in knowing that something might be cofigured well. If you can't quickly find out how to do it, then for many practical purposes, it's a waste of time.

Now consumers, installers, realtors and builders can all find the critical information in a fraction of a second using one device: a cell phone or tablet. The remainder of this document will focus on privacy concerns: how we identify and categorize them, how we looked for existing solutions, and how we fully address them.

Contents

Section 2. Control Subjects

This Standard defines controls for smart home components, human elements, and systems. Collectively, these are called the Control Subjects.

The Control Subjects include:

Common Approach, Different Specifics

All certification begins with registration and attestation. An attestation is a formal statement by an entity describing how a specific Control Subject meets the requirements of this Standard. The attestation is reviewed by an the Certification Authority. After successful certification, the attestation information may be made available to the public or kept limited, depending on the certification category and applicable rules.

Registration and attestation alone does not authorize use of the PrivateEZ™ Badge. Use of the Badge is governed by the Certificaton Policy.

Certification Categories

This Standard establishes the following categories of certification, each of which is subject to specific rules outlined in the Certification Policy:


Contents

Section 3. Smart Home Use Case Categories

WARNING: We are about to 'show our work', demonstrating several steps toward developing a list of privacy concerns and mitigation strategies. It is tedious and you may want to skim, but it is important to document the steps we took to get to our final control list, and this is where we start. If you intend to seek a Knowledge-based certification under this standard, you are advised not to skim.

This section provides a high-level overview of the basic use cases for smart home Offerings and their primary functions.

Smart home Offerings are use-case driven but increasingly defined by integration standards (notably Matter and Thread for seamless cross-brand interoperability), local versus cloud execution models, and the physical or functional domain they serve. Categories frequently overlap; a single Offering may belong to multiple groups.

Functional Grouping
For higher-level analysis, every category in this section can be mapped into one of three primary groups: Devices, Integration and Control Software, and AI Offerings.

3.1. Security & Surveillance

3.3. Climate & Energy Management

3.3. Home Automation & Control

3.4. Entertainment & Media

3.5. Appliances & Kitchen Tech

3.6. Health & Wellness

3.7. Gardening & Outdoor

3.8. Voice & Communication

3.9. Specialized Offerings

3.10. Integration & Ecosystems

3.11. Home Safety

3.12. Smart Cleaning & Maintenance

3.13. Connectivity & Infrastructure

3.14. Energy & Grid Integration


Contents

Section 4. Privacy Concerns and Mitigation

This section provides a high-level overview of the primary privacy risks associated with smart home Offerings and recommended mitigation strategies.

Across all categories, the core privacy risks involve data collection, unauthorized access, third-party sharing, inference/profiling attacks, and long-term data retention. The most effective mitigations prioritize local processing, data minimization, strong authentication, regular updates, network segmentation, encryption, and explicit user consent.

4.1. Security & Surveillance

Privacy Concerns: Cameras, locks, and sensors constantly collect video, audio, and usage data (often stored in the cloud); smart locks and sensors can reveal occupancy patterns and home/away routines; unauthorized access via weak credentials, unpatched firmware, or breaches; third-party sharing or sale of data; biometric data (facial/fingerprint) is especially sensitive if compromised.

Mitigation Measures:

4.2. Climate & Energy Management

Privacy Concerns: Thermostats, HVAC systems, and energy monitors reveal detailed occupancy, sleep, and lifestyle patterns; geofencing or motion data can infer location and routines; granular energy usage can be exploited for behavioral profiling or shared with utilities.

Mitigation Measures:

4.4. Home Automation & Control

Privacy Concerns: Cloud-connected hubs create single points of failure or broad surveillance; automation logs and activity histories may be stored remotely; voice commands processed through hubs can be recorded.

Mitigation Measures:

4.4. Entertainment & Media

Privacy Concerns: Voice assistants and smart speakers may record and transmit conversations; streaming Offerings and smart TVs often use Automatic Content Recognition (ACR) to identify viewed content for profiling or advertising; usage data may be shared with third parties.

Mitigation Measures:

4.5. Appliances & Kitchen Tech

Privacy Concerns: Refrigerators, ovens, and washers track usage patterns (including inventory, cooking habits, and routines); some models include internal cameras; remote access increases risk of unauthorized control or data exfiltration.

Mitigation Measures:

4.6. Health & Wellness

Privacy Concerns: Air purifiers, scales, sleep tech, and sensors collect sensitive health and biometric metrics; data may be shared with third parties, apps, or cloud services (even if not regulated under HIPAA); movement patterns can infer intimate routines.

Mitigation Measures:

4.7. Gardening & Outdoor

Privacy Concerns: Outdoor cameras and sensors capture activity and property boundaries; weather-aware or utility-linked systems may share location/usage data; outdoor Offerings face higher network exposure.

Mitigation Measures:

4.8. Voice & Communication

Privacy Concerns: Always-listening voice assistants can inadvertently (or deliberately) record conversations; voice logs may be retained indefinitely and used for training or profiling; Offerings can be compromised for eavesdropping.

Mitigation Measures:

4.9. Specialized Offerings

Privacy Concerns: Smart mirrors, beds/mattresses, biometric locks, and pet tech collect highly personal or intimate data (fitness metrics, sleep patterns, biometric identifiers); third-party integrations may expand data sharing.

Mitigation Measures:

4.10. Integration & Ecosystems

Privacy Concerns: Multi-platform ecosystems can aggregate and correlate data across components and brands; compromise of one account or component can expose the entire system; cross-component tracking is common.

Mitigation Measures:

4.11. Home Safety

Privacy Concerns: Smoke/CO detectors and environmental sensors send alerts that can reveal occupancy; integration with other systems may inadvertently expose location or activity data.

Mitigation Measures:

4.12. Smart Cleaning & Maintenance

Privacy Concerns: Robotic vacuums create detailed floor plans and maps of the home layout; some include cameras for navigation or monitoring; mapping data may be stored or shared.

Mitigation Measures:

4.14. Connectivity & Infrastructure

Privacy Concerns: Routers, mesh systems, and network components can expose the entire smart home if poorly secured; telemetry, DNS queries, or unencrypted traffic may leak metadata; network fingerprinting can reveal component types and usage.

Mitigation Measures:

4.14. Energy & Grid Integration

Privacy Concerns: EV chargers, solar inverters, smart meters, and home energy systems generate highly granular usage data that can reveal driving patterns, occupancy, appliance use, and lifestyle habits; data may be shared with utilities or grid operators.

Mitigation Measures:


Contents

Section 5. Privacy Controls for Components – Mitigation Challenges

This section examines existing standards, certifications, and programs that address aspects of smart-home privacy and security. Several of these efforts are excellent within their intended scope. In particular, Home Assistant and the "Works with Home Assistant" program have set a high bar for local control, open interoperability, and reducing unnecessary cloud dependency. PrivateEZ™is designed to complement, not replace, such initiatives. It focuses on a different layer: a standardized, independently verifiable set of privacy and security controls together with a simple, consumer-facing assurance signal that also delivers critical component information. The analysis that follows is intended only to clarify where existing work ends in scope, and where the specific requirements of this Standard require more.

This section outlines the difficulties encountered by both of our primary groups: ordinary home owners and employers, when attempting to mitigate privacy concerns using existing standards. As will be shown, even qualified information security professionals with access to all existing standards and accustomed to reading them, will have a real job just analysing the coverage. It demonstrates the issues by analysis of those other standards and concludes that a new approach is necessary to meet the goals of this standard.

We start by identifying what types of concerns may apply to which types of components. How does a Home Resident even know what kind of information is likely to be exposed with a particular component? How can that resident decide if the exposure is acceptable or not, without even knowing what the potential exposures are? If the resident hires an installer, how does the installer know how to configure a component, or even know if it is configurable, or know if the resident would want it at all, absent a definitive list of potential exposure? Where does an installer or other advisor even start?

The first step then, is to identify the potential concerns. Until you know that, you can’t even start. We have previously identified and categorized smart home components in Section 2, reducing the enormous number of smart components down to a few reasonable categories. We then listed the privacy concerns for each category in Section 4.

Now we can make a further reduction, by organizing the categories and concerns into a usable matrix, which we have done in Table 5.A. This is a critical step in simplification. Without it, there would be little hope of achieving a usable standard at all:

TABLE 5.A - Privacy Implication Matrix for components

Component Category (from Section 2) Privacy Implications? (from Section 4)
Security & SurveillanceYes (video/audio, occupancy, biometrics)
Climate & Energy ManagementYes (occupancy patterns, usage data)
Home Automation & ControlYes (automation logs, component control)
Entertainment & MediaYes (voice, viewing habits, ACR)
Appliances & Kitchen TechYes (usage patterns, inventory)
Health & WellnessYes (sensitive health/biometric data)
Gardening & OutdoorYes (location/activity data)
Voice & CommunicationYes (voice recordings, conversations)
Specialized componentsYes (highly personal data)
Home SafetyYes (occupancy alerts)
Smart Cleaning & MaintenanceYes (floor plans, mapping)
Connectivity & InfrastructureYes (network metadata)
Energy & Grid IntegrationYes (granular usage & lifestyle data)

That helps somewhat. It makes it easier to align the issues with certain types of components. So, let’s assume that a Home Resident has this information, and can decide which of the concerns are acceptable and which are not. Let’s further assume there are at least some product options to choose from. How would one choose between those options? How does a homeowner know if a specific bathroom mirror addresses the concerns? Assuming it does address the concerns, does it do so by default, out of the box, or does it require specific configuration? If that answer is configuration, does the configuration address the concern in all possible deployment scenarios, or only in some? This is where it might be hoped that there is some standard or formal framework that could make it easy to identify and rank your options.

WARNING: We are about to embark on a high-level exploration of the various existing standards. It is tedious and you may want to skip ahead, but it is important to document the steps we took to get to our final control list, and this is how we did it.

There are many standards/frameworks that are either directly relevant to smart-home privacy & security or are commonly perceived as relevant by vendors, regulators, installers, or consumers.

Do any of them cover what is needed, and how well do they relate to physical components in a smart home? That question calls for another matrix, which we provide in Table 5.B:

TABLE 5.B – Standards and Certifications Overview

Category Standard or Framework Positives Negatives
IoT components & Ecosystem StandardsMatter ComplianceProvides a solid foundation for security through encryption, authentication, and component attestation.Privacy protections are limited and depend heavily on the controlling ecosystem.
IoT component & Ecosystem StandardsWorks with Home AssistantExcellent at promoting local control, reducing cloud dependency, and enabling open, interoperable, privacy-respecting smart home architectures.Scope note (not really a "Negatives"): Focuses on local operation and interoperability. It does not define a formal, independently verifiable set of privacy and security controls or a consumer-facing assurance mark beyond the “Works with Home Assistant” designation itself.
IoT component & Ecosystem StandardsUL 2900Focuses on cybersecurity testing for vulnerabilities and secure development.Does not directly address data privacy or consent.
IoT component & Ecosystem StandardsETSI EN 303 645The leading baseline standard for consumer IoT, with strong provisions for personal data protection, secure updates, and user data deletion.Compliance is voluntary in most markets.
IoT component & Ecosystem StandardsNIST IR 8425Defines recommended cybersecurity outcomes for consumer IoT, including privacy considerations.It is guidance only, not a certification standard.
IoT component & Ecosystem StandardsCalifornia SB-327First U.S. state law specifically for connected components; requires “reasonable security features” and no universal default passwords.Very high-level with no detailed privacy requirements. California-only.
IoT component & Ecosystem StandardsISO/IEC 27402:2023International baseline standard specifically covering both security and privacy for IoT Offerings.Relatively new (2023); adoption still growing.
IoT component & Ecosystem StandardsISO/IEC 27403:2024Specifically tailored to home automation and smart-home systems.Guidance-focused rather than mandatory certification.
IoT component & Ecosystem StandardsioXt Alliance CertificationIndustry-led global IoT security certification program.Voluntary; focuses more on security than comprehensive privacy controls.
IoT component & Ecosystem StandardsOWASP IoT Top 10Widely recognized list of the most critical security and privacy risks specific to IoT components.Not a formal standard or certification — it is a risk-awareness and testing guide only.
IoT component & Ecosystem StandardsUK PSTI RegulationsMandatory UK requirements for consumer connectable products. Strongly aligned with ETSI EN 303 645.UK-only; focuses mainly on baseline security rather than full privacy-by-design.
Organizational / Management System StandardsISO 27001Internationally recognized Information Security Management System (ISMS) standard.General-purpose organizational standard, not Offering-specific.
Organizational / Management System StandardsSOC 2Strong focus on security, confidentiality, and privacy controls for service organizations.Applies only to service providers, not to consumer IoT component vendors.
Organizational / Management System StandardsISO/IEC 27701Extension of ISO 27001 specifically for privacy.Still an organizational standard, not component-level.
Legal / Regulatory FrameworksHIPAAProvides good privacy protection within medical establishments.Does not apply to consumer medical or health smart-home components.
Legal / Regulatory FrameworksCCPA/CPRAGives California residents strong rights over their personal information.State law only; applies only to large businesses.
Legal / Regulatory FrameworksGDPRComprehensive, extraterritorial privacy law.Broad legal regulation, not a technical component standard.
Legal / Regulatory FrameworksEU Cyber Resilience Act (CRA)Upcoming comprehensive EU regulation for cybersecurity of products with digital elements.Not yet fully in force.

All of these frameworks/standards have shortcomings for our purposes. Before we do deeper research, it makes sense to ask a very practical question: How would a consumer or installer even know that any component was in compliance with any of these standards?

Many standards are not written with the end user in mind, so let’s see what it takes to actually use any of these standards. We did that in Table 5.C.

TABLE 5.C – Privacy Standards Compliance Verification

Standard or Framework Verification Method
Matter ComplianceOfficial Matter logo on the component packaging, label, or retailer/product page.
Works with Home AssistantOfficial “Works with Home Assistant” badge on packaging, website, or product listings.
UL 2900UL certification mark on the component or packaging.
ETSI EN 303 645Vendor’s explicit statement of compliance in the user manual, product datasheet, or website.
NIST IR 8425No formal certification program. Vendors may voluntarily claim alignment in documentation.
California SB-327No official logo. Look for a vendor statement of compliance in documentation.
ISO/IEC 27402:2023Vendors may claim conformance in technical datasheets or security whitepapers.
ISO/IEC 27403:2024Vendors may reference it in marketing or documentation.
ioXt Alliance CertificationioXt SmartCert logo on packaging or component.
OWASP IoT Top 10Not a certifiable standard. Vendors may claim they addressed the risks in documentation.
UK PSTI RegulationsRequired Statement of Compliance (SoC) in the user manual or on the website.
ISO 27001ISO 27001 certification logo or certificate number on the vendor’s website.
SOC 2SOC 2 Type 2 report or attestation letter on the vendor’s website.
ISO/IEC 27701ISO 27701 certification mark (often combined with 27001).
HIPAAGenerally does NOT apply to consumer smart-home components.
CCPA/CPRACheck the vendor’s privacy policy for a clear statement of compliance.
GDPRReview the vendor’s privacy policy for explicit GDPR compliance language.
EU Cyber Resilience Act (CRA)CE marking plus an EU Declaration of Conformity.

It is now quite clear that many of these standards, while excellent for other purposes, are simply too cumbersome to be useful to a consumer. Table 5.D shows what remains when we include only the standards that are component-focused, reasonably verifiable by consumers or installers, and not limited to a single jurisdiction.

Table 5.D

Standard or Framework Verification Method
Matter ComplianceOfficial Matter logo on the component packaging, label, or retailer/product page.
Works with Home AssistantOfficial “Works with Home Assistant” badge on packaging, website, or product listings.
UL 2900UL certification mark on the component or packaging.
ETSI EN 303 645Vendor’s explicit statement of compliance in documentation.
ISO/IEC 27402:2023Vendors may claim conformance in technical datasheets or security whitepapers.
ISO/IEC 27403:2024Vendors may reference it in marketing or documentation.
ioXt Alliance CertificationioXt SmartCert logo on packaging or component.
OWASP IoT Top 10Vendors may claim they addressed the risks in documentation.

It’s a shorter list, but some still require that a user seek out a vendor’s claims. Let’s list only those standards that enforce a true standardized, recognizable notification scheme. In Table 5.E, anything that relies primarily on a vendor’s self-declared statement in non-stadardized locations has been eliminated.

This leaves just four standards — the only ones that give consumers and installers a quick, reliable way to verify compliance without searching for and digging through documentation.

TABLE 5.E – Standards with Enforced Notification Schemes

Standard or Framework Verification Method
Matter ComplianceOfficial Matter logo on the component packaging, label, or retailer/product page.
Works with Home AssistantOfficial “Works with Home Assistant” badge on packaging, website, or product listings.
UL 2900UL certification mark on the component or packaging.
ioXt Alliance CertificationioXt SmartCert logo on packaging or component.

This is now a practical shortlist. Time for another matrix. Table 5.F shows coverage of each privacy concern from Table 5.A by these four standards.

TABLE 5.F – Privacy Coverage Matrix

Component Category Primary Privacy Concerns Matter Home Assistant UL 2900 ioXt
Security & SurveillanceVideo/audio, occupancy patterns, biometricsPartiallyPartiallyPartiallyPartially
Climate & Energy ManagementOccupancy patterns, usage dataPartiallyFullyNot at allPartially
Home Automation & ControlAutomation logs, component controlPartiallyFullyPartiallyPartially
Entertainment & MediaVoice recordings, viewing habits, ACRPartiallyFullyNot at allPartially
Appliances & Kitchen TechUsage patterns, inventoryPartiallyFullyPartiallyPartially
Health & WellnessSensitive health/biometric dataPartiallyPartiallyNot at allPartially
Gardening & OutdoorLocation/activity dataPartiallyPartiallyPartiallyPartially
Voice & CommunicationVoice recordings, conversationsPartiallyFullyNot at allPartially
Specialized componentsHighly personal/intimate dataPartiallyPartiallyNot at allPartially
Home SafetyOccupancy alertsPartiallyPartiallyNot at allPartially
Smart Cleaning & MaintenanceFloor plans, mapping dataPartiallyFullyPartiallyPartially
Connectivity & InfrastructureNetwork metadata, component fingerprintingPartiallyFullyPartiallyPartially
Energy & Grid IntegrationGranular usage & lifestyle dataPartiallyFullyNot at allPartially

Home Assistant and the “Works with Home Assistant” program excel at what they were designed to do: enabling local control, reducing unnecessary cloud dependency, and giving users powerful, open tools for privacy-respecting automation. That program is the closest to what we need and the best standard for our purposes.

The last, and real elimination question as it turns out, is this one: How many of the standards that remain allow easy access to configuration information in a standardized location? Answer: 0.

It is now clear that even the standard with the most overlap was designed for different purposes. Further, even all of them together can not fully address our full, envisioned scope. It is not possible to use even a combination of existing standards to arrive at full coverage as we envision it. We have no objection to doing so. When we started, we hoped we might. We now know there is no such combination.

That is why we decided that we will not rely on other standards, as we orginally thought we might. We recognize their value and may even cite them, but they were not written for an entire ecosystem of home owners, employers, component vendors, installers of smart home components and other related professions, auditors and facilities. All of these participants either supply or need access to component information, and there is simply no existing solution to do it.

What we need

Any component intended for smart home use should employ more than just a trust mark that indicates its potential for privacy. Ideally, it should also readily expose the information required for decision making around privacy issues, and for the correct implementation of those decisions.

In other words, it should be easy to know the issues, easy to know what the component can do, and easy to know how to do it. We actually have a good start already: We have listed the privacy concerns in Section 5.

Now, in 5.1, we get some controls around those concerns. These controls are designed to support certification under the incremental rating system defined in the Certification Policy.

5.1 Core Privacy Controls for Smart Home components

5.1.1. Strong Authentication

Any component that supports remote or account-based administrative access must support two-factor authentication (2FA) and must not allow default or easily guessable passwords.

Components that are configurable only over the local network must require a strong component-specific PIN or equivalent local authentication for initial setup and any subsequent configuration changes.

Components with no administrative interface at all are exempt from this requirement.

5.1.2. Current Firmware

The component must support automatic security updates. Automatic updates must be enabled by default.

If automatic updates are not enabled by default, the PrivateEZ™ compliance Manual must include a specific, step-by-step reference showing exactly how the user can enable them.

All firmware and software updates must be cryptographically signed and verified by the component before installation. The component must reject any update that cannot be verified.

Updates must not re-enable any sensor, feature, or data collection capability that the user has previously disabled through physical or software controls, unless the user explicitly re-enables it after the update.

In all cases, the component must also provide clear instructions on how to check for, download, and apply all available security updates.

5.1.3. Local-First Operation

All core functions — including scheduling, automation, basic operation, and any user-initiated commands — must continue to work fully even when the component has no internet connection and the vendor’s cloud service is completely unavailable.

Occasional or optional use of the cloud is permitted only when explicitly enabled by the user.

5.1.4. Data Minimization

The component may collect or transmit only data that is strictly necessary for its documented primary functions (as stated in the product’s marketing materials and in the PrivateEZ™ compliance Manual).

The vendor must include in the PrivateEZ™ compliance Manual a complete data inventory table that lists every type of data the component collects, stores, or transmits. For each data element the table must state: - the specific primary function it supports, and - a clear justification of why that data element is necessary for that function.

All sensors, cameras, microphones, telemetry, analytics, diagnostic, or any other data-collection features that are not required for the component’s documented primary functions must be disabled by default. Any optional or secondary data collection requires explicit user opt-in before it can be enabled.

Voice Command and Wake Word Logging
Any component that uses voice commands or a wake word must clearly disclose in the PrivateEZ™ compliance Manual whether audio is captured or retained before the wake word is detected. If pre-wake-word audio is captured or retained, the manual must describe what is captured, how long it is retained, and how the user can disable this behavior.

Default Data Retention
The component must define and apply reasonable default data retention periods. Data must not be retained longer than necessary for the component’s documented primary function unless the user has explicitly opted in to longer retention. The PrivateEZ™ compliance Manual must state the default retention period for each category of data collected.

5.1.5. User-Controlled Data Sharing

Any sharing of data — including data listed in the data inventory table in the PrivateEZ™ compliance Manual — with third parties, cloud services, or any external entity requires explicit, granular user opt-in before it can occur.

The PrivateEZ™ compliance Manual must clearly describe, for each data element in the inventory table: - whether and with whom that data may be shared, - the exact purpose of the sharing, and - the step-by-step process (with page or section reference) by which the user can review, grant, or revoke permission for that sharing at any time.

All data sharing must be disabled by default until the user explicitly enables it.

5.1.6. Physical and Environmental Privacy Controls

Any component that captures audio, video, static images, voice-prints, or any biometric or behavioral data (including but not limited to gait, heart rate patterns, sleep patterns, or other inferred behavioral profiles), or environmental/biochemical data (including olfactory/scent data, volatile organic compounds (VOCs), chemical signatures, or any other air, water, or environmental sampling) must either:

  1. provide an obvious and easily accessible physical method (button, switch, sliding cover, lens cap, or equivalent) to disable the sensor(s), or
  2. clearly disclose in the PrivateEZ™ compliance Manual that no reliable built-in physical disablement method exists (due to the component’s design or typical installation location). In this case, the manual must include a specific reference (page number, section number, or step number) that details:

5.1.7. Clear Activity Indicators

Any component that captures audio, video, static images, voice-prints, biometric or behavioral data, or environmental/biochemical data (including olfactory/scent data, volatile organic compounds (VOCs), chemical signatures, or any other air, water, or environmental sampling) must either:

  1. Provide a clear, visible indicator (such as an LED, on-screen status, or equivalent) that is active whenever the sensor(s) is actively collecting data, or
  2. Clearly disclose in the PrivateEZ™ compliance Manual that no reliable built-in activity indicator exists (due to the component’s design or intended purpose). In this case, the manual must include a specific reference (page number, section number, or step number) that details:

5.1.8. Encryption of Data

All data transmitted by the component must be encrypted in transit using current industry-standard cryptographic methods.

Any user data or configuration data stored on the component must be encrypted at rest using industry-standard methods where technically feasible. If at-rest encryption is not implemented for any data element listed in the data inventory table, the PrivateEZ™ compliance Manual must include a specific reference (page number, section number, or step number) that discloses this limitation and describes the component’s storage practices and any compensating controls in place.

5.1.9. Secure Decommissioning

The component must support a complete, one-step factory reset that permanently deletes all user data, credentials, network settings, and configuration.

The PrivateEZ™ compliance Manual must include a specific reference (page number, section number, or step number) that provides clear, step-by-step instructions for performing the factory reset and any recommended post-reset verification steps to confirm that all personal data has been removed.


5.2 PrivateEZ™ compliance Checklist

The entity must complete this checklist for every component submitted for PrivateEZ™certification (Offering). For each control, enter one of the following in the Default Compliance column: Yes, No, or Partial.

If the answer is No or Partial, the entity must provide a precise reference in the PrivateEZ™ compliance Manual column (page number, section number, or step number) showing exactly where the user or installer can find the relevant instructions or compensating controls.

Control Requirement (Summary) Default Compliance Reference in PrivateEZ™ compliance Manual (required if No or Partial) Entity Notes
5.1.1Strong Authentication
5.1.2Current Firmware (automatic updates + integrity + no re-enablement of disabled features)
5.1.3Local-First Operation
5.1.4Data Minimization (complete data inventory + retention periods + wake word logging controls)
5.1.5User-Controlled Data Sharing
5.1.6Physical and Environmental Privacy Controls (including voice-prints and biometric/behavioral data)
5.1.7Clear Activity Indicators
5.1.8Encryption of Data
5.1.9Secure Decommissioning

The PrivateEZ™Checklist must be presented using the exact template above (or the corresponding database entries) to ensure that installers and consumers receive all expected information in a consistent format.

5.3 The Packaging and Trust Mark

The checklist and manual ensure that every privacy concern is considered and every related exception or special approach is addressed in a standard format.

The last step is standardizing the location of the regisration data, by linking directly from the Badge on the packaging and promotional material. The Badge and QR code are integral components of the standard and described elsewhere. The specific certification requirements associated with each rating level are defined in the Certification Policy and the use of the Badge itself is governed by the Trademark License Agreeement.

5.4 Audit Controls for components

Audit controls for components are described in the Certification Policy.


Contents

Section 6. Facilities Privacy Concerns and Mitigation

This section provides a high-level overview of the primary privacy risks associated with smart home related facilities and recommended mitigation strategies.

Across all facility categories, the core privacy risks involve data collection and retention, unauthorized access or interception, third-party sharing, inference/profiling attacks, and long-term data remanence. The most effective mitigations prioritize data minimization, encryption in transit and at rest, strict access controls, local/on-premise processing where possible, and explicit contractual prohibitions on secondary use. Where feasible, privacy decisions should favor facilities that support end-to-end encryption, zero-knowledge architectures, or verifiable deletion policies.

6.1. Connectivity

Privacy Concerns: ISPs and telco infrastructure can inspect traffic metadata or perform deep packet inspection, revealing occupancy patterns, component types, and behavioral routines; CDNs log IP-based update requests that create indirect usage fingerprints.

Mitigation Measures:

6.2. Compute & Storage

Privacy Concerns: Cloud providers and data centers store the majority of user-generated smart home data; edge nodes and on-premises servers may still sync sensitive streams; any external processing creates a copy of private data outside the home.

Mitigation Measures:

6.3. Utilities & Public Infrastructure

Privacy Concerns: Smart-grid operators and municipal systems receive granular energy and status data that reveals detailed home occupancy and routines; bidirectional grid communication expands the attack surface.

Mitigation Measures:

6.4. Manufacturing, Supply Chain & Distribution

Privacy Concerns: Minimal direct impact once components are deployed, but insecure firmware or pre-loaded telemetry code can create persistent privacy risks after installation.

Mitigation Measures:

6.5. Testing, Certification & Compliance

Privacy Concerns: Negligible direct risk to deployed homes; these facilities operate pre-market.

Mitigation Measures:

6.6. Security, Monitoring & Incident Response

Privacy Concerns: SOCs and identity services receive real-time logs and alerts from homes; key management services hold credentials that could expose entire households if breached.

Mitigation Measures:

6.7. Services & Support

Privacy Concerns: Third-party AI/analytics providers and field technicians have direct or indirect access to raw home data; emergency routing can inadvertently disclose occupancy.

Mitigation Measures:

6.8. End-of-life & Environmental

Privacy Concerns: Improper data wiping before disposal can leave personal data (videos, logs, credentials) recoverable.

Mitigation Measures:


Contents

Section 7. Facilities Controls

This section defines the core privacy controls for facilities, including the Facility Privacy Controls Checklist and the internal Facility Auditor Checklist.

Facilities present different challenges from components. Facilities are not directly observable by Home Residents, and unlike products that may be privacy-focused, facilities are often general-purpose or have conflicting commercial influences.

These are good reasons to treat facilities differently, but we retain our basic approach: certification begins with an attestation from facilities that want to be registered and certified. What differs is the control list and supporting documentation, which is necessarily different but still aligns with the incremental rating system defined in the Certification Policy.

7.1 Core Facility Privacy Controls

The following controls apply to facilities.

7.1.1. Data Minimization

Facilities may collect, process, store, or transmit only data that is strictly necessary for the documented primary functions supporting smart home components.

The facility must include in the PrivateEZ™ compliance Manual a complete data inventory table that lists every category of smart-home-derived data the facility collects, stores, or processes. For each data element the table must state the specific primary function it supports and a clear justification of why that data element is necessary.

All secondary collection, analytics, profiling, or telemetry features not required for the primary function must be disabled by default.

7.1.2. Encryption of Data

All data transmitted to or from the facility must be encrypted in transit using current industry-standard cryptographic methods.

Any smart-home-derived data stored by the facility must be encrypted at rest using industry-standard methods. If at-rest encryption is not implemented for any data element, the PrivateEZ™ compliance Manual must disclose this limitation and describe any compensating controls.

7.1.3. Strong Access Controls

Any administrative, diagnostic, or data-access interface must require multi-factor authentication and must not allow default or easily guessable credentials. Access must follow the principle of least privilege and must be logged with immutable audit trails.

7.1.4. Minimal and Transparent Logging

Facilities must minimize logging of smart-home-derived data to only what is strictly necessary for service delivery, security, or regulatory compliance. Logs must not create behavioral profiles or occupancy fingerprints beyond the documented primary function.

All non-essential logging must be disabled by default.

7.1.5. User-Controlled Data Processing and Sharing

Any processing, sharing, or transfer of smart-home-derived data with third parties, sub-processors, or external entities requires explicit, granular opt-in from the facility customer before it can occur. All such processing or sharing must be disabled by default.

7.1.6. Verifiable Data Deletion and Retention Limits

The facility must support complete, verifiable deletion of all smart-home-derived data upon request or at the end of the service relationship (including backups and replicas). Retention must be limited to the shortest period necessary for the primary function.

7.1.7. Support for Local-First or Zero-Knowledge Architectures

Where technically feasible, the facility should offer or support local/on-premise processing, end-to-end encryption, or zero-knowledge architectures. If such options are not available, the PrivateEZ™ compliance Manual must disclose the limitation and describe compensating controls.

7.1.8. Contractual Purpose Limitation and No Secondary Use

All contracts and data-processing agreements must explicitly prohibit secondary use, sale, behavioral profiling, or any use of smart-home-derived data beyond the documented primary function.

7.1.9. Privacy Impact Assessments and Audit Transparency

Facilities must conduct regular privacy impact assessments focused on smart-home data flows and must make summary results available to customers. Facilities must also support independent audits of their controls upon reasonable request.


7.2 PrivateEZ™ compliance Checklist (Facility Template)

Every facility submitted for PrivateEZ™certification must complete this checklist. For each control, enter Yes, No, or Partial in the Default Compliance column.

Control Requirement (Summary) Default Compliance Reference in Uploaded Support Manual Facility Notes
7.1.1 Data Minimization
7.1.2 Encryption of Data
7.1.3 Strong Access Controls
7.1.4 Minimal and Transparent Logging
7.1.5 User-Controlled Data Processing and Sharing
7.1.6 Verifiable Data Deletion and Retention Limits
7.1.7 Support for Local-First or Zero-Knowledge Architectures
7.1.8 Contractual Purpose Limitation and No Secondary Use
7.1.9 Privacy Impact Assessments and Audit Transparency

7.2.A PrivateEZ™ compliance Checklist (Fictitious Facility Example)

Facility Provider: Nexus Cloud, LLC
Facility/Service: Nexus SmartHome Cloud Platform
PrivateEZ™Registration Number: 9876543
Control Requirement (Summary) Default Compliance Reference in Uploaded Support Manual Facility Notes
7.1.1 Data Minimization Yes ✅ — Full inventory table provided
7.1.2 Encryption of Data Yes ✅ — TLS 1.3 + AES-256
7.1.3 Strong Access Controls Yes ✅ — MFA + least privilege enforced
7.1.4 Minimal and Transparent Logging Partial ⚠️ Nexus Operational Logging Policy, Page 14 Behavioral logging disabled by default
7.1.5 User-Controlled Data Processing and Sharing Yes ✅ — Granular opt-in required
7.1.6 Verifiable Data Deletion and Retention Limits Yes ✅ — 90-day max retention; verifiable deletion supported
7.1.7 Support for Local-First or Zero-Knowledge Architectures Partial ⚠️ Nexus Architecture Guide, Page 22 Zero-knowledge option available via customer-managed keys
7.1.8 Contractual Purpose Limitation and No Secondary Use Yes ✅ — Explicit prohibition in DPA
7.1.9 Privacy Impact Assessments and Audit Transparency Yes ✅ — Annual PIA + SOC 2 Type II available

7.3 Audit Controls for Facilities

Unlike components, Home Residents normally have no direct visibility into their data once it leaves the home and enters a facility. This makes independent auditing especially important.

Facility audits are more complex than component audits. To keep costs manageable while maintaining rigor, facilities are required to provide detailed evidence references for every control as part of the internal auditor checklist. This checklist and use is defined in the Certification Policy.


Contents

Section 8. Certifying the Home Itself

It may seem counterintuitive to certify a home — which requires collecting data about that home — when the entire focus of this standard is privacy in the home. However, there are valid use cases for doing so, including:

We begin with real estate transactions, as the discussion of component inventory provides the foundation needed for both real estate and employer use cases.

8.1 Real Estate Transactions and Fixture vs Chattel

In the U.S., smart home components are classified as either real property (fixtures) or personal property (chattel) in real estate transactions. This classification is based on longstanding common-law principles, with some variation by state.

Key Distinction

The Fixture Test (Used in Most States)

Courts generally apply a three-part test to determine whether an item is a fixture:

  1. Mode of annexation — How permanently is it attached?
  2. Adaptation to the property — Is it customized or essential to the home’s use?
  3. Intention of the party who installed it — Did the owner intend it to remain permanently with the house?

Smart home technology creates many gray areas, as even hardwired devices can be disputed depending on removal damage and account linkage.

Practical Reality in Transactions

The contract controls everything. Sellers and buyers should explicitly list which smart home components stay with the home, which are excluded, and confirm that all associated accounts, apps, passwords, and hubs will be transferred at closing.

8.2 Home Inventory Attestation

A Home Inventory Attestation creates a verifiable list of installed smart home components and classifies them as fixtures or chattels. This supports clean transfer during real estate transactions or changes in occupancy. Homes receive a certification rating as defined in the Certification Policy.

8.3 Full Home Certification

A Full Home Certification confirms that the home as a whole meets the privacy controls defined in this Standard and receives a certification rating as defined in the Certification Policy.

8.4 Landlord / Tenant Considerations

Smart home components installed by tenants generally remain the tenant’s personal property (chattel) unless they become permanent fixtures. Tenants are typically allowed to remove their installations at the end of the tenancy, provided removal causes no permanent damage to the property.

8.5 PrivateEZ™ WorkZone™ (for Employers)

Many employers require assurance that remote employees are taking reasonable steps to protect privacy and proprietary information. Employers should have a way to mitigate those concerns, without receiving excessive personal details about the home.

This standard addresses that need through a PrivateEZ™ WorkZone™ report, which provides basic, high-level assurances. The audit and resulting WorkZone™ report is performed either directly by the Certification Authority or by a PrivateEZ™ Certified Professional (WorkZone™ Auditor). The WorkZone™ report is simple, and does not include the component inventory or any detailed configuration information. Special rules for handling and distributing PrivateEZ™ WorkZone™ reports are defined in the Certification Policy.

The PrivateEZ™ WorkZone™ Report contains:

8.5.1 Scope of PrivateEZ™ WorkZone™ Audits

A PrivateEZ™ WorkZone™ audit shall not evaluate every smart-home component for full PrivateEZ™ compliance. The audit is limited to those components and systems that represent a realistic risk of compromise to the employer’s security posture (audio or visual capture of work-related activity, network pivot potential, or data-exfiltration paths).

The PrivateEZ™ WorkZone™ audit shall use the following prioritized risk-factor inventory to determine scope.

Critical Priority (Shall be evaluated if present in or within effective range of the primary workspace)

High / Medium Priority (Shall be evaluated if present in the same room or on the same network segment as work devices)

Low Priority / Generally Out of Scope

The following categories shall be excluded from a PrivateEZ™ WorkZone™ audit unless the device is physically located in the primary workspace and contains an unexpected camera or microphone:

8.5.2 PrivateEZ™ WorkZone™ Process

The Audit for PrivateEZ™ WorkZone™ shall take the following steps:

  1. Identify the primary remote-work location(s) with the Home Resident.
  2. Establish practical line-of-sight and audible range (approximately 15–20 feet for typical microphones).
  3. Inventory only the Critical and High/Medium Priority devices that fall inside those zones or share the work network segment.
  4. For each in-scope device, verify the presence of basic mitigations relevant to employer risk (physical mute capability, privacy zones or camera covers, local-only processing where available, network segmentation, and disabled always-listening features).
  5. Issue the PrivateEZ™ WorkZone™ report based solely on the in-scope items. Full-home PrivateEZ™ compliance is not required.

8.5.3 PrivateEZ™ WorkZone™ Training

The PrivateEZ™ WorkZone™ audit may optionally include Employee Awareness Training (EAT). When EAT is performed it shall be provided by the same WorkZone™ Auditor who performs the audit, at the time of the audit. The training will consist of an in person training, question and answer session and will cover the entirety of this section 8.5 with those in attendence. The WorkZone™ Auditor will be prepared to attest that the entire section 8.5 was covered, and collect the full names of those in attendence.

8.6 Home Certification Process

The process is designed so that Home Residents do not need authenticated access to the system. All authenticated activity is reserved for entities that have executed a Trademark Licensing Agreement (TMLA). The process is defined in the Certification Policy.

8.7 Sample Component Inventory

PrivateEZ™ Home Component Inventory
Home Address: 123 Privacy Lane, Anytown, USA 12345
Registration Date: 15 June 2026
Home Resident / Attestor: Jane Doe
PrivateEZ™Registration Number: HOME-478291
Certification Status: Inventory Attestation

Component Category Make / Model Location Wired / Wireless Fixture / Chattel Notes
Security Camera SecureCam Pro SCP-400 Front Door Wired Fixture Hardwired fixture
Smart Thermostat EcoTherm Elite Living Room Wired to HVAC Fixture Permanently installed
Smart Locks Keyless Entry XL All exterior doors Battery + wired deadbolt Chattel Removable
Voice Assistant Echo Hub Kitchen Wireless Chattel Portable

8.8 Sample PrivateEZ™ WorkZone™ Report

PrivateEZ™ WorkZone™ Report
Home Address: 123 Privacy Lane, Anytown, USA 12345
Auditor Firm: JT Enterprises
Auditor Full Name: Jill Turner, Certified Auditor #94Z0-63AD-340S
Audit Date: 20 June 2026
Standard: PrivateEZ™Privacy and Security Standard v1.3
Result: PASS – All applicable controls verified compliant
Employee Awareness Training Verified Attendance:
Jane Doe
John Doe

Auditor’s PrivateEZ™ Certification Mark (or Certification Authority Brand Mark):

8.9 Sample Full Home Certification Report

PrivateEZ™ Full Home Certification Report
Home Address: 123 Privacy Lane, Anytown, USA 12345
PrivateEZ™Registration Number: 94Z0-63AD-340S
Certification Date: 20 June 2026
Certification Valid Until: 20 June 2027
Auditor: Jill Turner, JT Enterprises

Certification Summary
All installed smart home components meet or exceed the controls defined in this Standard. The home operates with local-first operation enabled wherever technically feasible.

Auditor’s PrivateEZ™ Certification Mark (or Certification Authority Brand Mark):

Contents

Section 9. Knowledge-Based Certifications

We have now covered all of the Control Subjects previously introduced, except for Knowledge-Based certifications. There have been several cases in this standard that call for the use of certified professionals.

Knowledge-based certifications are intended to create a readily available pool of qualified professionals who understand this standard and can apply it in their respective fields.

The underlying and common requirement for all Knowledge-based certifications is knowledge of this standard, together with knowledge of a specific related field. All requirements are defined in the Certification Policy.


Contents

Section 10. Conclusion

We began this standard with observations of concern over smart home privacy from two primary groups: Home Residents and employers with remote workforces.

We demonstrated, with reference to multiple independent studies and surveys, that these concerns are real, growing, and span the entire political spectrum.

We suggested that political solutions are unlikely to be the most effective path forward, and that while existing standards and initiatives are valuable, they do not fully address the core requirements outlined in this document — particularly the need for timely, actionable information at the point of decision.

Instead, we developed a practical approach centered on standardized information delivery through a trust mark and QR code system, combined with clear, auditable controls. This standard introduces an incremental certification rating system (visually represented as 1 to 5 stars on the Badge) that applies across components, facilities, and homes, supported by Knowledge-Based certifications for the professionals who install, audit, and manage these systems.

Together with the Trademark Licensing Agreement and the associated certification processes, this framework represents our contribution to improving smart home privacy while enabling practical use cases in real estate transactions and remote work environments.

We began with a clear problem: the rapid proliferation of smart home technology, especially in conjuction with AI, has outpaced our ability to understand and control the privacy implications. This standard offers one coherent response — a framework built on transparent information delivery, measurable controls, and professional accountability. It is our contribution toward a future in which technology serves the home, rather than the home serving technology.