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Responsible VR

27 February 2020
Protect consumers in virtual reality
Security Privacy data

Photo: Hollandse Hoogte

VR- brillen uitgesneden
Virtual reality (VR) is about to become popular with the general public. To protect consumers against unwanted effects of VR, such as misuse of data, we propose four measures.




What is VR? 

Virtual reality (VR) is an immersive computer-generated three-dimensional, environment. Wearing VR headsets and using the accompanying accessories, users can move freely through this environment and interact with one another and objects. Facebook, Sony, Google, HTC, Microsoft and other tech giants have invested billions in this technology in recent years. As a result, VR has overcome many technical barriers and the devices now on the market are affordable and user-friendly enough and of good enough quality to be accessible to millions of people.

Virtual reality (VR) makes new digital experiences and forms of communication possible. It has been tested mainly in the professional world as a means of innovating transport, communication, education, healthcare, safety and product development. While the VR sector is excited about the potential of this new technology, there is less concern about its risks and the ethical issues surrounding its use by consumers. That is the focus of the present study. There has been little political or public debate, whether in the Netherlands or elsewhere, about VR technology (Kool et al., 2018) and very few VR-related policy measures, case law or ethical codes have emerged. What we do see is a growing list of academic publications addressing the key public and ethical issues involved. This study therefore analyses these publications and proposes a framework for organising their content. We summarise the most important ethical and public issues associated with VR in the consumer domain and note a growing challenge, as politicians continue to ignore VR despite the need to develop frameworks for integrating VR technology into society. We identify actions to resolve this dichotomy. Our study marks a starting point for an urgent public and political discussion of consumer use of VR in the Netherlands and Europe.

What’s new about VR?

While VR resembles existing media technology, for example gaming and social media, in that it can function as a communication platform that connects people, it differs from that technology in two important respects.
First of all, VR is an immersive technology that submerges users entirely in a computer-generated environment, making it impossible for them to interact physically, in real time, with their real-world environment. VR sets cut users’ senses off from the outside world. The sets make use of powerful computer simulations and headsets, headphones and gadgets to immerse users in a new, virtual world. The aim is to create a ‘sense of presence’, i.e. a subjective feeling on the part of users 
that they are actually inhabiting the computer-generated environment in the here and now.
Second, VR is an intimate technology in which sensors in the VR headset collect large volumes of personal biometric data. By tracking user motion, including users head and body movements, eye movements, facial expressions and gestures, the technology collects information on a person’s personality and preferences. Such biometric datasets can be used to create unique profiles of consumers, also known as ‘kinematic fingerprints’. The fingerprints, in turn, can be used to identify and analyse specific individuals, both in the VR environment and beyond, by combining them with data obtained in other environments.

Overview of public and ethical issues associated with VR

This study reveals that the immersive and intimate nature of VR raises a multitude of ethical and public issues, for example with regard to privacy, autonomy, physical and mental integrity, informed consent, and access to technology. We differentiate between four clusters of risks pertaining to VR: physical and mental risks, social risks, abuse of power, and legal risks (see Figure 1).


  1. With respect to physical and mental risks, there are serious questions about addiction and the long-term consequences of VR use. Some users experience a high level of emotional engagement with and even a disproportionate sense of attachment to virtual characters, virtual entities and the VR world. They run the risk of losing touch with reality, leading to feelings of confusion and loss of control because they cannot distinguish between real-world or familiar experiences and experiences in virtual reality.
  2. VR may also pose social risks. Like the internet and social media, the rise of VR may well change the way we interact with others. In extreme cases, this can lead to people becoming estranged from their social environment. The immersive nature of VR means that extreme content poses risks, such as in the case of sexual and/or aggressive images that could lead to inappropriate behaviour in the physical world. Whether murder and other behaviour that is unlawful in the physical world should be permitted in VR is a question that must be taken seriously in light of VR’s immersive nature. One telling sign is the increasing number of reports of sexual assault, defamation, stalking and other forms of threatening and aggressive behaviour in the virtual world (e.g. in online games).
  3. Abuse of power refers to the ability of developers and users to influence user behaviour by manipulating virtual worlds, objects and avatars without the user knowing or agreeing. User data (including personal data) can be manipulated or misappropriated for purposes of profit or political or other influence, undercutting personal autonomy, freedom from social control, freedom of choice and self-determination. This is particularly relevant because VR systems can collect all types of intimate biometric data from users, giving VR companies information on a person’s personality, behaviour and preferences. A related issue is that virtual spaces offer numerous opportunities for targeted advertising that keys into a person’s desires, preferences and choices on a direct and subconscious level. We also note that the tech giants are extending their current unique concentration of power. A small number of major tech companies are developing the hardware, software, content and infrastructure of the virtual world, leading to an unwelcome concentration of power. For example, there are no VR spaces outside the control of tech companies where people can interact without being observed.

VR represents a grey area in which several legal and legal-philosophical issues converge and this entails a number of legal risks. What does privacy mean in the virtual world? Can damage to virtual entities be equated with damage to real entities – and if so, to what extent? These issues must be clarified for the protection of users and their virtual possessions.

Physical and mental risks
Source: Rathenau Instituut

Regulating VR

As it seems that VR could be entering the consumer market on a massive scale in the coming years, and since the technology raises many public and ethical issues, we note a growing dichotomy between the lack of political interest in VR on the one hand and the need to develop frameworks for integrating this technology into society on the other.

The most fundamental question is to what extent VR should be seen and regulated as a biomedical technology. As computers, cameras, biometric sensors, VR headsets and the human body become ever more closely integrated, it is growing easier to influence individuals in real time without their noticing. Politicians and the authorities must respond to the development of intimate technology without delay and move to establish appropriate and effective frameworks for integrating VR into society. Politicians can do this by building on existing regulatory frameworks that deal with personal data protection and biomedical technology.


What is virtual reality?

Virtual reality (VR) is a three-dimensional, computer-generated environment in which users can immerse themselves. With the help of VR glasses and associated accessories, users can move freely through this computer-generated environment and interact with each other and objects. VR distinguishes itself from existing media technology in two important ways.

First of all, VR is an immersive technology that completely immerses users in a computer-generated environment. Real-time embodied physical interaction with the environment is possible. For this purpose, VR sets cut off the user's senses from the outside world.

Secondly, VR is an intimate technology that collects numerous biometric data via sensors in VR glasses, such as body movements and facial expressions. The collection of this biometric data creates a unique profile of a consumer. This is also referred to as a kinemetric fingerprint.

Why has the Rathenau Institute conducted research into virtual reality?

In recent years, technology giants have invested billions in virtual reality. As a result, technology has overcome many technical barriers and the devices that are now on the market in terms of price, quality and user-friendliness are within reach of a million people.

Scientists, technology journalists, but also the industry itself, are concerned about the use of VR by consumers. We see a growing number of scientific publications in which important social and ethical issues are raised. That is why the Rathenau Instituut has carried out an investigation into the issues associated with virtual reality for consumers.

How did the Rathenau Institute conduct this research?

We have conducted a systematic literature study. We investigated both scientific and so-called "gray" literature, such as news reports and journalistic articles. We have structured and analyzed this literature.

Why does the Rathenau Institute call for the protection of consumers in virtual reality?

Our research shows that the immersive and intimate nature of VR leads to a multitude of ethical and social issues, such as in the areas of privacy, autonomy, physical and mental integrity, informed consent and access to technology. Properly informing and protecting consumers about possible harmful effects of VR is therefore essential. In VR, people provide their most intimate data and become vulnerable to market parties, but also to other people. It is necessary to inform consumers about the personal and intimate data that they generate in VR and how this can infringe on their privacy and autonomy.

What measures does the Rathenau Institute propose to protect consumers?

Political and social attention are needed to protect consumers. There must be a debate about rights in the virtual world. Can you use someone else's face or body for your avatar? Can you grope or kill someone in VR? It must be clarified what existing regulation, such as privacy legislation and consumer law, means for VR. Information about and restrictions on the use of biometric data are desirable, as well as further research into the long-term effects of VR.



To curtail the public and personal risks posed by VR, we propose the following four measures:


  1. Launch a national/international debate on the ethics of VR
  2. Establish frameworks for integrating VR into society
  3. Inform and protect VR consumers properly
  4. Study the long-term effects of VR


  1. Launch a national/international debate on the ethics of VR. In addition to informing consumers, it is important to have a public and political debate on abuses of power and the physical, mental and social risks of VR. Over the past two years, there have been numerous attempts worldwide in scholarly, business, civil society and government circles to scrutinise the ethical aspects of and regulate social media, robotization, AI and other digital technologies. Debates on such new technologies not only raise public awareness of risks, but also lead to the development of normative frameworks that are then used and refined by those working in academia, industry, civil society organisations and government bodies. The specific issues surrounding VR will require much more public and political consideration worldwide in the years to come.
  2. Establish frameworks for integrating VR into society. There are various regulatory frameworks that can be applied to consumer use of VR, including privacy legislation and consumer law. It is important to clarify what such existing frameworks mean for VR and to what extent VR calls for specific adaptations, for example rules pertaining to the sharing of specific biometric data. Within the framework of competition law, governments must keep a close eye on the possibility of tech giants dominating the market and abusing market power, and ensure consumer protection. The fact that companies are now increasingly able to link up data streams, profile users in fine detail, and influence their behaviour makes it both necessary and urgent for them to shoulder the responsibility for secure data management and privacy and for user health and wellbeing. The most fundamental question is to what extent VR should be regulated as a biomedical technology as well as being subject to consumer law.
  3. Inform and protect VR consumers properly. Research suggests a long list of VR-related risks (see Figure 1). It is therefore essential to properly inform consumers about and protect them against the possible harmful effects of VR. Following the example of the medical sector, this could take the form of leaflets, professional guidance or information campaigns. VR users hand over their most intimate data and become vulnerable to commercial parties, but also to other people. Consumers need to be informed about the personal and intimate data they generate in VR and how this data can be used to infringe their privacy and autonomy. VR platforms are neither public nor private spaces; rather, they are markets in which money and data change hands. Both supply and demand are mediated not by a neutral platform but by a private facilitator that makes the rules. This comes down to a case of ‘information asymmetry’, with consumers not knowing exactly what happens to their personal data, even if they consent. Because certain data are so personal and intimate that they make the individual vulnerable to abuse, whether by governments, hackers, commercial parties or other users, legal restrictions should be imposed on the collection, combining and sharing of data in VR.
  4. Study the long-term effects of VR. Because consumer VR is a recent phenomenon, there is insufficient knowledge about its risks and virtually no understanding of its long-term effects. VR researchers have drawn attention to the many empirical questions related to VR that should be addressed in the short term. For example, what impact does immersion in VR have on users? Which VR experiences have disruptive and negative effects on users? As in the case of new drugs with cognitive side effects, longitudinal research is required to identify the long-term effects on different groups.

The absence of hard evidence concerning the possible secondary effects and harmful consequences of VR is currently slowing down its use in healthcare. meanwhile VR companies are increasingly marketing their applications as self- therapy products for which a medical prescription is not required, thus circumventing the expensive and time-consuming investigation process involved in marketing medical products. This study argues that the immersive and intimate nature of VR gives it intrinsic biomedical effects, even if they are unintended (side effects), and that its use may pose a variety of physical and mental risks, such as addiction, depersonalisation and dissociation. It is important for the scholarly community to do more research into the effects of VR and to identify its long-term risks.