On December 1, 2025, the Federal Trade Commission (FTC) approved a proposed complaint and order against Illuminate Education, Inc., an education technology provider requiring it to “to implement a data security program and delete unnecessary data to settle allegations that the company’s data security failures led to a major data breach, which allowed hackers to access the personal data of more than 10 million students.”

The FTC alleges that Illuminate “failed to deploy reasonable security measures to protect student data stored in cloud-based databases. These failures led to a major data breach.” According to the complaint, in late December 2021, a hacker used the credentials of a former employee to access Illuminate’s databases stored in the cloud.  The threat actor accessed information including students’ email addresses, mailing addresses, dates of birth, student records, and health information.

The FTC further alleges that Illuminate failed to notify school districts in a timely manner, as “it waited nearly two years to notify some school districts, comprising more than 380,000 students, about the data breach.”

The FTC’s proposed order includes:

  • Deleting personal information no longer needed to provide requested services;
  • Following a publicly available data retention schedule that details why information is collected and establishes a timeframe for its deletion;
  • Establishing and implementing a comprehensive information security program that protects the security, availability, confidentiality, and integrity of personal information it collects; and
  • Notifying the FTC if it has alerted another federal, state, or local government about a data breach involving consumers’ personal information.

There was no monetary settlement included in the proposed order. The FTC voted 2-0 to accept the proposed complaint and order for public comment.

Photo of Linn Foster Freedman Linn Foster Freedman

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her…

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law.  Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.