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FTC Finalizes Order Against Illuminate Education for Student Data Breach

Illuminate Education Inc.June 5, 2026Federal Trade Commission

Consumers Affected

10,100,000

Summary

The FTC finalized a consent order against Illuminate Education Inc. for failing to secure students' personal data, leading to a breach affecting 10.1 million students. The order requires Illuminate to implement a data security program, delete unnecessary data, and limit data collection, but imposes no monetary penalty.

Remedy

Illuminate is prohibited from misrepresenting its data security and privacy practices and breach notification speed. It must delete unnecessary personal data, limit data collection to what is reasonably needed, adopt a data retention schedule, implement a comprehensive information security program, and notify the FTC if it reports a breach to other government entities.

InjunctionConsent DecreeCompliance ProgramData DeletionReporting Requirements

Contract Impact

In-house legal teams should review vendor agreements with education technology providers for data security obligations, breach notification timelines, data retention and deletion clauses, and representations about privacy and security. Specific focus should be on contracts with schools that include student data processing, ensuring they require prompt breach notification, data minimization, and a comprehensive security program. Also, contracts with third-party vendors that have access to student data should include security vulnerability remediation requirements and audit rights.

Contract Search Terms

data security programstudent data breach notificationdata retention schedulethird-party vendor security vulnerabilitiescloud-based database securitypersonal information deletionprivacy and security representationsbreach notification timelinedata minimization requirementhealth-related information

Laws Cited

FTC Act

Violation Types

Entity Details

Entity

Illuminate Education Inc.

Industry

Education

Official Sources

Source Evidence

Entity Name
"Illuminate Education Inc."
Consumers Affected
"10.1 million students"
Violation Types
"data security failures led to a major data breach"
Violation Types
"failed to notify schools about the breach in a timely manner"
Remedy Types
"implement a data security program, limit collection and retention of consumer data, and delete unnecessary data"
Document Urls
"https://www.ftc.gov/system/files/ftc_gov/pdf/2223105c4833illuminatefinalcomplaint.pdf"

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