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The Ghost of Employees Past: The Data Breach Risks from User-Credential Management

By Liisa Thomas, Kathryn Smith & Angela Banks* on December 3, 2025
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A recent settlement with an education service provider and three states – California, Connecticut, and New York – serves as a reminder to deactivate the credentials of departed employees. The case arose following a data breach suffered by Illuminate Education, which provides assessment software to K-12 school systems. As part of its services, the company stores sensitive details like students’ special education and accommodation needs.

In 2021, a hacker accessed the company’s network using the administrative-level credentials of a former employee. The hacker created new accounts and exfiltrated the personal information of millions of students. The states alleged that failing to turn off the credentials of the former employee directly led to the 2021 breach. This, they argued, was a violation of their respective student privacy laws and was an unfair trade practice.

To settle the matter, the company agreed to pay $5.1 million: California will receive $3,250,000, Connecticut $1,700,000, Connecticut, and $150,000 will go to New York. The company also agreed to modify its security measures. Among other things, it will create and maintain data inventories, as well as limit data retention periods. It will also strengthen its access control and authentication processes.

Putting it into Practice: Threat actors are using more sophisticated tools to identify vulnerabilities. This settlement serves as a reminder to establish a clear process for removing credentials of departing employees. Especially those who may have been systems administrators.

Photo of Liisa Thomas Liisa Thomas

Liisa Thomas, a partner based in the Chicago and London offices, is Leader of the firm’s Privacy and Cybersecurity Practice Group.

Read more about Liisa ThomasEmail
Photo of Kathryn Smith Kathryn Smith

Kathryn (“Katie”) Smith is an associate in the Intellectual Property Practice Group in the firm’s Chicago office and a member of the Privacy and Cybersecurity Team. She is certified by the International Association of Privacy Professionals (IAPP) for CIPP/US.

Read more about Kathryn SmithEmail
Photo of Angela Banks* Angela Banks*

Angela Banks is a Cybersecurity & Privacy Fellow in the firm’s Chicago office. 

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Eye On Privacy
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

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