ARTICLE
10 December 2025

The Ghost Of Employees Past: The Data Breach Risks From User-Credential Management

SM
Sheppard, Mullin, Richter & Hampton LLP

Contributor

Businesses turn to Sheppard to deliver sophisticated counsel to help clients move ahead. With more than 1,200 lawyers located in 16 offices worldwide, our client-centered approach is grounded in nearly a century of building enduring relationships on trust and collaboration. Our broad and diversified practices serve global clients—from startups to Fortune 500 companies—at every stage of the business cycle, including high-stakes litigation, complex transactions, sophisticated financings and regulatory issues. With leading edge technologies and innovation behind our team, we pride ourselves on being a strategic partner to our clients.
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.
United States California Connecticut New York Privacy
Liisa M. Thomas’s articles from Sheppard, Mullin, Richter & Hampton LLP are most popular:
  • with readers working within the Consumer Industries industries
Sheppard, Mullin, Richter & Hampton LLP are most popular:
  • within Cannabis & Hemp and Insolvency/Bankruptcy/Re-Structuring topic(s)

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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

[View Source]

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More