All case studies

Where keeping it cost them

FTC / Illuminate Education

Ordered deletion of student data it did not need

A consent order made deletion a compliance term: the company must remove covered information it does not need and keep a retention schedule it can be held to.

Removed: the covered information it does not need in order to provide the products its customers contracted for, with a written retention schedule it can be held to.

Outcome: a final order, Docket No. C-4833, whose second section is titled “Mandated Deletion and Data Minimization”, carrying compliance reporting with it.

The FTC’s action against Illuminate Education over its handling of student records ended in a final order, Docket No. C-4833, whose second section is titled “Mandated Deletion and Data Minimization”: the company has to delete the covered information it does not need in order to provide the products its customers contracted for, and keep a written retention schedule it can be held to.

“You should delete this” stopped being advice the moment it became an order term with compliance reporting attached.

Source: FTC, Decision and Order in the Matter of Illuminate Education, Inc., Docket No. C-4833 (5 June 2026)