Leaked Active School Shooter Plans Revive Scrutiny of Ed Tech Privacy Pledge

A security lapse at a leading school safety company that exposed millions of sensitive records online — including districts’ active-shooter response plans, students’ medical records and court documents about child abuse — has revived criticism that an industry student privacy pledge fails to police bad actors.

In response to an inquiry by The 74, the nonprofit Future of Privacy Forum said last week it would review Raptor Technologies’ status as a Student Privacy Pledge signatory after a cybersecurity researcher found more than 4 million sensitive records maintained by the company were readily available without any encryption protection despite Raptor’s claims that it scrambles its data. 

“We are reviewing the details of Raptor Technologies’ leak to determine if the company has violated its Pledge commitments,” David Sallay, the Washington-based group’s director of youth and education privacy, said in a Jan. 24 statement. “A final decision about the company’s status as Pledge signatory, including, if applicable, potential referrals to the [Federal Trade Commission] and relevant State Attorneys General, is expected within 30 days.” 

Should the privacy forum choose to take action, Raptor would become just the second-ever education technology company to be removed from the pledge. 

Texas-based Raptor Technologies, which counts roughly 40% of U.S. school districts as its customers, offers an extensive suite of software designed to improve campus safety, including a tool that screens visitors’ government-issued identification cards against sex offender registries, a management system that helps school leaders prepare for and respond to emergencies, and a threat assessment tool that allows educators to report if they notice “something a bit odd about a student’s behavior” that they believe could become a safety risk. This means, according to a Raptor guide, that the company collects data on kids who appear ‘unkempt or hungry,” withdrawn from friends, to engage in self-harm, have poor concentration or struggle academically. 
Rather than keeping students safe, however, cybersecurity researcher Jeremiah Fowler said the widespread data breach threatened to put them in harm’s way. And as cybersecurity experts express concerns about digital vulnerabilities among education technology providers, they’ve criticized the Student Privacy Pledge for lackluster enforcement in lieu of regulations and minimum security standards. 

Fowler, a cybersecurity researcher at vnpMentor and a self-described “data breach hunter,” has been tracking down online vulnerabilities for a decade. The Raptor leak is “probably the most diverse set of documents I’ve ever seen in one database,” he said, including information about campus surveillance cameras that didn’t work, teen drug use and the gathering points where students were instructed to meet in the event of a school shooting. 

vpnMentor notified Raptor of the security lapse in December and Fowler said the company was responsive and worked quickly to fix the problem. The breach wasn’t the result of a hack and there’s no evidence that the information has fallen into the hands of threat actors, though Fowler wasn’t the only researcher who stumbled onto the documents in the last several months. 

The situation could have grown far more dire without Fowler’s audit. 

“The real danger would be having the game plan of what to do when there is a situation,” like an active shooting, Fowler said in an interview with The 74. “It’s like playing in the Super Bowl and giving the other team all of your playbooks and then you’re like, ‘Hey, how did we lose?’”

David Rogers, Raptor’s chief marketing officer, said last week the company is conducting an investigation to determine the scope of the breached data to ensure “that any individuals whose personal information could have been affected are appropriately notified.” 

“Our security protocols are rigorously tested, and in light of recent events, we are committed to further enhancing our systems,” Rogers said in a statement. “We take this matter incredibly seriously and will remain vigilant, including by monitoring the web for any evidence that any data that has been in our possession is being misused.” 

‘Maybe this is a pattern’

Raptor is currently among more than 400 companies that signed the Student Privacy Pledge, a self-regulatory effort designed to ensure education technology vendors are ethical stewards of the sensitive information they collect about children. 

Raptor and the other companies have vowed against selling students’ personally identifiable information or using it for targeted advertising, among other commitments. They also agreed to “maintain a comprehensive security program that is reasonably designed to protect the security, confidentiality and integrity” of student’s personal information against unauthorized or unintended disclosure. Cybersafeguards, the pledge notes, should be “appropriate to the sensitivity of the information.” 

Raptor touts its pledge commitment on its website, where it notes the company takes “great care and responsibility to both support the effective use of student information and safeguard student privacy and information security.” The company claims on its website that it ensures “the highest levels of security and privacy of customer data,” including encryption “both at rest and in-transit,” meaning that data is scrambled into an unusable format without a password while it is being stored on servers and while it’s being moved between devices or networks. 

Its privacy policy, however, offers a more proscribed assurance, saying the company takes “reasonable” measures to protect sensitive data, but that it cannot guarantee that such information “will be protected against unauthorized access, loss, misuse or alterations.” 

Districts nationwide have spent tens of millions of dollars on Raptor’s software, according to GovSpend, a government procurement database. Recent customers include the school districts in Dallas, Texas, Broward County, Florida, and Rochester, New York. Under a state law in New York, education technology companies that collect student data are required to maintain a cybersecurity program that includes data encryption and controls to ensure that personally identifiable information doesn’t fall into the hands of unauthorized actors. 

Countering Raptor’s claims that data were encrypted, Fowler told The 74 the documents he accessed “were just straight-up PDFs, they didn’t have any password protections on them,” adding that the files could be found by simply entering their URLs into a web browser. 

Officials at the Rochester school district didn’t respond to requests for comment about whether they had been notified about the breach and its effects on their students or if they were aware that Raptor may not have been in compliance with state encryption requirements. 

Doug Levin, the national director of the nonprofit K12 Security Information eXchange, said the Raptor blunder is reminiscent of a 2022 data breach at the technology vendor Illuminate Education, which exposed the information of at least 3 million students nationwide, including 820,000 current and former New York City students. Levin noted that both companies claimed their data was encrypted at rest and in transit — “except maybe it wasn’t.” 

A decade after the privacy pledge was introduced, he said “it falls far short of offering the regulatory and legal protections students, families and educators deserve.”

“How can educators know if a company is taking security seriously?” Levin asked. Raptor “said all of the right things on their website about what they were doing and, yet again, it looks like a company wasn’t forthright. And so, maybe this is a pattern.” 

State data breach rules have long focused on personal information, like Social Security numbers, that could be used for identity theft and other financial crimes. But the consequences of data breaches like the one at Raptor, Fowler said, could be far more devastating — and could harm children for the rest of their lives. He noted the exposure of health records, which could violate federal privacy law, could be exploited for various forms of fraud. Discipline reports and other sensitive information, including about student sexual abuse victims, could be highly embarrassing or stigmatizing. 

Meanwhile, he said the exposure of confidential records about physical security infrastructure in schools, and district emergency response plans, could put kids in physical danger. 

Details about campus security infrastructure have been exploited by bad actors in the past. After Minneapolis Public Schools fell victim to a ransomware attack last February that led to a large-scale data breach, an investigation by The 74 uncovered reams of campus security records, including campus blueprints that revealed the locations of surveillance cameras, instructions on how to disarm a campus alarm system and maps that documented the routes that children are instructed to take during an emergency evacuation. The data can be tracked down with little more than a Google search. 

“I’ve got a 14-year-old daughter and when I’m seeing these school maps I’m like, ‘Oh my God, I can see where the safe room is, I can see where the keys are, I can see the direction they are going to travel from each classroom, where the meetup points are, where the police are going to be,” Fowler said of the Raptor breach. “That’s the part where I was like, ‘Oh my God, this literally is the blueprint for what happens in the event of a shooting.” 

‘Sweep it under the rug’

The Future of Privacy Forum’s initial response to the Raptor breach mirrors the nonprofit’s actions after the 2022 data breach at Illuminate Education, which was previously listed among the privacy pledge signatories and became the first-ever company to get stripped of the designation. 

The forum’s decision to remove Illuminate followed an article in The 74, where student privacy advocates criticized it for years of failures to enforce its pledge commitments — and accused it of being a tech company-funded effort to thwart government regulations. 

The pledge, which was created by the privacy forum in partnership with the Software and Information Industry Association, a technology trade group, was created in 2014, just one week after California lawmakers passed rules placing restrictions on the ways ed tech companies could use the data they collect about K-12 students. 

Along with stripping Illuminate of its pledge signatory designation, the forum referred it to the Federal Trade Commission, which the nonprofit maintains can hold companies accountable to their commitments via consumer protection rules that prohibit unfair and deceptive business practices. The company was also referred to the state attorneys general in New York and California to “consider further appropriate action.” It’s unclear if regulators took any actions against Illuminate. The FTC and the California attorney general’s office didn’t respond to requests for comment. The New York attorney general’s office is reviewing the Illuminate breach, a spokesperson said. 

“Publicly available information appears to confirm that Illuminate Education did not encrypt all student information” in violation of several Pledge provisions, Forum CEO Jules Polonetsky told The 74 at the time. Among them is a commitment to “maintain a comprehensive security program” that protects students’ sensitive information” and to “comply with applicable laws,” including New York’s  “explicit data encryption requirement.” 

After the breach and before it was removed from the pledge, the Software and Information Industry Association recognized Illuminate with the sector’s equivalent of an Oscar. 

Raptor isn’t the only pledge signatory to fall victim to a recent data breach. In December, a cybersecurity researcher disclosed a security vulnerability at Education Logistics, commonly known as EduLog, which offers a GPS tracking system to give parents real-time information about the location of their children’s school buses. A statement the forum provided The 74 didn’t mention whether it had opened an inquiry into whether EduLog had failed to comply with the pledge commitments. 

Despite the forum’s actions against Illuminate Education, and its new inquiry into Raptor, the pledge continues to face criticism for having little utility, including from Fowler, who likened it to “virtue signaling” that can be quickly brushed aside. 

“Pledges are just that, they’re like, ‘Hey, that sounds good, we’ll agree to it until it no longer fits our business model,” he said. “A pledge is just like, “whoops, our bad,” a little bit of bad press and you just sweep it under the rug and move on.” 

Chad Marlow, a senior policy counsel at the American Civil Liberties Union focused on privacy and surveillance issues, offered a similar perspective. Given the persistent threat of data breaches and a growing number of cyberattacks on the K-12 sector, Marlow said that schools should take a hard look at the amount of data that they and their vendors collect about students in the first place. He said Raptor’s early intervention system, which seeks to identify children who pose a potential threat to themselves or others, is an unproven surveillance system that could become a vector for student discrimination in the name of keeping them safe. 

Although he said he has “a great deal of admiration” for the privacy forum and the privacy pledge goals, it falls short on accountability when compared to regulations that mandate compliance.

“Sometimes pledges like this, which are designed to make a little bit of progress, actually do the opposite because it allows companies to point to these pledges and say, ‘Look, we are committed to doing better,’ when in fact, they’re using the pledge to avoid being told to do better,” he said. “That’s what we need, not people saying, ‘On scout’s honor I’ll do X.’”  

Disclosure: The Bill & Melinda Gates Foundation and the Chan Zuckerberg Initiative provide financial support to the Future of Privacy Forum and The 74.

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