In the contemporary digital landscape, children represent one of the most vulnerable populations for identity theft and financial fraud, yet they remain one of the least protected demographics when data breaches occur. The alarming reality is that in 2022 alone, approximately 1.7 million children fell victim to data breaches, meaning that roughly one in every forty-three children had their personal information exposed or compromised. This report provides an exhaustive examination of the mechanisms, strategies, and frameworks through which parents, guardians, educators, and organizations can effectively protect children following data breaches, with particular emphasis on proactive personal information monitoring, identity exposure detection, and comprehensive breach remediation strategies. The analysis encompasses the epidemiology of child identity theft, the evolving legal frameworks designed to provide protection, practical protocols for immediate response, technological tools available for monitoring and restoration, and recommendations for systemic improvements to close existing vulnerabilities in the protection ecosystem.
The Escalating Crisis of Child Data Breaches: Understanding Vulnerability and Scale
Children have become increasingly attractive targets for data thieves and identity fraudsters, not because of malice toward minors specifically, but rather because of the unique structural vulnerabilities that characterize childhood in the modern digital economy. The 2021 Javelin Strategy and Research report documented that 1.25 million American children were victims of identity theft and fraud in 2020 alone, with the average family bearing financial losses exceeding $1,100. More recent surveys indicate that this problem has intensified rather than diminished, with the rate of child victimization accelerating at an alarming pace. Perhaps most disturbingly, research has shown that children are approximately 51 times more vulnerable to identity theft than their adult counterparts, a disparity that stems directly from the structural characteristics of childhood identity and credit profiles.
The unique vulnerability of children derives fundamentally from what cybersecurity experts term the “blank slate” problem. Children under the age of eighteen typically do not have credit reports, Social Security numbers that have been used to establish credit history, or other markers in the financial system that would trigger fraud detection mechanisms. This absence of financial history, while seemingly protective in theory, actually creates a perfect environment for fraudulent activity in practice. Identity thieves recognize that they can use a child’s Social Security number to open credit accounts, take out loans, apply for government benefits, rent housing, obtain employment, or file fraudulent tax returns with minimal risk of immediate detection. The crime may go undetected for years, often remaining hidden until the child reaches late adolescence or early adulthood and attempts to secure their first independent credit line, apartment lease, or student loan. By that time, the damage to the child’s financial reputation and creditworthiness may be extensive and difficult to remediate.
Recent high-profile breaches have illustrated the scale and scope of child data exposure. In early 2025, the PowerSchool Student Information System experienced a significant cybersecurity incident through which hackers accessed personal information belonging to approximately 62 million students and 10 million teachers across the United States and Canada. The compromised data included names, addresses, Social Security numbers, grades, and potentially medical and health records. The breach occurred when malicious actors used stolen credentials to access PowerSchool’s customer support portal, highlighting how institutional vulnerabilities can suddenly expose millions of children’s data simultaneously. Similarly, the National Public Data breach in early 2024 exposed data for potentially 170 million people across the United States, United Kingdom, and Canada, including full names, Social Security numbers, mailing addresses, email addresses, and phone numbers. These breaches underscore the reality that children’s data vulnerability extends far beyond individual parental negligence and reflects systemic weaknesses in organizational cybersecurity practices and regulatory oversight.
Furthermore, schools have become particularly attractive targets for cybersecurity attacks specifically because of the sensitive data they maintain about students. According to research from the Center for Internet Security, 82 percent of K-12 schools in the United States experienced cyberattacks during the eighteen-month period from July 2023 to December 2024. This extraordinarily high incidence rate indicates that data breaches affecting children are not exceptional events but rather have become routine occurrences in the educational technology landscape. The concentration of vulnerable data—including Social Security numbers, health information, academic records, and family contact information—makes schools and school districts particularly valuable targets for cybercriminals operating either for profit or for espionage purposes.
The psychological and social dimensions of child data breaches extend beyond the immediate financial consequences. When children and adolescents learn that their personal information has been exposed and potentially misused, the resulting anxiety and sense of vulnerability can manifest in long-term psychological distress. Parents similarly experience significant emotional burden when confronted with evidence that their children’s information has been compromised, particularly given the uncertainty regarding what exactly has been exposed and how that information might be used. This emotional toll compounds the practical challenges of breach remediation and underscores the importance of clear communication, responsive institutional action, and accessible mechanisms for affected families to restore their children’s information security and financial integrity.
Understanding Child Identity Theft: Forms, Mechanisms, and Consequences
Child identity theft encompasses a diverse spectrum of fraudulent activities, each with distinct mechanisms and consequences for the victim child and their family. The Federal Trade Commission defines child identity theft as occurring when someone uses a child’s sensitive personal information to obtain services or benefits, or to commit fraud. The information used in such schemes typically includes the child’s Social Security number, name and address, and date of birth, though increasingly sophisticated thieves also target biometric identifiers, government-issued identification numbers, and other markers of identity.
The specific fraudulent purposes to which criminals put children’s stolen information reveal the economic logic of child identity theft as a criminal enterprise. A perpetrator might use a child’s Social Security number to apply for government benefits, including healthcare coverage or nutrition assistance programs to which the fraudster is not entitled. More commonly, thieves use children’s identities to establish financial accounts, with criminals opening bank accounts or credit card accounts in the child’s name and then either transferring funds fraudulently or accumulating debt that becomes attached to the child’s credit record. In other instances, criminals apply for loans—auto loans, personal loans, mortgages—in the child’s name, building substantial financial obligations that the child and their family later discover when the child comes of age and seeks to establish legitimate credit. Utility services including water, gas, electricity, and telephone services have been fraudulently obtained in children’s names. The scope of potential fraud extends even to employment fraud, wherein thieves use a child’s Social Security number to obtain employment, claiming wages and tax benefits fraudulently.
One particularly insidious form of child identity theft is what criminologists term “synthetic identity fraud,” which represents a more sophisticated and increasingly common approach to exploiting children’s personal information. In synthetic identity fraud, criminals combine genuine information from a child (such as the child’s real Social Security number) with fabricated or stolen information from other sources to create an entirely new synthetic identity. The perpetrator might pair a child’s legitimate Social Security number with a different name, date of birth, address, and employment history to create a wholly new person in the financial system. This approach presents particular difficulties for detection and remediation because the child’s genuine Social Security number is being used, yet the associated biographical and financial history is entirely false, making it difficult for credit bureaus and financial institutions to determine which information is accurate. The perpetrator can then build this synthetic identity over months or years, establishing credit history, obtaining loans, and accumulating wealth or benefits entirely fraudulently before the scheme is discovered.
The financial consequences of child identity theft for affected families are substantial and lasting. Research indicates that families recovering from child identity theft incidents typically incur costs exceeding $1,100 on average, with additional expenses of approximately $400 for restoration and recovery services, bringing the total cost to approximately $1,140 per affected household. However, these aggregate figures mask the wide variation in individual cases, with some families experiencing minimal fraud of a few hundred dollars while others discover fraudulent mortgages, auto loans, or extensive accumulated debt in their children’s names. The process of remediation typically requires months of sustained effort, including contacting fraudulent creditors, communicating with credit bureaus, filing police reports, dealing with debt collectors, disputing fraudulent charges, and in some cases engaging legal counsel to challenge claims against the child’s identity.
Beyond the financial costs, child identity theft frequently results in direct harm to the child’s credit record, which can have cascading consequences extending well into adulthood. A child who discovers significant fraudulent credit history at age 18 or 19 may find themselves unable to qualify for student loans necessary for higher education, unable to secure employment requiring a credit or background check, and unable to rent an apartment or obtain other services that depend on credit worthiness. The psychological and developmental consequences of discovering one’s identity has been stolen by an unknown perpetrator—potentially someone within the child’s own family—adds an additional layer of trauma beyond the financial and logistical challenges.
Legal and Regulatory Frameworks: Federal Architecture and State Variations
The legal landscape governing the protection of children’s personal information following data breaches is characterized by significant fragmentation, with overlapping and sometimes conflicting federal, state, and international regulatory regimes each imposing distinct requirements on organizations collecting and processing children’s data. Understanding this complex legal architecture is essential for parents, educators, and institutional administrators seeking to navigate the post-breach environment effectively.
At the federal level, the cornerstone legislation governing children’s online privacy is the Children’s Online Privacy Protection Act (COPPA), enacted in 1998 and administered by the Federal Trade Commission. COPPA establishes baseline protections by mandating that websites and online services directed at children under thirteen years of age must obtain verifiable parental consent before collecting, using, or disclosing personal information from children. The rule applies not only to websites explicitly designed for children but also to general-audience websites and services that have actual knowledge they are collecting information from children under thirteen. In April 2025, the FTC finalized significant amendments to COPPA that substantially modernized and strengthened the rule to account for technological advances that had occurred since the last major update in 2013. The amended COPPA rule now includes expanded definitions of “personal information” to encompass biometric identifiers including fingerprints, facial patterns, voiceprints, gait patterns, and DNA sequences, as well as government-issued identifiers. The amendments also establish stricter standards for “mixed audience” services that are not primarily directed at children but may nevertheless attract child users, requiring such services to implement age verification before collecting any personal information. Enhanced parental notice and consent requirements now mandate that organizations disclose specifically how personal data will be used, identify third parties receiving data and their specific purposes, and obtain separate parental consent for certain categories of third-party disclosures, particularly those related to marketing or artificial intelligence training. Organizations must implement enhanced security programs proportionate to their size and data sensitivity, designate a security coordinator, and prohibit indefinite retention of children’s personal data. Compliance with the amended COPPA rule is required by April 22, 2026.
The Family Educational Rights and Privacy Act (FERPA), codified at 20 U.S.C. § 1232g, represents another critical piece of the federal infrastructure protecting children’s information. FERPA protects the privacy of personally identifiable information maintained in educational records by schools and educational agencies, prohibiting disclosure of such information without prior written consent from parents or eligible students except in specific statutory circumstances. Importantly, however, FERPA does not explicitly require schools to notify parents when student records have been breached or subjected to unauthorized disclosure. Instead, FERPA establishes baseline privacy protections and generally prohibits disclosure, while notification requirements depend on state law and organizational policy. The absence of explicit breach notification requirements under FERPA has created situations where schools have experienced significant data breaches without promptly notifying affected families, a gap that has prompted calls for strengthened federal requirements.
At the state level, the regulatory landscape has undergone dramatic expansion and evolution in recent years. California emerged as a pioneer in children’s privacy regulation with the California Consumer Privacy Act (CCPA) and its successor, the California Privacy Rights Act (CPRA), which extended enhanced privacy protections to minors under eighteen years of age. Other states have followed suit, enacting laws that focus specifically on regulating children’s data, particularly in connection with social media platforms. New York’s recently enacted SAFE for Kids Act represents a state-level initiative addressing specific harms to children from algorithmic content personalization on social media platforms. The law prohibits covered online platforms from providing minors with addictive feeds that use data about the minor or the minor’s device to personalize content, a feature explicitly linked to addictive behavior and extended screen time. The law also prohibits nighttime notifications between midnight and 6 a.m. related to addictive feeds. These state-level initiatives reflect growing recognition that children require specific protection tailored to the particular risks they face in digital environments.
However, the proliferation of state-level privacy laws has created what legal scholars and policymakers characterize as a fragmented and patchwork regulatory landscape. While some level of state variation and experimentation can produce beneficial policy innovation, the current situation creates substantial compliance burdens for businesses and potential protection gaps for consumers. A company operating nationally must navigate dozens of different state privacy regimes, each with distinct definitions of regulated entities, covered data, consumer rights, and required safeguards. This fragmentation creates particular challenges for small businesses and educational technology vendors who may lack the resources to implement fully differentiated compliance programs for each state in which they operate. Furthermore, the patchwork nature of state privacy laws creates geographic protection gaps wherein residents of states with weaker privacy laws receive less protection than similarly situated residents of states with stronger legal regimes.
Recognizing these challenges, legal experts and policy advocates have called for the establishment of a federal privacy standard that would supersede state laws and create uniform baseline protections across all jurisdictions. Such a federal standard would presumably establish consistent definitions of regulated entities and data, create uniform consumer rights and remedies, and impose standardized security and privacy obligations on organizations. The ideal federal privacy law would balance the need for robust consumer protection with recognition of the benefits that arise from appropriate data use, such as personalized recommendations, improved products, and discounted services. However, negotiations over the content of a prospective federal privacy law have faced substantial political obstacles, with disagreements among consumer advocates, business interests, state governments, and members of Congress about appropriate scope, enforcement mechanisms, and the extent to which federal law should preempt state laws.
Immediate Response Protocols: Detecting and Assessing Breach Impact
When a parent or guardian becomes aware that a child’s personal information has been exposed in a data breach—whether through direct notification from an organization, media reports, or other sources—a structured sequence of immediate actions is essential to mitigate harm and establish a baseline understanding of what information has been compromised and what risks the child faces. The Family Policy Compliance Office at the U.S. Department of Education has developed comprehensive guidance for parents navigating the aftermath of school data breaches, and the principles articulated in that guidance apply broadly to all child data breaches regardless of the institutional context.
The first critical step is to obtain confirmation from the affected organization regarding whether the child’s information was actually involved in the breach. Parents frequently learn about data breaches through media reports or word-of-mouth rather than direct notification from the organization itself, and in many cases, the information provided in initial media reports may be incomplete or inaccurate regarding the specific records affected. Contacting the affected organization and requesting explicit confirmation that the child’s information was involved in the breach allows parents to move from generalized concern to specific knowledge about whether their particular child is at risk. In cases involving school breaches, this conversation should address specifically what student records were affected and whether the child’s Social Security number, financial account information, or other particularly sensitive data were included in the unauthorized access or exfiltration.
The second critical step is to carefully evaluate the specific types of data that were exposed and the relative risk associated with each data category. Not all personally identifiable information carries equivalent risk of misuse or harm. For example, if a breach exposed a child’s name, school grade level, and grade point average, the risk of identity theft is substantially lower than if the breach exposed the child’s Social Security number, date of birth, address, and account numbers. The risk assessment should consider whether highly sensitive data including Social Security numbers, biometric identifiers, account numbers, passwords, or financial information were compromised versus less sensitive information such as grades, photographs, or addresses. This assessment of data sensitivity should inform the specific remedial actions the family undertakes in response to the breach.
Following this risk assessment, parents should implement a targeted set of protective measures calibrated to the specific types of data that were compromised. If the breach exposed financial account information including credit or debit card numbers, the immediate priority should be to contact the financial institutions and request cancellation of compromised cards, monitoring for fraudulent transactions, and potentially disputing unauthorized charges. If the breach exposed Social Security numbers or other sensitive identifying information, the priority shifts toward placing fraud alerts or credit freezes on the child’s credit report to prevent unauthorized account opening. In all cases, parents should monitor the affected organization’s website for additional information about the breach as the investigation continues, monitor personal and family financial accounts for unexpected activity, and consider obtaining credit or identity theft monitoring services to provide ongoing detection of suspicious activity.
An important dimension of immediate response that is often overlooked involves protecting the child and family from follow-up phishing attempts and scams by threat actors exploiting the publicity surrounding the breach. Cybercriminals frequently attempt to capitalize on breaches by sending phishing emails, text messages, or making phone calls that reference the breach and attempt to persuade victims to provide additional sensitive information or to click on malicious links. For example, in the aftermath of a school data breach, criminals might send messages purporting to be from the school or from identity theft protection services, offering to help the family secure their child’s information but in reality attempting to harvest additional personal data or install malware. Parents should be vigilant about unsolicited communications claiming to be from the affected organization or offering breach-related services, and should verify any communications by contacting the organization directly through a phone number or website obtained independently rather than relying on contact information provided in the potentially fraudulent communication.
Credit Freezes and Financial Lock-Down: Proactive Defense Against Account Opening Fraud
Among the most powerful protective mechanisms available to parents of children whose information has been exposed in a data breach is the credit freeze, sometimes also referred to as a security freeze or a protected consumer freeze depending on jurisdiction and credit bureau terminology. A credit freeze restricts access to a child’s credit report and prevents credit bureaus from releasing information about the child to third parties seeking to make credit decisions, effectively blocking the ability of identity thieves to open new accounts in the child’s name.
The mechanics of the credit freeze process operate at the level of the three major national credit reporting agencies: Experian, TransUnion, and Equifax. These three bureaus maintain comprehensive databases of individuals’ credit histories and score the creditworthiness of consumers based on patterns of borrowing, payment history, and outstanding debt. When a lender or other party seeks to extend credit to an individual, they typically first contact one or more of these credit bureaus to obtain a credit report and credit score. A credit freeze essentially tells the credit bureau not to release the credit report to third parties unless and until the freeze is specifically lifted by the account holder or their authorized representative. By preventing the release of the credit report, the freeze makes it dramatically more difficult for an identity thief to open new accounts in the child’s name, since most creditors will not extend credit without first reviewing a credit report.
Federal law now provides that parents and legal guardians of children under sixteen can place a free security freeze on their child’s credit report with each of the three major credit bureaus. This represents a significant policy victory for consumer advocates, as prior to recent legislative changes, placing a security freeze required payment of fees in many jurisdictions, creating a financial barrier to this protective measure. The process for placing a freeze on a minor’s credit report differs from the process for freezing an adult’s credit and typically requires submission of documentation establishing the parent’s or guardian’s identity and the child’s identity, along with proof of the parental or guardial relationship.
The specific procedures for placing a freeze vary somewhat among the three credit bureaus, though the general framework is consistent. For Experian, parents seeking to place a freeze on a minor’s credit report must gather copies of government-issued identification for the parent, proof of the parent’s current address, the child’s birth certificate, the child’s Social Security card, and proof of guardianship if not named on the child’s birth certificate. These documents must be submitted to Experian either by mail or through the company’s online document upload portal, with contact information available on Experian’s website. Once Experian has received the request and all required documentation, which typically takes approximately ten to fifteen days, a security freeze will be placed on the child’s credit file. If a credit file does not previously exist for the child, Experian will create the file and then immediately place the freeze on it.
For Equifax, the process similarly requires submission of documentation including a government-issued ID for the parent, proof of the parent’s address, the child’s birth certificate, the child’s Social Security card, and documentation establishing parental or guardial relationship. These documents should be mailed to Equifax at the address specified on their website, with the company typically requiring up to three business days to complete the freeze request once all documentation is received. For TransUnion, the process is comparable, requiring similar documentation to be submitted by mail or through their online portal. A key point that parents must understand is that security freezes must be placed separately with each of the three major credit bureaus—placing a freeze with one bureau does not automatically place freezes with the other two.
An important practical question concerns the duration of a security freeze placed on a minor’s credit report. Parents naturally want to understand how long the protective effects of the freeze will persist and whether they will need to periodically renew or update the freeze. In most jurisdictions, a security freeze placed on a minor’s credit report remains in place indefinitely until it is explicitly lifted by the parent or guardian, or until the child reaches the age of majority (typically eighteen) and requests removal themselves. This indefinite duration provides substantial long-term protection, as the freeze will persist through the child’s early years and into late adolescence, protecting the child during the period when identity theft is most likely to remain undetected. Once the child reaches eighteen years of age and the age of majority, the freeze remains in place unless and until the individual decides to lift it to enable legitimate credit application.
In situations where a child’s information has already been compromised and identity theft has occurred, parents should also consider placing a fraud alert on the child’s credit report in addition to or in place of a security freeze. A fraud alert notifies credit bureaus and potential creditors that the account holder may be a victim of identity theft, and creditors should implement additional verification procedures before extending credit. A fraud alert is typically free and can be placed by telephone or online with one of the three credit bureaus, which is then required to notify the other two. However, fraud alerts typically remain in effect for only one year, making them a less durable protective measure than a security freeze for long-term protection.
Monitoring and Detection: Proactive Identification of Fraudulent Account Opening
Beyond the defensive measure of a security freeze, parents can implement active monitoring systems to detect whether their child’s information has already been misused or fraudulently applied for accounts. The federal government has designated IdentityTheft.gov, managed by the Federal Trade Commission, as the central repository and resource for identity theft reporting and recovery information. When a parent suspects that their child’s identity has been stolen, they should visit IdentityTheft.gov to file a report, obtain a personalized identity theft recovery plan, and access templates for communications to creditors, credit bureaus, and debt collectors.
A critical component of fraud detection involves regularly checking whether a child has a credit report. In the normal course of events, children under eighteen should not have credit reports maintained by credit bureaus, as they have not engaged in credit transactions that would prompt the establishment of a credit file. The existence of a credit report in a child’s name is therefore a red flag indicating potential identity theft, as it suggests that someone has applied for credit in the child’s name. Parents can check for the existence of a credit report in their child’s name by contacting each of the three credit bureaus—Experian, TransUnion, and Equifax—and requesting a manual search using the child’s name and Social Security number. The process typically involves following specific procedures established by each credit bureau, which may include telephone contact or written request.
Experian provides specific instructions on its website for parents seeking to check whether a minor has a credit report. Parents are instructed to navigate to Experian’s website, locate the section labeled “Minor Child Instructions” under “Information You Should Know,” and follow the procedures outlined there. Similarly, TransUnion and Equifax provide specific processes for checking whether credit reports exist in minors’ names, with parents typically needing to provide government-issued identification and other verification documents.
If the credit bureau search reveals that no credit file exists in the child’s name, this is reassuring and indicates that the child’s identity has not (yet) been fraudulently used to establish credit. Parents should follow up with written confirmation requests to each credit bureau, asking them to confirm in writing that they maintain no credit file under the child’s name or Social Security number. These written confirmations create a documented record that can be valuable if fraud is subsequently discovered or disputed.
If, conversely, the credit bureau search reveals that a credit file does exist in the child’s name, this is a significant warning sign suggesting identity theft, and parents should immediately take action. The credit bureau will typically provide a copy of the child’s credit report, which should be carefully reviewed for fraudulent accounts or inquiries. Any fraudulent accounts or inquiries should be immediately disputed through the credit bureau’s dispute process, requesting removal of the fraudulent information from the report. Parents should contact companies where fraudulent accounts have been opened, explaining that the accounts were opened fraudulently in a minor’s name and requesting that the accounts be closed and that documentation confirming the child’s lack of liability be provided.
Beyond credit bureau monitoring, parents can employ identity monitoring and theft protection services designed specifically for families and children. These services vary in their specific features but typically include monitoring of credit reports for suspicious activity, monitoring of the dark web and other illicit data markets for signs that the child’s personal information is being traded or used, provision of alerts when certain categories of activity are detected, and assistance with identity restoration if fraud is discovered. Services such as LifeLock Junior, Aura, Identity Guard, IdentityIQ, and others offer family plans that allow parents to monitor multiple children and family members simultaneously. These services typically charge monthly or annual subscription fees, though some organizations affected by breaches offer complimentary identity monitoring services to affected individuals for a period of one to two years following the breach.
The FTC also recommends that parents begin regular credit report checks when their child reaches sixteen years of age, as this is when children may begin establishing their own credit history through authorized credit card accounts or other financial products. These periodic checks can serve as an early warning system, allowing parents to identify fraudulent activity before it becomes extensive.
Special Protections in Educational Contexts: FERPA and School Data Breach Response
Schools and school districts occupy a unique and critically important position in the data ecosystem of childhood, maintaining extensive collections of personally identifiable information about students for educational, administrative, and safety purposes. This data collection creates both legitimate educational benefits and significant privacy risks, as the concentration of sensitive information about children makes schools attractive targets for cybercriminals. The legal framework governing school data breaches combines FERPA’s general privacy protections with state-specific data breach notification laws and emerging state laws focused specifically on children’s online privacy and safety.
FERPA establishes baseline confidentiality protections for education records maintained by schools and educational agencies. Education records, as defined by FERPA, include any record directly related to a student and maintained by an educational agency, including records of academic progress, disciplinary records, special education records, grades, test scores, financial information, and other student-related information. FERPA prohibits disclosure of these records without prior written consent from parents (for students under eighteen) or eligible students (for students over eighteen) except in specifically enumerated statutory circumstances including emergencies involving threats to student health or safety, disclosures to school officials with legitimate educational interests, and disclosures required by court order or subpoena.
However, the critical gap in FERPA’s protection in the data breach context is that FERPA does not explicitly require schools to notify parents when student records have been subject to unauthorized access, exfiltration, or disclosure resulting from a data breach. While FERPA requires schools to maintain records of disclosures they make, it does not mandate proactive notification to parents when records have been breached. Instead, breach notification obligations at the federal level are minimal, instead being delegated to state breach notification laws. State laws typically impose obligations to notify affected individuals when personal information has been subject to a breach, but these state laws vary substantially in their scope, the categories of information that trigger notification obligations, and the timeline within which notification must occur.
The absence of explicit federal breach notification requirements under FERPA has created situations where parents have only learned of school data breaches weeks or months after they occurred, sometimes through media reports rather than direct institutional notification. The U.S. Department of Education’s Student Privacy Policy Office has emphasized that while FERPA itself does not require breach notification, it is a best practice for schools to notify parents following a data breach assessment, and many states do impose breach notification requirements through state law.
For parents navigating a school data breach, the Department of Education recommends a structured four-step process. First, parents should confirm with the school that their child’s records were actually involved in the breach, as initial breach announcements may not specify which specific records were affected. Second, parents should evaluate the risk associated with the particular types of information exposed, using the framework discussed above regarding data sensitivity and fraud risk. Third, parents should take protective steps calibrated to the specific types of data compromised, which may include placing fraud alerts or credit freezes if Social Security numbers were exposed, or monitoring accounts for unauthorized activity if financial information was involved. Fourth, if parents believe the school has violated FERPA protections, they may file a complaint with the Family Policy Compliance Office within 180 days of becoming aware of the alleged violation.
The enhanced regulatory environment surrounding children’s online privacy that has emerged in recent years will increasingly affect school data practices. The amended COPPA rule applies to educational technology vendors and online services used in schools, imposing enhanced requirements for data minimization, parental consent, and security protections. Many states are also enacting comprehensive privacy laws applicable to student data, requiring educational institutions to implement specific privacy and security safeguards, limit student data collection and use, provide transparency to parents regarding data practices, and enable parents to access and delete their children’s data. These evolving legal requirements are gradually strengthening protections for student data, though significant gaps and inconsistencies remain.
Long-Term Recovery and Remediation: Restoring Financial Integrity After Fraudulent Account Opening
When a child has been the victim of identity theft and fraudulent accounts have been opened in the child’s name, the remediation process can be complex, time-consuming, and emotionally stressful for families. The FTC provides comprehensive guidance for identity theft victims seeking to restore their financial identity and credit history, and the protocols outlined in that guidance apply to child victims of identity theft with necessary modifications accounting for the child’s age and legal status.
The first component of remediation involves contacting the companies where fraudulent accounts have been opened and requesting account closure. Parents should contact the fraud department of each company where unauthorized accounts have been opened, explain that the accounts were opened fraudulently using a minor child’s identity and without parental authorization, and provide documentation such as a copy of the child’s birth certificate establishing that the person accessing the accounts is not the same individual as the account holder. Parents should request written confirmation from each company confirming that the accounts have been closed and that the child is not liable for the fraudulent charges. These written confirmations create an important paper trail for future reference if disputes arise regarding these accounts.
A second critical component involves notifying the three major credit bureaus of the fraudulent activity. Parents should contact each credit bureau and inform them that fraudulent accounts have been opened in the child’s name, providing details about the fraudulent accounts, and requesting that the fraudulent information be removed from the child’s credit report. The credit bureaus are required by law to investigate such disputes and, if fraud is confirmed, to remove the fraudulent information from the consumer’s credit report. The dispute process can be initiated by telephone, mail, or online, depending on the credit bureau’s procedures.
A third critical component of remediation involves filing an official identity theft report with law enforcement and the FTC. Filing a police report with local law enforcement creates an official record of the identity theft incident, provides documentation that may be valuable in future disputes regarding the fraudulent accounts, and may be required by the credit bureaus to place an extended fraud alert or security freeze in some circumstances. Parents should file the police report using the procedures established by their local law enforcement agency, and they should obtain a copy of the police report for their records.
Additionally, parents should file an identity theft report with the Federal Trade Commission at IdentityTheft.gov. The FTC collects identity theft complaints from consumers, maintains a database of identity theft incidents, and shares information with law enforcement agencies. Filing a report with the FTC generates a personalized recovery plan that provides detailed, customized guidance for the specific types of fraud the child has experienced, whether tax fraud, financial account fraud, medical fraud, or other categories of identity theft. The FTC’s identity theft recovery tool also provides pre-filled letters and forms that parents can use in communicating with creditors, credit bureaus, and debt collectors, substantially simplifying the remediation process.
The timeline for identity theft remediation varies substantially depending on the complexity and extent of the fraudulent activity. In relatively straightforward cases involving a single fraudulent account with limited charges, remediation might be substantially completed within weeks or a few months. In cases involving multiple fraudulent accounts, substantial accumulated debt, or fraudulent tax filings, the remediation process can extend for many months or even years. Some identity theft cases require legal intervention, particularly when creditors refuse to acknowledge that charges are fraudulent or when debt collectors attempt to collect on fraudulent debts. In such situations, parents may benefit from consultation with an attorney or from working with an identity theft resolution service that specializes in negotiating with creditors and debt collectors.
Systemic Challenges: Fragmentation, Enforcement Gaps, and the Need for Regulatory Reform
Despite the substantial legal infrastructure that has been erected to protect children’s information both in advance of breaches and in response to breaches that do occur, significant systemic challenges persist that limit the effectiveness of these protections and create opportunities for fraudsters to exploit children’s data with limited consequences. These systemic challenges reflect fundamental tensions between regulatory approaches, resource limitations, and the evolving sophistication of cybercriminal enterprises.
One substantial systemic challenge involves the geographic and jurisdictional fragmentation of privacy regulation discussed above. The absence of a uniform national privacy standard creates a patchwork of federal, state, and international requirements that companies must navigate, with different states imposing different definitions of covered data, different scope of applicability, different consumer rights, and different enforcement mechanisms. This fragmentation creates particular challenges for educational technology companies and small businesses that may lack the resources to implement fully differentiated compliance programs for multiple states. Furthermore, cybercriminals and data brokers who may be operating internationally can exploit gaps between jurisdictions, conducting operations from locations with minimal regulatory oversight and selling stolen data to purchasers in any jurisdiction. The lack of consistent standards creates opportunities for companies to adopt minimalist approaches to privacy protection in jurisdictions with weaker requirements, knowing that stronger regulatory requirements in other jurisdictions do not constrain their operations.
A second systemic challenge involves the persistent gap between regulatory requirements and actual organizational compliance, particularly with respect to security protections. While COPPA, state privacy laws, and various industry standards establish requirements for information security proportionate to the sensitivity of data maintained, many organizations fail to implement adequate security measures. The PowerSchool breach, for example, resulted from the company’s failure to implement multi-factor authentication on a customer support portal, a fundamental security practice that would have prevented the unauthorized access that led to the breach. Similarly, many school districts continue to operate legacy computer networks with known vulnerabilities and inadequate security infrastructure, creating systematic vulnerabilities that attackers can exploit. The resource constraints facing many school districts, particularly those serving lower-income communities, create situations where districts lack the financial resources to invest in adequate cybersecurity infrastructure and expert personnel.
A third systemic challenge involves the inadequacy of breach notification and liability mechanisms as an incentive for organizations to invest in security. Current state breach notification laws require organizations to notify affected individuals when personal information has been breached, but these laws typically do not impose significant financial penalties on organizations that fail to implement adequate security measures or that provide inadequate notification. The absence of meaningful financial consequences or liability creates a situation where organizations may find it economically rational to minimize security spending and accept the risk of breaches, calculating that the cost of breach notification and potential reputational harm is lower than the cost of implementing robust security measures. Some commentators have advocated for strengthened liability frameworks, including private rights of action allowing consumers to sue organizations for breaches resulting from inadequate security, in order to create stronger financial incentives for investment in protection.
A fourth systemic challenge involves the detection and prosecution of child identity theft after the fact. While mechanisms exist for reporting identity theft and for attempting to remediate its consequences, the investigation and prosecution of the perpetrators of child identity theft remains under-resourced and inconsistent. Many local law enforcement agencies lack specialization in identity theft cases and may be unable to effectively investigate or prosecute perpetrators, particularly when the crimes involve interstate elements or the use of anonymous online payment systems or cryptocurrency. Federal law enforcement agencies including the Federal Bureau of Investigation and the Secret Service have some capacity to investigate identity theft, but the volume of identity theft cases greatly exceeds the investigative capacity available.
A fifth systemic challenge, and perhaps the most troubling from a family perspective, is that children often face identity theft from persons they know and trust, including parents, guardians, or other family members. Research suggests that nearly seventy-five percent of identity theft victims know the perpetrators. In the case of parental identity theft, the child faces profound complications in pursuing remediation, as reporting the theft may result in family disruption, the involvement of law enforcement or child protective services, and the child’s potential removal from the home. Some states have enacted specific laws addressing family identity theft, but the legal and social complexities surrounding such cases make them extraordinarily difficult to navigate. The development of effective protocols for responding to family identity theft remains an underdeveloped area of law and practice.
Emerging Threats and Evolving Attack Vectors
The landscape of threats to children’s information and privacy continues to evolve as cybercriminals develop more sophisticated attack methodologies, as technology creates new vectors for data collection and exploitation, and as the business models underlying various digital platforms create new incentives for data monetization. Understanding these emerging threats is essential for parents and institutions seeking to maintain protective measures that remain effective as the threat environment changes.
One increasingly prominent threat vector involves the misuse of children’s data through biometric collection and processing, which the amended COPPA rule specifically addresses. Facial recognition, fingerprint scanning, voice recognition, and gait recognition technologies are increasingly deployed in schools, retail environments, and other contexts where children gather. While these technologies offer legitimate benefits including security and personalization, they also create new opportunities for misuse if not adequately safeguarded. The amended COPPA rule now includes biometric identifiers in the definition of personal information requiring parental consent, and establishes specific procedures for organizations seeking to use facial recognition for parental consent verification.
A second emerging threat involves the use of artificial intelligence and machine learning technologies to analyze children’s data for purposes of behavioral manipulation and engagement enhancement. The amended COPPA rule specifically addresses the use of data for creating psychological profiles of children intended to target them with personalized content designed to maximize engagement and time spent on platforms. Research has documented that algorithmic content personalization can contribute to problematic social media use, sleep disruption, depression, anxiety, and self-harm in adolescents. The regulatory response, as reflected in both the amended COPPA rule and New York’s SAFE for Kids Act, restricts the use of children’s data for engagement-enhancing purposes, but enforcement and effective monitoring remain challenging.
A third emerging threat involves the collection and monetization of children’s location data. Mobile devices and location-tracking technologies enable collection of detailed information about where children spend time, when they are present in particular locations, and patterns of movement. Location data can be combined with other personal information to create highly detailed behavioral profiles that can be exploited for marketing, manipulation, or in extreme cases, targeting of children for exploitation. While privacy laws increasingly recognize location data as sensitive personal information, effective protection of children’s location data remains challenging, particularly given the embedded nature of location tracking in many applications and devices.
A fourth emerging threat involves the exploitation of children through the dark web and illicit data markets. Cybercriminals purchase children’s personal information from data brokers or through theft and then use that information to commit fraud, or in more sinister contexts, to facilitate trafficking, exploitation, or other serious harms to children. Recent high-profile cases have involved criminal organizations threatening to publish stolen data of children obtained from nurseries, schools, and other institutions, demanding ransom payments with explicit threats to release sensitive information or to harm the children if payment is not made. These threats, while relatively rare, underscore the potential for stolen data to be weaponized against families.
Technological Solutions: Identity Protection Services and Monitoring Tools
The market for child-focused identity protection and monitoring services has expanded substantially in recent years as awareness of child identity theft risks has grown among parents and institutions. These services offer varying degrees of functionality, ranging from relatively basic credit monitoring to comprehensive identity monitoring combining credit surveillance, dark web monitoring, identity restoration services, and related offerings. Understanding the landscape of available services and the capabilities of different products can help parents make informed decisions about which services, if any, are appropriate for their circumstances.
LifeLock Junior, now marketed under the Norton umbrella following corporate consolidation in the cybersecurity industry, offers identity theft protection services specifically designed for children under eighteen. The service provides monitoring of the child’s Social Security number, proactive searches of file-sharing networks for exposure of the child’s personal information, and comprehensive identity restoration services if identity theft occurs, including provision of necessary lawyers and experts if needed to resolve the case. LifeLock Junior is available only in conjunction with adult membership in LifeLock, creating a family-based protection structure.
Aura has emerged as a highly-rated provider of family identity protection services, offering comprehensive monitoring of multiple family members simultaneously. Aura provides triple-bureau credit monitoring, home title monitoring, identity monitoring, dark web surveillance, and identity restoration services. The service has received particular commendation for its user-friendly interface and comprehensive approach to family-wide monitoring.
Identity Guard, which leverages artificial intelligence powered by IBM’s Watson platform, offers family plans covering multiple adults and unlimited children. Identity Guard provides comprehensive identity monitoring, credit monitoring, and fraud resolution services, with particular strengths in social media monitoring and detection of compromised accounts across online platforms.
IdentityIQ provides comprehensive credit and identity protection services with particular strengths in credit monitoring and protection against various forms of fraud including synthetic identity fraud. The service includes monitoring for criminal records, dark web surveillance, and assistance with fraud recovery.
Importantly, many organizations affected by data breaches now offer complimentary identity monitoring and credit monitoring services to affected individuals for a defined period, typically one to two years following the breach. The PowerSchool breach, for example, resulted in the company offering two years of complimentary identity protection services and two years of complimentary credit monitoring services through Experian’s IdentityWorks for all affected students and educators. These breach-related offerings provide valuable temporary protection for affected individuals while they are at heightened risk of identity theft related to the specific breach.
Societal Recommendations and Best Practices: Multi-Stakeholder Approaches to Child Data Protection
Protecting children’s data after breaches and preventing future breaches that expose children’s information requires coordinated action across multiple constituencies including parents and guardians, educational institutions, technology companies, law enforcement agencies, and legislative bodies. Recognizing that no single intervention can fully address the problem, experts and advocates have developed frameworks for comprehensive, multi-stakeholder approaches to child data protection.
Parents and guardians bear significant responsibility for implementing protective measures tailored to their children’s specific circumstances and vulnerabilities. Best practices for parents include the following: First, educate children about privacy and online safety from an early age, teaching them to be cautious about sharing personal information, to recognize phishing attempts, to use strong and unique passwords, and to understand that information shared online may persist indefinitely. Second, implement parental controls on devices and networks to monitor and restrict children’s online activities, limit access to age-inappropriate content, and provide visibility into what information children are sharing. Third, protect documents containing children’s personal information by maintaining them in secure storage, shredding sensitive documents before disposal, and being cautious about who has access to information such as Social Security cards and birth certificates. Fourth, exercise caution when providing children’s Social Security numbers to organizations, questioning whether the number is actually necessary and whether alternative identifiers could be used. Fifth, regularly monitor children’s credit reports, particularly as children approach the age of sixteen, to detect fraudulent activity. Sixth, place security freezes on children’s credit reports to prevent unauthorized account opening. Seventh, maintain open and supportive communication with children about online threats, including scams, predatory behavior, and identity theft, creating an environment where children feel safe reporting suspicious activity.
Educational institutions and organizations serving children bear responsibility for implementing robust security practices proportionate to the sensitivity of data they maintain about students and program participants. Best practices include the following: First, conduct comprehensive data inventories to identify what personal information is being collected, where it is stored, how it is being used, and who has access to it. Second, implement security controls including encryption of sensitive data, multi-factor authentication for administrative access, firewalls, intrusion detection systems, and regular security audits. Third, develop comprehensive incident response plans that specify how the organization will respond to data breaches, including procedures for investigation, forensic preservation of evidence, notification of affected individuals and law enforcement, media communication, and remediation efforts. Fourth, maintain comprehensive cybersecurity insurance or cyber-liability insurance to provide financial protection and access to expert assistance in the event of a breach. Fifth, provide ongoing training to staff regarding cybersecurity best practices, phishing awareness, and proper handling of sensitive data. Sixth, implement data minimization practices to collect only information that is actually necessary for the organization’s legitimate purposes, thereby reducing the quantity of sensitive data at risk in the event of a breach.
Technology companies and online service providers serving children bear responsibility for implementing privacy-protective design practices aligned with evolving regulatory requirements. Best practices include the following: First, implement privacy-by-design principles that integrate privacy protection into the foundational architecture and operations of systems and services rather than treating privacy as an afterthought. Second, comply with the enhanced requirements of the amended COPPA rule, including expanded definitions of personal information, enhanced parental consent procedures, and prohibitions on indefinite data retention and engagement-enhancing techniques. Third, provide transparency to parents and children regarding data collection practices, use of data, categories of third parties receiving data, and retention periods. Fourth, minimize collection and retention of children’s personal information to what is necessary for legitimate educational, commercial, or other purposes. Fifth, maintain robust security practices including designation of a security coordinator, regular security assessments, testing of security controls, and oversight of service providers. Sixth, maintain written information security programs proportionate to the organization’s size, resources, and the sensitivity of data maintained.
Law enforcement agencies at federal, state, and local levels bear responsibility for investigating and prosecuting identity theft and data breaches with particular attention to crimes targeting children. Recommendations for law enforcement include the following: First, develop or expand specialized units focused on identity theft and cybercrime to provide necessary expertise and investigative capacity. Second, establish protocols for coordination with federal law enforcement agencies including the Federal Bureau of Investigation, the Secret Service, and the Department of Justice for investigation of significant breaches and sophisticated criminal operations. Third, provide training to law enforcement personnel regarding identity theft investigation, digital evidence preservation, and investigation of financial crimes. Fourth, engage in public education efforts to raise awareness of identity theft risks, particularly regarding risks to children, and to provide information regarding how to report suspected identity theft. Fifth, prioritize prosecution of significant identity theft cases, particularly those involving organized criminal enterprises exploiting children’s data at scale.
Legislative bodies at federal, state, and international levels bear responsibility for establishing and strengthening the legal and regulatory frameworks governing children’s data protection. Recommendations include the following: First, enact comprehensive federal privacy legislation establishing uniform baseline protections for children’s data, preempting less protective state laws, and creating consistent requirements for organizations collecting and processing children’s information. Second, strengthen federal breach notification requirements, potentially mandating that organizations notify affected individuals within a specific timeframe of discovering a breach, and establishing penalties for failure to provide adequate notification. Third, establish or strengthen mechanisms for private rights of action, potentially enabling consumers to sue organizations for breaches resulting from failure to implement adequate security measures. Fourth, allocate resources to federal agencies responsible for enforcing privacy and cybersecurity laws to enable expanded monitoring of organizational compliance and investigation and prosecution of violators. Fifth, conduct periodic review and update of privacy and cybersecurity laws to account for technological changes and emerging threat vectors.
Sustaining Child Protection in the Wake of a Breach
Protecting children’s information after data breaches represents one of the defining challenges of the contemporary digital age, reflecting the intersection of exponentially expanding data collection, increasing sophistication of cybercriminal enterprises, and the unique vulnerabilities of childhood in the context of financial systems and digital platforms primarily designed by and for adults. The problem is neither marginal nor theoretical: in 2022 alone, approximately 1.7 million children experienced data breaches, and emerging evidence suggests that the incidence and severity of child identity theft continues to increase.
The response to this challenge cannot rest on a single intervention or a sole stakeholder. Parents and guardians implementing personal protective measures are essential, but individual actions cannot address systemic vulnerabilities in organizational cybersecurity, regulatory gaps, or the sophisticated criminal enterprises that exploit children’s data. Educational institutions must implement robust security measures and transparent data practices, but schools alone cannot establish the security standards necessary to protect student data against sophisticated threat actors. Technology companies must implement privacy-protective design practices and comply with regulatory requirements, but market-based incentives alone have proven insufficient to generate adequate investment in security and privacy protection. Law enforcement must investigate and prosecute identity theft affecting children, but criminal prosecution alone cannot undo the financial and psychological damage experienced by victims. Lawmakers must establish clear, uniform, and adequately enforced legal requirements, but law cannot substitute for the responsible, proactive implementation of security and privacy protection by all stakeholders.
The path forward requires sustained commitment from all sectors to comprehensive, coordinated action in service of the goal that children should be able to navigate and benefit from the digital world without having their personal information exploited for fraud, manipulation, or other harmful purposes. The recent amendments to COPPA, state-level privacy laws increasingly focused on children’s protection, and growing public awareness of child identity theft risks provide cause for cautious optimism that regulatory and institutional attention to child data protection will continue to expand. However, substantial challenges remain, including the fragmentation of regulatory authority, the persistent gap between regulatory requirements and actual organizational compliance, the inadequacy of breach notification and liability mechanisms as incentives for security investment, and the continuing vulnerability of children to identity theft from trusted persons within their own families and communities.
By implementing the protections, monitoring strategies, and remediation procedures outlined in this report—by placing security freezes on children’s credit reports, by monitoring for fraudulent activity, by maintaining open communication with children about online safety, by advocating for stronger institutional security measures and regulatory requirements, and by reporting suspected identity theft to appropriate authorities—parents, institutions, and policymakers can substantially reduce the risk that children’s information will be exploited and can enable faster, more effective response when breaches do occur. The work of child data protection is ongoing, multifaceted, and demanding, but it is among the most important investments a society can make in the future security, prosperity, and wellbeing of its youngest and most vulnerable members.
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