The Center for Democracy & Technology has developed a model policy for TK-12 districts in response to the proliferation of real and deepfake imagery that is being used to harass students.

Sexually explicit images and videos — whether authentic or generated using AI technology — are called non-consensual intimate imagery or NCII, and it’s a growing problem in schools, according to the Center for Democracy & Technology. Forty percent of students and 29 percent of teachers say they know of a deepfake depicting individuals associated with their school being shared in the past school year, according to a report the center published last year.

The images, usually shared via social media or text, may be more common than teachers or parents are aware of because incidents aren’t coming to the attention of authority figures, “leaving nearby parents and teachers in the dark about the extent of this issue.”

Survey data from the report shows that female students and LGBTQ+ students are the most likely victims of NCII, however these groups also report less confidence in school officials to respond to these incidents.

While students are the most likely perpetrators and victims in NCII, the report also acknowledges that adults in schools can also be a target. Among teachers who have heard about deepfake NCII being shared at their school, 43 percent say that a teacher, administrator, or other school staff member was depicted compared to 58 percent who say that a student was depicted, according to the report.

Schools aren’t doing enough to get ahead of the issue, according to the report. Few teachers report that they have received policies on how to address NCII or that schools are doing a good job to educate students on the harms associated with this type of harassment. Survey data show that schools that have had an NCII incident are twice as likely to have policies and procedures in place than those schools that haven’t.

“This suggests that schools are reactively addressing deepfake NCII and creating policy when it happens, but not before,” according to the report.

Schools can take preventative measures, such as including NCII in Title IX policies and addressing the issue as a part of broader sexual harassment or digital citizenship efforts. Schools can also provide more resources to victims and involve parents in NCII policymaking.

The Center for Democracy & Technology has developed a model policy for schools to use in student/employee handbooks and parental notices. Access this resource at content.acsa.org/model-non-consensual-intimate-imagery-ncii-policy-for-k-12-schools.