Published by Fractional Coordinator, Inc. | November 2025

Emerging technologies have transformed the way young people learn, communicate, and interact—but they have also created new and deeply harmful avenues for misconduct. Among the most pressing issues facing K-12 institutions today is the non-consensual sharing of intimate images (NCII), including both authentic and AI-generated content.

At Fractional Coordinator, Inc., we help schools navigate these rapidly evolving risks with clarity, compassion, and compliance. Our team has developed a model framework that guides districts in responding to incidents of NCII using equity-centered, trauma-informed, and legally sound practices.

Understanding the Challenge

Across the nation, schools are confronting the growing reality of NCII among students and staff. These cases involve the distribution of authentic or digitally fabricated intimate images without consent—often spread through social media, airdrop, or text messaging. What may begin as a prank can cause lasting harm: reputational damage, emotional trauma, and, in some cases, loss of employment.

The rapid accessibility of AI and image-generation tools has made it easier than ever for students to create convincing synthetic content. Many K-12 institutions are unprepared to address these incidents effectively or consistently, leaving victims without recourse and schools vulnerable to liability.

Where Current Policies Fall Short

Most districts rely on a patchwork of student-conduct policies or outdated technology codes that fail to address the complexity of NCII. The result is inconsistent enforcement and limited protection for those affected. Without clear definitions and investigative procedures, administrators often hesitate to act—especially when incidents occur off-campus or on personal devices.

This gap leaves students and employees exposed to harm and institutions at risk of non-compliance under Title IX and related federal frameworks.

Integrating an Equity-Centered Approach

Fractional Coordinator’s model policy situates NCII within existing civil-rights frameworks, recognizing that digital sexual misconduct can create a hostile environment based on sex or gender. Whether incidents occur on or off campus, schools have an obligation to act when the effects disrupt the educational or workplace environment.

Our recommended process aligns with Title IX-adjacent procedures, allowing schools to respond swiftly without the procedural rigidity of a formal grievance process. This approach emphasizes harm assessment, supportive measures, and institutional accountability—providing clear guidance for administrators, investigators, and coordinators.

Defining the Terms for Consistency

To strengthen clarity and accountability, we use shared language that distinguishes between two categories of harm:

• Synthetic NCII: The creation or alteration of intimate or sexual images using AI or digital manipulation, distributed without consent.

• Authentic NCII: The non-consensual sharing of real, intimate images or videos captured in a private context.

By focusing on distribution rather than creation, the model policy helps schools define jurisdiction clearly and address behaviors that disrupt learning and workplace environments.

Why This Framework Matters

Our approach provides a scalable roadmap that allows K-12 districts to integrate NCII response protocols within their existing compliance infrastructure. It is adaptable, trauma-informed, and consistent with Title IX, FERPA, and applicable state laws.

The framework includes:

• Policy language for integration into student and employee handbooks.

• Guidance on investigative steps, evidence preservation, and privacy.

• Templates for communication with parents and law enforcement.

• Recommendations for takedown requests and online reporting.

Adopting a proactive NCII policy demonstrates leadership, empathy, and a commitment to student and employee safety. It also ensures that schools can respond consistently, minimizing risk while promoting fairness and care.

Taking Action

K-12 leaders don’t need to wait for state mandates to act. Fractional Coordinator, Inc. encourages districts to review their existing technology and harassment policies and integrate this framework as part of their broader equity and compliance strategy.

We also recommend ongoing staff training, student awareness initiatives, and alignment between Title IX, HR, and IT departments to ensure a unified response.

Partnering with Fractional Coordinator

Our consultants work directly with schools and districts to design NCII response protocols tailored to their size, resources, and legal obligations. From policy drafting to investigator training, we help institutions build the internal capacity to respond to digital misconduct with consistency, compliance, and compassion.

To learn more about implementing the Non-Consensual Image Sharing Policy Framework or to request a consultation, visit www.fractionalcoordinator.com or contact support@fractionalcoordinator.com.