Coursera · Coursera Privacy Notice · View original document ↗

Enterprise and Campus Customer Data Disclosure

High severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Coursera recorded 7 documented changes in the last 30 days.
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Document Record

What it is

The policy states that when access is sponsored by an employer or educational institution, Coursera may share the user's name, enrollment records, course progress, completion status, and assessment performance with that sponsoring organization.

This analysis describes what Coursera's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that employers or educational institutions sponsoring platform access may receive identifiable learner performance data including assessment results, which creates operational implications for employee privacy expectations and institutional data governance obligations. The scope of permissible disclosure to enterprise customers warrants evaluation under applicable employment privacy laws, FERPA, and GDPR depending on the jurisdiction and nature of the sponsoring organization.

Recent Activity

This document changed recently

Medium May 11, 2026

The updated terms now explicitly disclose that Coursera processes communications through voice-enabled features that transcribe audio into text, and clarify that personal data may be shared with third parties including affiliates and business partners. The policy expands descriptions of AI-driven personalization and chatbot applications that use your learning and interaction data. The terms establish that data may be transferred to entities that become Coursera affiliates or subsidiaries during business transitions. You should review the updated guidance that cautions against including unnecessary or sensitive personal data in the platform's free-text and voice-enabled communication features.

View change record →
Medium Apr 18, 2026

The updated Privacy Notice removes explicit language stating that the policy does not apply to Coursera's Ollie mobile application and no longer directs users to a separate Ollie Privacy Notice for that app. Previously, users of Ollie had clear notice to consult a dedicated privacy policy; that direction is now absent from the main Privacy Notice. The updated notice also narrows the scope of covered entities by removing 'affiliates' from the definition of Coursera, stating the policy now applies to Coursera, Inc., its subsidiaries, and international branches only. Users of the Ollie App should independently verify what privacy terms currently govern that application, as the main Coursera Privacy Notice no longer explicitly addresses Ollie coverage.

View change record →

Consumer impact (what this means for users)

Under this clause, users whose Coursera access is sponsored by an employer or educational institution may have their course enrollment, progress, completion, and assessment performance disclosed to that organization. The agreement does not establish a user-controlled opt-out mechanism for this disclosure category.

How other platforms handle this

Telegram Medium

By issuing a chargeback or refund request for Premium subscriptions paid for through a third party, you agree to allow Telegram to release necessary data to that third party regarding your account status and Telegram Premium purchases.

Grubhub Medium

For campus users only, we may provide identifiers to select food service providers that operate restaurants and other food ordering and delivery services on your campus so that they can communicate directly with you and send you personalized communications and marketing. Please see Section 2.1 below...

YouTube Kids Medium

We will share individual user information with companies, organizations or individuals outside of Google if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable govern...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you access Coursera through your employer or another organization (an "Enterprise Customer"), or if someone else is paying for your access, we may share information about your use of Coursera with that organization. This may include your name, the courses you've enrolled in, your progress and completion, and your performance on assignments and assessments.

— Excerpt from Coursera's Coursera Privacy Notice

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision engages GDPR in EU/EEA employment contexts, where employee monitoring and data sharing obligations may require a higher standard of lawful basis. FERPA applies where the enterprise customer is an educational institution receiving student record information. State employment privacy laws in California and Illinois may also be relevant. GOVERNANCE EXPOSURE: High. Disclosure of assessment performance and course completion to employers creates potential tension with employee privacy expectations and applicable employment data regulations. In GDPR jurisdictions, the lawful basis for sharing assessment performance data with employers requires careful documentation, as legitimate interest may be challenged where processing affects employee rights. JURISDICTION FLAGS: EEA and UK users in enterprise deployments face the most significant exposure given GDPR employment data processing requirements. California employees may have rights under CPRA. Educational institutions acting as enterprise customers in the US must assess FERPA implications for student record disclosures. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customer contracts should specify the categories of data received, permissible uses, retention limits, and downstream sharing restrictions. Procurement teams should confirm whether Coursera's enterprise agreement includes data processing terms satisfying GDPR Article 28 and whether the enterprise customer's own privacy obligations are addressed. COMPLIANCE CONSIDERATIONS: Organizations deploying Coursera for employee learning should update internal privacy notices to disclose that assessment and completion data is shared with Coursera and may be returned to the organization. GDPR-subject employers should confirm the lawful basis documented for receiving and using this data. FERPA-subject institutions should assess whether receiving this data is consistent with their institutional privacy policies.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over consumer and employee data privacy practices and adequacy of notice under the FTC Act.
    File a complaint →
  • Doe
    Where enterprise customers are educational institutions, FERPA compliance for student record disclosures falls under Department of Education oversight.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Coursera Privacy Notice
Entity
Coursera
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-013104
Document ID
CA-D-00158
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0be9e4add991830bce51b20853881ea92a941d97b5fa2cd494958ad1d6aefe2f
Analysis generated
May 21, 2026 05:07 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coursera
Document: Coursera Privacy Notice
Record ID: CA-P-013104
Captured: 2026-05-21 05:07:28 UTC
SHA-256: 0be9e4add991830b…
URL: https://conductatlas.com/platform/coursera/coursera-privacy-notice/enterprise-and-campus-customer-data-disclosure/
Accessed: May 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Coursera's Enterprise and Campus Customer Data Disclosure clause do?

This provision establishes that employers or educational institutions sponsoring platform access may receive identifiable learner performance data including assessment results, which creates operational implications for employee privacy expectations and institutional data governance obligations. The scope of permissible disclosure to enterprise customers warrants evaluation under applicable employment privacy laws, FERPA, and GDPR depending on the jurisdiction and nature of the sponsoring …

How does this clause affect you?

Under this clause, users whose Coursera access is sponsored by an employer or educational institution may have their course enrollment, progress, completion, and assessment performance disclosed to that organization. The agreement does not establish a user-controlled opt-out mechanism for this disclosure category.

Is ConductAtlas affiliated with Coursera?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Coursera.