Coursera · Coursera Privacy Notice · View original document ↗

Sharing Learner Data with Institutional Clients

High severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Coursera recorded 2 documented changes in the last 30 days.
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Document Record

What it is

If your employer or school pays for your Coursera account, they may be able to see which courses you have taken, whether you completed them, and how far you have progressed.

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)

Many users may not realize that enrollment through an employer or university program means their learning activity is visible to that organization, which could affect employment or academic assessments.

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)

This provision means that course enrollment choices, completion status, and learning progress data may be accessible to an employer or institution, which could be reviewed in performance or academic contexts.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Contact Coursera at privacy@coursera.org to request a copy of the personal data Coursera holds about you, including what has been shared with your institutional client.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you are accessing Coursera through a subscription purchased by your employer, educational institution, or other organization, that organization may have access to certain information about your activity on Coursera, including the courses you've started and completed, and your progress through courses.

— Excerpt from Coursera's Coursera Privacy Notice

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision engages GDPR Articles 13 and 14 (transparency obligations), FERPA where the institutional client is an educational institution and Coursera acts as a school official or service provider, and CCPA where California-resident employees are enrolled through employer subscriptions. The relevant enforcement authorities include EU supervisory authorities, the U.S. Department of Education (FERPA), and the California Privacy Protection Agency. GOVERNANCE EXPOSURE: High. The data flow from Coursera to institutional clients (employers and universities) covering individual learner performance creates significant compliance obligations. Employers accessing employee learning data may trigger additional obligations under applicable employment law depending on jurisdiction, and the adequacy of notice to individual learners at the point of enrollment varies by implementation. JURISDICTION FLAGS: EU/EEA users have heightened rights under GDPR, including the right to be informed of this data flow at the time of collection. California employees enrolled by employers may have rights under CPRA regarding employee personal information. The UK GDPR imposes similar transparency requirements. In some EU member states, works council or employee representative consultation may be required before employer monitoring of learning activity. CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should review whether Coursera's data processing agreements with institutional clients specify the scope and granularity of learner data accessible to the client organization, and whether individual learner consent or notice obligations are clearly allocated between Coursera and the institutional client. Liability for inadequate notice to employees may sit with either party depending on contractual terms. COMPLIANCE CONSIDERATIONS: Institutional clients should audit their internal policies to ensure employees are informed that their Coursera activity is visible to the organization. FERPA-covered institutions should confirm Coursera's role as a legitimate educational interest service provider is documented. GDPR-covered organizations should verify that data processing agreements under Article 28 adequately describe this sharing arrangement.

Full compliance analysis

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

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Applicable agencies

  • Doe
    FERPA may apply where the institutional client is an educational institution and Coursera acts as a service provider handling student education records.
    File a complaint →
  • FTC
    The FTC has authority over unfair or deceptive practices related to consumer data sharing disclosures that may not be sufficiently prominent.
    File a complaint →

Applicable regulations

EU AI Act
European Union
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 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009416
Document ID
CA-D-00158
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
59834b4e08e538f4b11e3db8b297dc7b75811100ba60ce40b60950ff40b3b3a6
Analysis generated
May 10, 2026 18:17 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coursera
Document: Coursera Privacy Notice
Record ID: CA-P-009416
Captured: 2026-05-10 18:17:25 UTC
SHA-256: 59834b4e08e538f4…
URL: https://conductatlas.com/platform/coursera/coursera-privacy-notice/sharing-learner-data-with-institutional-clients/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Coursera's Sharing Learner Data with Institutional Clients clause do?

Many users may not realize that enrollment through an employer or university program means their learning activity is visible to that organization, which could affect employment or academic assessments.

How does this clause affect you?

This provision means that course enrollment choices, completion status, and learning progress data may be accessible to an employer or institution, which could be reviewed in performance or academic contexts.

Is ConductAtlas affiliated with Coursera?

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