Coursera · Coursera Terms of Use · View original document ↗

FERPA and Student Data

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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

When Coursera provides services to universities or schools, it may handle your student education records and is required to protect them under federal education privacy law (FERPA).

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)

The provision clarifies Coursera's operational status within the FERPA regulatory framework when acting in connection with institutional educational services. This designation determines what procedural obligations and restrictions apply to Coursera's handling of student education records, as FERPA imposes specific requirements on entities functioning as school officials.

Recent Activity

This document changed recently

Medium Jul 3, 2026

The updated refund policy establishes a new condition under which Coursera may deny refund requests: when a significant portion of the course content has been accessed prior to submitting the refund request. This addition does not replace existing denial grounds such as policy violations, repeated refund requests, or chargeback activity, but adds an access-based threshold alongside them. The terms do not define what constitutes a significant portion of content, leaving that determination to Coursera's discretion. Learners who access substantial course materials before requesting a refund may find their request denied under this provision.

View change record →
Medium Jun 30, 2026

The updated terms establish new procedural requirements for refunds on Coursera subscription plans. According to the revised language, canceling a subscription will stop future billing but will not automatically issue a refund; refunds must be requested separately. The terms now explicitly state that refunds will not be provided for renewal charges on annual subscription plans. For Specializations purchased through subscriptions, users may request a full refund within the applicable 7-day refund period or before earning a certificate, whichever occurs first. You can request a refund separately through Coursera's Support Services, but the updated terms indicate this is a manual process rather than an automatic one upon cancellation.

View change record →
Medium May 21, 2026

The updated terms remove the explicit guarantee that Coursera provides a 7-day free trial for subscriptions. The revised language states that 'certain subscriptions may come with a free trial period' without specifying a default duration or which subscriptions include trials. This creates operational uncertainty for users: trial availability and length are no longer stated in the main terms but are now delegated entirely to individual checkout pages. Users evaluating whether a subscription includes a trial must now visit the specific product page rather than relying on the standard terms.

View change record →

Consumer impact (what this means for users)

Students accessing Coursera through an institutional partner should be aware that their educational records — including performance data and course completions — may be shared between their institution and Coursera, and are subject to FERPA's access and amendment rights.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Coursera and its Content Offerings are not directed to children under 13. Coursera works with educational institutions and may act as a school official under FERPA in connection with the educational services it provides to students of those institutions, handling student education records in accordance with FERPA's requirements.

— Excerpt from Coursera's Coursera Terms of Use

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY FRAMEWORK: FERPA (20 U.S.C. § 1232g; 34 C.F.R. Part 99) governs the privacy of student education records held by institutions receiving federal funding. Where Coursera acts as a 'school official' under FERPA, it may access education records under the 'legitimate educational interest' exception without student consent. The DOE's Student Privacy Policy Office (SPPO) has enforcement authority. Additionally, state student data privacy laws — including California's Student Online Personal Information Protection Act (SOPIPA) and similar statutes in New York, Colorado, and Illinois — impose additional obligations on ed-tech vendors. 2)

Full compliance analysis

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

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Applicable agencies

  • Doe
    The DOE's Student Privacy Policy Office enforces FERPA and oversees ed-tech vendors acting as school officials with access to student education records.
    File a complaint →
  • State AG
    State attorneys general enforce state student data privacy laws such as California's SOPIPA and New York Education Law § 2-d against ed-tech vendors handling student data.
    File a complaint →

Provision details

Document information
Document
Coursera Terms of Use
Entity
Coursera
Document last updated
May 5, 2026
Tracking information
First tracked
April 18, 2026
Last verified
April 18, 2026
Record ID
CA-P-002853
Document ID
CA-D-00157
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d67cd5c44e1912191635fd8b7e2198b45b8ec6ab8725f8a00753d9335a136c85
Analysis generated
April 18, 2026 10:12 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coursera
Document: Coursera Terms of Use
Record ID: CA-P-002853
Captured: 2026-04-18 10:12:56 UTC
SHA-256: d67cd5c44e191219…
URL: https://conductatlas.com/platform/coursera/coursera-terms-of-use/ferpa-and-student-data/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Coursera's FERPA and Student Data clause do?

The provision clarifies Coursera's operational status within the FERPA regulatory framework when acting in connection with institutional educational services. This designation determines what procedural obligations and restrictions apply to Coursera's handling of student education records, as FERPA imposes specific requirements on entities functioning as school officials.

How does this clause affect you?

Students accessing Coursera through an institutional partner should be aware that their educational records — including performance data and course completions — may be shared between their institution and Coursera, and are subject to FERPA's access and amendment rights.

Is ConductAtlas affiliated with Coursera?

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