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Dear FERPA Professors,

I have something I hadn’t encountered before and am trying to gather some opinions on it. Regarding the recent Canvas hack, the only unit on campus that is using Canvas offers only Continuing Education Units. The university’s FERPA policy states that a student is “an individual currently or previously enrolled in an academic offering” of the university. Our policy manual states that CEUs are “professional development and personal enrichment opportunities.” Does FERPA actually apply in this case?

Sincerely,

Eddie U.


Dear Eddie U.,

If I understand correctly, your university’s established policy does not consider individuals taking CEU courses to be or to have been students in attendance at the University. If that is the case, FERPA would not apply. It has been the policy of the Department that institutions determine when an individual is considered to be a student “in attendance” at the institution. I hope this is helpful.

The FERPA Professor

AACRAO members, send your questions to the FERPA Professor at communications@aacrao.org.

Get the Addendum to the 2012 Guide, “Navigating the Evolving Landscape of Student Privacy Under FERPA: An Addendum to the AACRAO 2012 FERPA Guide,” from the AACRAO Bookstore.

Register for the new webinar series “Navigating the Evolving Landscape of Student Privacy Under FERPA – A Six-Part Webinar Series” running from August 2026 to January 2027.

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