Industries
Education: what your operating records are worth to AI research
An education company's unit of work is the course run: how a class is scheduled, taught and assessed. Student education records that name a learner are never shared. A training company is not automatically a school, and the fit check decides eligibility.
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| Fact | Detail |
|---|---|
| Unit of work | course run |
| First exclusion | student education records that name a learner |
| First rule | Except as noted in 34 CFR 99.10, Part 99 applies to an educational agency or institution to which funds have been made available under any program administered by the Secretary, if the institution provides educational services or instruction, or both, to students, or the agency is authorized to direct and control public elementary or secondary, or postsecondary, educational institutions. eCFR |
| Second rule | Part 99 does not apply to an educational agency or institution solely because its students receive non-monetary benefits under a program administered by the Secretary, if no funds under that program are made available to the agency or institution. eCFR |
What Education operating records look like
Education operating records are the course run, how a class is scheduled, taught, and assessed, and they are not the student file that names a learner.
Opening a course run records the syllabus, the session dates, and the instructor role. Running the sessions records what was taught and which activity slipped. The roster, the grade tied to a name, and the transcript are the learner's file. The run of the class can be discussed once those are gone.
Other sectors are grouped under company data licensing by industry.
The license itself is explained in how to sell company data to AI companies.
Workflows in Education that AI research can learn from
Opening a course run, running the sessions, and recording completion without the learner's identity are three trails inside one course run a team delivers.
- opening a course run
- running the sessions
- recording completion without the learner's identity
Recording completion without the learner's identity shows that a seat finished, not who sat in it. The full run matters because a completion count hides the sessions that were moved.
For a related sector's records, read healthcare company data for AI research or pharma company data for AI research.
Systems Education companies usually run
Docs, mail, and chat hold the instructor side of a course run. A learning system is named only as plain text beside them.
Google Workspace holds the syllabus and the shared deck. Microsoft 365 holds the staff mail about the cohort. Slack holds the instructor handoff. The learning system holds the gradebook and is listed as plain text.
| System | Category | Why it holds this sector's work |
|---|---|---|
| Google Workspace | Email and collaboration | Syllabi and shared decks sit in documents. |
| Microsoft 365 | Email and collaboration | Staff mail about a cohort sits in mail. |
| Slack | Chat | Instructor handoffs sit in chat. |
| learning system | Industry system | Grades and named rosters sit in the learning system. |
What a Education license leaves out
Student education records that name a learner never leave in a license, even when the course run lists them on a roster.
- student education records that name a learner
Student education records that name a learner include the transcript, the grade, and the attendance row with a name. A corporate training vendor is not automatically a school. The fit check still decides, and the named file still stays out.
The details that never leave any company are listed in what is never shared.
Rules cited for Education records
A note about a course run quotes a public source on education records, and it says a training vendor is not automatically a school.
Notes distinguish an educational agency or institution, in the source's words, from a company that only sells training. The same exclusion applies either way: a record that names a learner stays out.
| Rule | What the source says | Source |
|---|---|---|
| 34 CFR 99.1(a) — Who the regulations cover | Except as noted in 34 CFR 99.10, Part 99 applies to an educational agency or institution to which funds have been made available under any program administered by the Secretary, if the institution provides educational services or instruction, or both, to students, or the agency is authorized to direct and control public elementary or secondary, or postsecondary, educational institutions. | eCFR |
| 34 CFR 99.1(b) — When funding alone is not enough | Part 99 does not apply to an educational agency or institution solely because its students receive non-monetary benefits under a program administered by the Secretary, if no funds under that program are made available to the agency or institution. | eCFR |
| 34 CFR 99.3 — Education records | Education records are records directly related to a student and maintained by an educational agency or institution, or by a party acting for the agency or institution. The Act in these regulations means the Family Educational Rights and Privacy Act of 1974, as amended, section 444 of the General Education Provisions Act. | eCFR |
| 34 CFR 99.3 — Records that are not education records | Education records do not include records kept in the sole possession of the maker, used only as a personal memory aid, and not revealed to anyone except a temporary substitute. They also do not include employment records made in the normal course of business that relate only to the person as an employee and are not used for any other purpose. Records of a student employed because of student status are education records. | eCFR |
| 34 CFR 99.3 — Directory information | Directory information means information in a student's education record that would not generally be considered harmful or an invasion of privacy if disclosed. It includes the student's name, address, telephone listing, electronic mail address, photograph, date and place of birth, major field of study, and grade level. It does not include a student's social security number. | eCFR |
| 34 CFR 99.30 — Prior consent to disclose | A parent or eligible student shall provide a signed and dated written consent before an educational agency or institution discloses personally identifiable information from the student's education records, except as provided in 34 CFR 99.31. The consent must specify the records, state the purpose, and identify the party or class of parties who may receive them. | eCFR |
Wind-down specifics for Education
Closing a training company does not turn a named student file into a licensable archive. The course run is the record, and the learner's file stays out.
Export the session plan and the completion counts with names removed. Leave the gradebook out. Ending a cohort does not make the student file an operating record.
- Export the session plan and completion counts with names removed.
- Leave the gradebook out.
- Ending a cohort does not make the student file an operating record.
General information only. This is not legal, tax or financial advice.
Related
- Industries
What operating records look like by sector, and what is left out.
- How to sell company data
How to sell or license company data to AI companies, and which route fits.
- What's shared
Which records can be licensed, which details never leave, and what you approve.
- Eligibility
Staff, records, daily-use systems, and the right to license, plus a checker.
- Estimate
US payout bands by staff at peak, and the estimator that uses them.
- Healthcare
Care-episode workflow, with patient identifiers left out.
- Pharma
Batch and study milestones, with subject identities left out.
Questions about education company data for AI research
Which student education records never leave a school or training company in a license?
Student education records that name a learner never leave a school or a training company in a license. That includes the transcript, the grade, and the attendance row with a name. The course run can be described: how the class was scheduled, taught, and assessed. The gradebook is not the course run. The same exclusion applies whether or not the company is a school.
When is a course run an operating record instead of a learner file?
A course run is an operating record when it shows the syllabus, the session dates, the instructor role, and which activity slipped, without naming the learner. Opening a course run, running the sessions, and recording completion without the learner's identity are the trails. A completion count that still contains names is a learner file. Strip the names and the count can remain.
Does a corporate training vendor follow the same limits as a school?
A corporate training vendor is not automatically a school. The limit on named learner records is the same either way: student education records that name a learner stay out. The vendor is not told yes because it sells courses. The fit check decides. A roster with names is out for the vendor just as it is out for a school.
Which learning and email systems should an education company map before a license?
Map Google Workspace for the syllabus and the shared deck, Microsoft 365 for staff mail about the cohort, and Slack for the instructor handoff. The learning system holds the gradebook and is listed as plain text. Map it too, and leave the named grades out. Canceling the mail suite does not make the gradebook an operating record.
Sources
- eCFR. 34 CFR 99.1(a) — Who the regulations cover. Checked 2026-11-04
- eCFR. 34 CFR 99.3 — Education records. Checked 2026-11-04
- eCFR. 34 CFR 99.30 — Prior consent to disclose. Checked 2026-11-04