Student Identity Verification for Enrollment through Third-Party Learning Platforms

Effective: January 1, 2026 (interim)

Approved by: Justin Schwartz, Chancellor

Policy Owner: Provost and Executive Vice Chancellor for Academic Affairs

Policy Contact: Vice Chancellor and Executive Vice Provost for Academic Resource Management

Supersedes: N/A

Applies to: Students

I. Introduction

The University of Colorado Boulder (CU Boulder) offers a range of courses and academic credentials delivered and supported online through approved third-party vendors. These offerings extend access to education beyond the physical campus and support CU Boulder’s commitment to serving a wider learner population. As part of the admissions process for these online courses and academic credentials, CU Boulder verifies student identity in adherence to all applicable laws, regulations, accreditor standards and institutional policies governing online education.

This policy establishes the standards, definitions and procedures governing identity verification for students accessing CU Boulder courses or academic credentials online through the third-party Coursera learning platform.

II. Definitions

Account creation: The process to establish a new user profile or record in a system, which can be a digital platform or an accounting system.

Authentication: The process of validating that a student’s credentials or identifying information match an approved record, confirming that the individual accessing a system or service is the verified student.

Fraud indicators: Patterns, behaviors or data points that suggest an individual may be attempting to use a false or stolen identity to gain unauthorized access or commit fraud.

Higher Learning Commission (HLC): And accrediting agency recognized by the U.S. Department of Education that accredits postsecondary institutions based on established criteria for quality, effectiveness, governance, financial responsibility and student learning. CU Boulder is accredited by HLC.

Identity evidence: The set of documents or digital attributes, including government-issued IDs or authoritative data sources, used to substantiate a person’s claimed identity in accordance with NIST identity-proofing standards.

Identity proofing: The initial process of establishing a reliable link between a person and their digital identity.

National Institute of Standards and Technology (NIST): The U.S. federal agency that issues widely recognized standards for cybersecurity, identity proofing and authentication, which CU Boulder references to ensure secure and reliable identity-verification processes.

Online course, academic program or academic credential: A course, degree, certificate, micro-credential or other academic credential in which the required instruction, learning activities and interactions are delivered through online technologies rather than through in-person, campus-based instruction.

Personally identifiable information (PII): Any data that can identify, contact or locate an individual, either directly or when combined with other information, including names, dates of birth, identification numbers, addresses, biometric data and other unique personal attributes.

Student identity verification: The process of confirming a student or prospective student is who they claim to be through approved methods such as government-issued identification, personal information validation or secure authentication tools

The Family Educational Rights Privacy Act (FERPA): The federal law that grants students rights over their education records and requires institutions to protect those records from unauthorized access or disclosure.

Third-party vendor: An external entity engaged by CU Boulder to perform functions related to the delivery, administration or support of online education, such as hosting course content, verifying student identities or providing technological infrastructure. Examples include Coursera (online learning platform) and Persona (identity-verification service).

III. Policy Statement

Responsibilities for Student Identity Verification for Online Courses, Academic Programs and Academic Credentials Offered through a Third-Party Learning Platform
1. CU Boulder is responsible for ensuring that each person who registers for, enrolls in or participates in an online course, academic program or academic credential offered through a third-party learning platform is a real, identifiable person and that the academic work submitted and credit awarded accurately reflect that person's efforts.
2. The responsibility for student identity verification applies to all online courses, academic programs and academic credentials delivered or supported through a third-party learning platform, including credit-bearing, noncredit and professional education.
3. The student identity verification process must certify that:
  1. The person who creates a student account or registers in a course or academic program or credential is a real person, and the identity information provided is accurate, complete and belongs to the registrant.
  2. The person who accesses CU Boulder systems, participates in online learning activities and completes academic work is the same person who registered and enrolled.
  3. The person who earns academic credit, grades or credentials (e.g., a degree, certificate or micro-credential) is the same person who engages in the coursework and assessments.
  4. The person is not located in an embargoed country or any jurisdiction where the CU Boulder is prohibited from delivering online education.
4. CU Boulder must cross-verify through periodic reviews that student accounts related to online courses, academic programs or academic credentials represent accurate core student identity attributes and must disable unenrolled or inactive accounts.
5. It is the responsibility of the CU Boulder organizational unit that delivers goods or services to students to ensure procedures are in place to prevent delivery of goods or services to a person who registers for, enrolls in or participates in an online course, program or academic credential and whose student identity cannot be verified.
Scope of Student Identity Verification and Verification Process Auditing for Online Courses, Academic Programs and Academic Credentials Offered through a Third-Party Learning Platform
1. CU Boulder must employ a tiered and comprehensive approach to student identity verification, beginning at the point of application and continuing throughout a student’s engagement in online courses, academic programs and academic credentials. Student identity verification must occur:
  1. After application submission but prior to account creation to ensure a genuine registrant.
  2. Throughout participation in the online course, academic program or academic credential.
2. Student identity verification must include:
  1. Cross-verification of all core identity attributes between application forms and identity verification platforms.
  2. CU Boulder organizational units that maintain identity verification processes must continuously monitor and periodically audit those processes to identify emerging threats and potential or actual process failures.
Acceptable Methods of Verification
1. CU Boulder may verify student identity through secure authentication and, where appropriate, supplemental identity-proofing and identity-verification methods.
2. All student identity verification methods used must protect student privacy, comply with federal and state law and accreditor expectations and uphold the integrity of student academic records.
3. CU Boulder organization units, including academic units, and contracted third-party vendors may not implement additional or alternative methods without explicit approval from the Division of Academic Affairs.
Third-Party Vendor Compliance Requirements
1. All third-party vendors involved in student account creation; student identity verification; provision of a learning platform or learning management system, online instruction, proctoring, or assessment delivery; or online student support must:
  1. Comply with FERPA and applicable federal and state privacy laws;
  2. Meet all University of Colorado (CU) and CU Boulder data-protection, cybersecurity and information governance standards;
  3. Adhere to all contractual security requirements, including secure storage, access controls, encryption and breach-notification obligations;
  4. Limit their use of student PII exclusively to:
    1. Identity verification;
    2. Authentication;
    3. Instructional delivery and support;
    4. Provision of contracted services; and
    5. Other purposes explicitly authorized by CU and CU Boulder;
  5. Implement robust technical and administrative safeguards to protect student data; and
  6. Permit the CU Boulder to conduct oversight activities, including security reviews, compliance checks and performance monitoring.
Consequences of Non-Compliance
1. CU Boulder organizational units, departments, programs including academic units, or third-party vendors found to be in violation of this policy may be required to implement corrective actions, including, but not limited to:
  1. Mandatory training or retraining;
  2. Revision of processes or procedures;
  3. Adoption of approved identity verification methods; and
  4. Enhanced monitoring or temporary restrictions on online course or program delivery.
2. CU Boulder may modify, suspend or terminate vendor agreements with third-party vendors found to be in violation of this policy.
Actions for Students Whose Identity Cannot be Verified
1. A student whose identity cannot be verified may be required to submit additional identity evidence or complete an alternative verification process which may include:
  1. In-person identity verification;
  2. Verification through a trusted data source; and
  3. Other approved methods.
2. A student whose identity cannot be verified may be granted provisional access limited to basic onboarding functions (e.g., orientation materials) or placed on an enrollment hold preventing the following:
  1. Registration;
  2. Participation in online courses;
  3. Submission of assignments or assessments; and
  4. Access to student record systems.
3. If CU Boulder determines that a student’s identity cannot be verified after reasonable attempts to resolve discrepancies, the student may be:
  1. Denied enrollment in the course or program;
  2. Administratively withdrawn; or
  3. Prevented from receiving academic credit, grades or academic credentials (e.g. degrees, certificates or micro-credentials).
4. A student who is found to have intentionally misrepresented their identity or used another person’s credentials may face disciplinary action up to and including expulsion, and may incur additional criminal, civil or administrative sanctions.
5. CU Boulder must notify the student of any adverse action related to identity verification and must provide an opportunity to appeal or submit additional documentation consistent with this policy. Appeals must be initiated within the period established in the procedure.

IV. Roles and Responsibilities

Division of Academic Affairs: Ensure academic programs and course designs incorporate approved verification methods; oversee faculty training.

Office of Information Technology (OIT): Maintain secure authentication systems; review and approve third-party vendors; perform periodic security reviews; monitor security incidents.

Office of Academic Planning and Assessment: Oversee policy implementation; maintain documentation for HLC and SARA; coordinate periodic audits and Federal Compliance reviews.

Office of the Registrar: Oversee students’ academic records; disablement of dormant accounts.

Third-Party Vendors: Comply with CU and CU Boulder standards for identity verification, privacy and data protection under written agreement.

V. Related policies, forms and guidelines

VI. History

Adopted: January 1, 2026 (interim)
Revised: N/A
Last Reviewed: June 30, 2026

Search

Other ways to search:

Student Identity Verification for Enrollment through Third-Party Learning Platforms