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Enforcement ActionLow RiskMultistate

State AGs Sue Education Dept Over IPEDS Student Privacy Risks

Department of EducationMarch 11, 2026Oregon Attorney General

Summary

Privacy enforcement action where Oregon AG and a coalition of 16 other states sue the Trump Administration to stop the Department of Education's new IPEDS data reporting requirements, arguing they jeopardize student privacy, lack proper definitions, and risk data errors and identification.

Remedy

Seeking an injunction to block the Department of Education from implementing the new IPEDS data collection requirements and retroactive reporting demands.

Injunction

Contract Impact

In-house legal teams should review all agreements where the entity (e.g., colleges/universities) receives federal financial aid or handles student data, including federal aid compliance agreements, data processing addendums with the Department of Education, and vendor contracts involving student information. Specific clauses to scrutinize include data submission obligations, accuracy warranties, audit rights, indemnification for reporting errors, and privacy safeguards. Given the lawsuit's focus on rushed implementation, lack of definitions, and privacy risks, contracts may need amendments to: (1) define new data elements (e.g., race-neutral admissions criteria) clearly; (2) implement data validation and error-correction protocols; (3) restrict data use strictly to compliance with the stated IPEDS purpose; (4) address liability for inadvertent errors; and (5) ensure alignment with existing student privacy laws like FERPA, even if not explicitly cited.

Contract Search Terms

IPEDS compliance clausestudent data disclosure requirementsfederal survey mandatedata accuracy certificationprivacy safeguard for student recordsrace-neutral admissions reportingregulatory change notificationaudit rights for federal reportingdata error liabilitySupreme Court decision implementation

Violation Types

Entity Details

Entity

Department of Education

Industry

Other

Multistate Coalition

CaliforniaColoradoConnecticutDelawareHawaiʻiIllinoisMarylandMassachusettsNevadaNew JerseyNew YorkRhode IslandVermontVirginiaWisconsinWashington

Official Sources

Source Evidence

Entity Name
"Department of Education"
Violation Types
"jeopardize student privacy and could lead to individuals being easily identified"

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