SEVIS Privacy Impact Assessment

Privacy Impact Assessment
for the

Student & Exchange Visitor Information
System II
December 4, 2009
Contact Point
James Dinkins
Director, Office of Investigations
U.S. Immigration and Customs Enforcement
(202) 732-5100
Reviewing Official
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security
(703) 235-0780

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Abstract
The Department of Homeland Security U.S. Immigration and Customs Enforcement (ICE) is
developing the Student & Exchange Visitor Information System II (SEVIS II) as a modernization effort to
address limitations in the original SEVIS immigration benefits tracking tool. SEVIS II is an information
system that tracks and monitors students, exchange visitors, and their dependents that are in the U.S. on F,
M, or J classes of admission throughout the duration of approved participation within the U.S. education
system or designated exchange visitor program. SEVIS also maintains information on the schools,
exchange visitor program sponsors, and their representatives. ICE is conducting this Privacy Impact
Assessment (PIA) to document publicly the privacy protections that are in place within the system
because SEVIS II collects, maintains, and provides personally identifiable information (PII) in the
execution of its mission. SEVIS II will be deployed in two phases; however this PIA describes the system
as it will be fully deployed.

Overview
The Student and Exchange Visitor Program (SEVP), a division of the ICE Office of
Investigations, owns SEVIS II. SEVIS II supports the application and admission of foreign nationals who
seek to come to the U.S. as students and exchange visitors under F, M, or J classes of admission. SEVIS
II maintains PII about these foreign nationals and any dependents that come with them to the U.S. In
addition, SEVIS II maintains PII about officials of approved schools and designated exchange visitor
program sponsors as well as American families who host nonimmigrant students and exchange visitors.
SEVIS II will deploy in two phases; the first phase will likely occur in 2010 and will allow
SEVIS II users, such as students, exchange visitors, schools and sponsors, to establish their SEVIS II
customer accounts on a voluntary basis. The personal data collected from individuals during the first
phase is limited to user account data (described in Question 1.1). The first phase will also support the
periodic migration of SEVIS data to SEVIS II. During the first phase, users that elect to establish SEVIS
II accounts may view their migrated record and request correction of any incorrect information. The
original SEVIS system will remain operational during the first phase.
The second and final phase of SEVIS II deployment will occur at a date yet to be determined.
This phase will implement all other SEVIS II functionality as described in this PIA and SEVIS II will
become the system of record in which all student and exchange visitor transactions described in this PIA
will occur. With the full deployment of SEVIS II, ICE will migrate all data from and retire the original
SEVIS system.
Background
The U.S. has a history of welcoming foreign nationals into our country as students or exchange
visitors. While they stay for an extended period, the U.S. considers them nonimmigrant, temporary
visitors.
When nonimmigrants apply for admission to the U.S., they must declare their primary purpose
for visiting. Based upon that purpose, U.S. immigration law recognizes a number of classes of admission,

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such as those for tourists and business travelers. For foreign students and exchange visitors, the U.S.
immigration law recognizes the following three classes of admission:
F-1 Admission: For foreign students pursuing a full course of study in a college, university,
seminary, conservatory, academic high school, private elementary school, or other academic
institution or language training program in the U.S. that SEVP has certified to enroll foreign
students.
M-1 Admission: For foreign students pursuing a full course of study in a U.S. vocational or other
recognized nonacademic institution (e.g., technical school) that SEVP has certified to enroll
foreign students.
J-1 Admission: Foreign nationals who are selected by a Department of State (DOS)-designated
Exchange Visitor Program sponsor to participate in an exchange visitor program in the U.S.1
F-1, M-1, and J-1 nonimmigrants may bring their eligible spouse and dependent children
(hereafter, dependents) with them for the duration of their stay. Dependents of F-1, M-1, or J-1
nonimmigrants are admitted to the U.S. under a corresponding class of admission: F-2, M-2, or J-2. Their
purpose for visiting is to accompany or are following to join the F-1, M-1, or J-1 nonimmigrant (the
principal nonimmigrant for the family). Dependents may stay only as long as the principal nonimmigrant
maintains legal immigration status.
A foreign national who wishes to come to the U.S. as a foreign student or exchange visitor on an
F-1, M-1, or J-1 class of admission must do all of the following:
Apply to and be accepted by an SEVP-certified school or a DOS-designated Exchange Visitor
Program sponsor.
Obtain a student or exchange visitor visa from an embassy or consulate abroad or, if from a visa
exempt country (e.g., Canada or Bermuda), apply for admittance at a U.S. port of entry (POE), or
if already in the United States in another nonimmigrant class of admission, obtain a change of
status to F, M, or J from U.S. Citizenship and Immigration Services (USCIS).
In addition, F and M nonimmigrants must be able to pay the cost of schooling and living expenses
while in the U.S. and furnish proof of sufficient funding to the school.
F/M/J nonimmigrants must comply with federal regulations that are specific to their class of
admission. These regulations dictate eligibility requirements, required activities, and prohibited activities.
F/M/J nonimmigrants who do not continue to comply with these requirements are ―out of status,‖ and
they and their dependents cannot remain in the U.S.
The Student and Exchange Visitor Program and the Office of Private Sector Exchange
1

The DOS Exchange Visitor Program is an international exchange program that implements the Mutual
Educational and Cultural Exchange Act of 1961, as amended, by means of educational and cultural exchanges. The
purpose of the Program is to provide foreign nationals with opportunities to participate in educational and cultural
programs in the United States and return home to share their experiences, and to encourage Americans to participate
in educational and cultural programs in other countries. Exchange visitor programs vary and include au pairs,
professors, and trainees in various occupational categories.

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Two separate federal offices work collaboratively on issues involving the regulation of the
student and exchange visitor process in the U.S. Those offices are ICE’s SEVP and DOS’s Office of
Private Sector Exchange (OPSE) in the Bureau of Educational and Cultural Affairs.
ICE’s SEVP is responsible for certifying academic and technical schools in the U.S. that seek to
bring F or M nonimmigrants to study at their school. SEVP determines if the school meets the regulatory
requirements for certification. The schools designate officials who are responsible for updating SEVIS II
(and previously, SEVIS) with current school-related information on F and M students. SEVP also
monitors certified schools to ensure compliance with reporting and recordkeeping requirements. SEVP
has an intensive outreach program to ensure that school officials have the information and training to
comply with all requirements. In addition, SEVP manages the fees collected from F/M/J nonimmigrants.
It also manages and operates SEVIS II and is responsible for maintaining and updating the section of
federal regulations dealing with Aliens and Nationality (Title 8, Code of Federal Regulations) that pertain
to F/M/J nonimmigrants and SEVP-certified schools.
DOS’s OPSE administers the Exchange Visitor Program, which governs the allowed activities of
nonimmigrants in the J class of admission. OPSE designates an Exchange Visitor Program applicant to
conduct an Exchange Visitor Program as a sponsor and determines which categories of exchange visitors
they may sponsor. OPSE also monitors the compliance of sponsors with DOS regulations and DHS
regulations on immigration. OPSE works closely with SEVP in the ongoing development of SEVIS II
capabilities.
The Student and Exchange Visitor Information System
Congress passed the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) in
1996 (Public Law 104-208) that authorized the former Immigration and Naturalization Service (INS) to
create an electronic system to collect information on F/M/J nonimmigrants. The system was to support
INS efforts to determine how many F/M/J nonimmigrants2 are in the country, where they are, and what
they are studying. After September 11, 2001, Congress updated the legislation mandating the use of an
electronic system to collect information on all F/M/J nonimmigrants.
To meet this mandate, the Department of Homeland Security (DHS) and the DOS developed
SEVIS, which deployed in January 2003. DHS published a PIA for SEVIS on February 5, 2005. SEVIS is
a web-based information system that tracks and monitors F/M/J nonimmigrants and dependents
throughout the duration of approved participation within the U.S. education system or designated
exchange visitor program. SEVIS maintains records on these nonimmigrants and receives updated
information from schools and sponsors, such as change of domestic address and changes in program
study. SEVIS also maintains information on the schools, exchange visitor program sponsors, and their
representatives.
Creation of SEVIS II

2

SEVIS II does not track all cultural exchange visitors and all foreign students; it tracks only nonimmigrants
admitted under F/M/J classes of admission. In some cases, nonimmigrants who are students or exchange visitors are
in the U.S. on other classes of admission. As such, this PIA will use the term ―F/M/J nonimmigrant‖ rather than the
terms foreign students and exchange visitor to avoid confusion.

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SEVIS II is a modernization effort to address limitations in the original SEVIS application.
SEVIS II improves on the existing system in several areas. First, SEVIS II creates an entirely paperless
process for all activities related to the admission and tracking of F/M/J nonimmigrants. Under SEVIS II,
F/M/J nonimmigrants, school, and sponsor officials will use digital signatures to sign electronic forms
related to the student and exchange visitor process. Government officials will also use SEVIS II—or a
system that links to SEVIS II—to document electronically decisions about visa issuance, changes of
status, entry into the U.S., and other requests for nonimmigrant benefits (e.g., employment authorization).
Second, SEVIS II permits F/M/J nonimmigrants to create user accounts and directly access their
own information in the system. This feature of SEVIS II permits F/M/J nonimmigrants to view
information about their status, immigration benefits, and payment of SEVP fees. F/M/J nonimmigrants
will also be able to view their own information in the system in real time and request that SEVP make a
change if it is inaccurate.
Third, SEVIS II creates a new, person-centric recordkeeping system that will unify information
about the same F/M/J nonimmigrants that the original SEVIS maintained in multiple records. SEVIS II
seeks to unify records about the same individuals by using immigration identification numbers (IINs)
assigned to F/M/J nonimmigrants through the activation of SEVIS II accounts. SEVIS II also obtains the
Fingerprint Identification Number for F/M/J nonimmigrants from the DHS’s U.S. Visitor and Immigrant
Status Indicator Technology’s (US-VISIT’s) Automated Biometric Identification System (IDENT). The
Fingerprint Identification Number is an assigned numeric identifier linked to the F/M/J nonimmigrant’s
fingerprints, which are collected as part of the visa application process and/or upon admission to the U.S.
SEVIS II uses the Fingerprint Identification Number to maintain the one-person, one-record system;
however, SEVIS II does not collect, store, or process actual fingerprints or other biometric information.
Fourth, SEVIS II generates and displays an admissibility indicator for each F/M/J nonimmigrant
that reflects whether they are currently eligible for admission into the U.S. under the terms of their F/M/J
class of admission. F/M/J nonimmigrants may view their admissibility indicator in SEVIS II before
traveling to the U.S. to confirm that they are eligible to enter the U.S. at that time. To generate the
admissibility indicator, SEVIS II uses the information already in the system and a set of business rules to
determine if the individual is currently eligible to enter the U.S. as an F/M/J nonimmigrant. SEVIS II
exports the admissibility indicator to the U.S. Customs and Border Protection (CBP) TECS system to
allow CBP officers to view the admissibility indicator when the F/M/J nonimmigrant arrives at the border
and requests admission. The CBP officer uses the admissibility indicator as one factor in determining if
the individual may enter as an F/M/J.
Finally, SEVIS II indicates whether a nonimmigrant is eligible for employment in the U.S. under
the terms of his or her F/M/J class of admission. USCIS’s E-Verify system queries SEVIS II in response
to a request for an employment authorization.3 SEVIS II uses information already in the system and a set
of business rules to determine if the nonimmigrant is eligible for employment, the maximum allowable
length of employment, and (if applicable) the allowable location for employment under the terms of his or
her F/M/J admission. This information is sent to E-Verify.
3

E-Verify is an Internet-based system operated by USCIS in partnership with the Social Security Administration
that allows participating employers to electronically verify the employment eligibility of their newly hired

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SEVIS II Users
There are three categories of SEVIS II users. The first category is comprised of F/M/J
nonimmigrants and persons serving as proxies or parents/guardians. These users must have a customer
account and an IIN. F/M/J nonimmigrants can view any pending request for benefits, initiate requests for
certain actions from their school or sponsor officials, request corrections of data that appears incorrect,
determine whether they are eligible to travel and enter/re-enter the U.S., view fee payment information,
and determine whether SEVIS II indicates they are in or out of F/M/J status. Dependents may elect to
either create their own SEVIS II accounts or allow the principal nonimmigrant to manage the process on
behalf of the entire family; however, anyone over the age of 14 will be required to access their account in
order to electronically sign their SEVIS II record. In certain circumstances, a proxy, parent, or guardian
may create and maintain the SEVIS II account for select F/M/J nonimmigrants that are under the age of
14 or are unable to access SEVIS II.
The second category of SEVIS II users represent the schools and sponsors. These users must have
a customer account and an IIN. Schools and sponsors initially use SEVIS II to apply for certification or
designation that will allow them to enroll or sponsor F/M/J nonimmigrants. In SEVIS II, they enter
information that government officials use to make the certification or designation decision. After
certification or designation, selected employees become the designated or responsible officials. These
employees must U.S. citizens or lawful permanent residents of the United States. They use SEVIS II to
update school and sponsor information, input information on F/M/J nonimmigrant applicants, and record
information on events that relate to a nonimmigrant’s status, such as enrollment, failure to enroll in a full
course of study, failure to report to a program, or completion of a course of study or program. They can
also recommend approval for status-related benefits (e.g., employment, transfers, and extensions of
status).
The third category of SEVIS II users are select government agency employees who directly
access SEVIS II through a user account rather than a customer account. Personnel at three agencies have
direct access to SEVIS II through user accounts: DHS, DOS, and Department of Justice’s (DOJ’s) Federal
Bureau of Investigation (FBI). DHS users are personnel working for ICE SEVP, who use SEVIS II to
decide whether to certify a school to admit F or M nonimmigrants to a full course of study, to monitor the
compliance of certified schools, to respond to questions about selected nonimmigrants, make
determinations on requests for corrections, and to manage SEVIS II. DOS OPSE users access SEVIS II to
determine whether to designate an entity as a sponsor in the Exchange Visitor Program. Both SEVP and
OPSE personnel use SEVIS II in support of help desk services. Finally, FBI users access SEVIS II for
information critical to criminal and intelligence investigations.
SEVIS II Information Sharing
SEVIS II is the system of record for information on schools, sponsors, and F/M/J nonimmigrants.
When other federal offices and agencies need this information to carry out their missions, SEVIS II is the
source. For example, extracts of SEVIS II data are shared with ICE’s Office of Investigations,
Compliance Enforcement Unit (CEU) to support CEU investigations into violations of immigration law
and possible criminal activity of nonimmigrants. SEVIS II data is sent to USCIS to allow USCIS
employees.

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personnel access to the information to support adjudication of immigration-related benefits and verify
status and employment eligibility. SEVIS II data is also sent to CBP systems to allow its personnel to
make decisions on eligibility for admission to the U.S. Outside of DHS, SEVIS II data is sent to a DOS
Consular Affairs system to allow consular officials to use it in support of visa issuance decisions. SEVIS
II extracts are also sent to the FBI’s Foreign Terrorist Tracking Task Force (FTTTF), which uses it for
criminal and intelligence investigations. DHS also shares information from SEVIS II about individuals
that meet specified homeland security threat criteria, who may require further investigation.

Section 1.0 Characterization of the Information
1.1

What information is collected, used, disseminated, or
maintained in the system?

SEVIS II maintains information about F/M/J nonimmigrants and their dependents, SEVPapproved schools and school officials, and Exchange Visitor Program sponsors and sponsor officials.
Table 1 below details exact data collected for each of these categories of information in the system.
SEVIS II also contains address and family name information for American host families of au pairs and
high school exchange visitors in order to monitor Exchange Visitor Program sponsor compliance with
regulatory requirements.
Table 1: Information Category and Collected PII

Category of Information

Personally Identifiable Information Collected

Non-Government SEVIS II User
Account Information (For all F/M/J
nonimmigrants that create user
accounts; and school and sponsor
officials, owners, chief executives,
legal counsel and/or proxies, parents,
or guardians.)

-Name (first, middle, last)
-U.S. Domestic Address
-Foreign Address (F/M/J nonimmigrants only)
-Date of Birth
-Birth Country and City
-Country of Citizenship
-Country of Legal Permanent Residence
-Username
-E-mail addresses
-Immigrant Identification Number (IIN)
-Alien Number (If the school or sponsor officials select U.S. as their
legal permanent residence country but not the country of citizenship,
then an Alien Number is required)
-National Identity Number (identity number issued by foreign national’s
home country. Requested from all F/M/J nonimmigrants, required for
South Korean nationals)
-Passport – optional (number, issuing country, expiration date)
-Program of study – educational level and first major, second major, and
minor)
-School Registration Information (major, course and registration
information, program completion information, drop below full course
information)
- Exchange visitor program information (category, site of activity,

F/M/J Principal Nonimmigrant
Educational and Financial
Information (For F-1, M-1, and J-1
nonimmigrants only)

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Category of Information

F/M/J Nonimmigrant Status and
Benefit Information (For all F/M/J
Nonimmigrants, including
dependents)

Personally Identifiable Information Collected
program completion information)
-Program completion or termination information
-Transfer information
-Out of country absences and study abroad
-Extensions
-Change of Educational Level
-Student ID Number (number issued by U.S. school, optional, F/M only)
- I-901 Fee Payment Information
-Financial Information (For F and M nonimmigrants financial
information includes data on source of funds - personal or school, and
average annual cost – tuition, books, fees, and living expenses. For J
nonimmigrants financial information includes total estimated financial
support, financial organization name and support amount)
-Fingerprint Identification Number
-Visa (number, issuing country, expiration date)
-Class of admission
-Immigrant benefit application information - (Primarily reinstatement,
and employment authorization and 212(e) Waiver, etc.)
-Arrival and departure information (POE and date of entry/exit)
- Flag identifying individuals that meet specified homeland security
threat criteria who may require further investigation

SEVIS II produces compliance monitoring reports and user-generated reports containing status
and school/sponsor information for government and school/sponsor SEVIS II users only. The system also
generates the admissibility indicator for F/M/J nonimmigrants by applying business rules to information
already in the system. The admissibility indicator displays if the nonimmigrant is currently eligible to
enter the U.S. (green), not eligible for entry (red), or may be eligible (yellow). F/M/J nonimmigrants can
see this indicator in SEVIS II and CBP officers can view it through TECS.
The system also generates an employment eligibility determination for F/M/J nonimmigrants by
applying business rules to information already in the system. USCIS’s E-Verify system queries SEVIS II
for employment eligibility data on a particular nonimmigrant. SEVIS II sends in return the employment
eligibility determination that reflects whether an F/M/J nonimmigrant is eligible to work in the U.S., the
length of employment eligibility, and whether it is authorized for multiple employers.

1.2

What are the sources of the information in the system?

Most F/M/J principal nonimmigrant user account, educational and financial information
(described in Table 1 above) is collected directly from the F/M/J principal nonimmigrant. In many cases,
the F/M/J principal nonimmigrant will create, access, and maintain SEVIS II accounts for all dependents
and will therefore serve as the source of information about them. Dependents may also elect to create
their own username and password to gain access and control their account, and may serve as the source of
certain biographic information about them in the system. See Question 1.1, Table 1 above, ―NonGovernment SEVIS II User Account Information.‖ A proxy, parent, or guardian may create a SEVIS II
account for an F/M/J principal nonimmigrant who is under the age of 14 or is unable to access SEVIS II

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due to a disability or other reasons. If the F/M/J principal nonimmigrant is under the age of 13, a parent
or guardian must create their own account first to create an account for an F/M/J nonimmigrant.
SEVIS II also receives the following information on F/M/J nonimmigrants from sources other
than the individual:
The DHS Arrival and Departure Information System (ADIS) provides arrival and departure
information on F/M/J nonimmigrants. ADIS is a repository of information from various
systems on pre-entry, entry, status management, and exit of immigrants and nonimmigrants.
The DHS US-VISIT IDENT system provides the Fingerprint Identification Number.
Schools and sponsors provide information about enrollment or participation, programs of
study, transfers, and detailed education and financial information on F/M/J nonimmigrants.
The U.S. Treasury Department’s I-901 web portal provides information about F/M/J
nonimmigrants’ payment of fees related to the SEVP. Nonimmigrants must use the I-901
payment website to pay fees to ICE related to the SEVP.
The DOS Consular Consolidated Database (CCD) provides visa issuance information,
corrected biographic information, and 212(e) waiver information. U.S. consular officials
collect biographic information from F/M/J nonimmigrants during the visa issuance process
and input it into CCD. Visa issuance information pertains to whether the DOS has issued or
denied a visa to an F/M/J nonimmigrant. The DOS also collects information from J
nonimmigrants applying for a waiver of the two-year foreign residency requirement through
the completion of the 212(e) Waiver.
The USCIS Computer-Linked Application Information Management System 3 (CLAIMS 3)
provides information on USCIS’s adjudication of immigration benefits sought by an F/M/J
nonimmigrant.
Information about SEVIS II users who work for schools and sponsors is collected directly from
those individuals during the user account registration and update processes.
The legacy SEVIS database is also a source of information in SEVIS II. Prior to the deployment
of SEVIS II, ICE identified and merged SEVIS records about the same F/M/J nonimmigrants, schools,
sponsors, and school and sponsor officials into a single SEVIS II record. These records were loaded into
SEVIS II. In addition, SEVIS II uses commercial software to access U.S. Post Office address information
to verify domestic addresses in the system.
SEVIS II itself is the source of user audit data and various SEVIS II reports. SEVIS II is also the
source of the admissibility indicator and employment eligibility determination for F/M/J nonimmigrants.

1.3

Why is the information being collected, used,
disseminated, or maintained?

Federal law requires the collection of information about F/M/J nonimmigrants and the
maintenance of the SEVIS II system. The information is collected to maintain current information on

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F/M/J nonimmigrants during the course of their stay in the U.S. SEVIS II facilitates DHS and DOS
oversight and enforcement activities concerning F/M/J nonimmigrants, schools, and sponsors, to ensure
compliance with applicable federal laws and regulations. Table 2 lists the specific information in SEVIS
II and why it is needed.

Table 2: PII Collection Justification

Category of
Information

Personally Identifiable
Information

Purpose

NonGovernmental
SEVIS II User
Account
Information (For
F/M/J
nonimmigrants
and dependents
and school and
sponsor officials,
owners, chief
executives, legal
counsel and/or
proxies, parents,
or guardians.)

Name, Address (Domestic and
Foreign), and Date of Birth
Birth Country and City
Country of Citizenship
Country of Legal Permanent
Residence
Username
E-mail addresses
Immigrant Identification Number
(IIN)

Used to identify unique individuals and to communicate
with F/M/J nonimmigrants as well as schools/sponsors.
Used to help identify F/M/J nonimmigrants
Used to enforce the requirement that only U.S. citizens
or lawful permanent residents can serve as school or
sponsor officials.
Used for account management, tracking a user’s system
activity, and communication with users.
IINs are issued to all SEVIS II users, including school or
sponsor officials who are U.S. citizens, and are used to
uniquely identify SEVIS II users.
Used to verify that a school or sponsor official is a U.S.
lawful permanent resident.

Alien Registration Number (DHSassigned number)
National Identity Number
(assigned by foreign governments
to their citizens and residents; not a
U.S. identity number)
Passport – optional (number,
issuing country, expiration date)

F/M/J Principal
Nonimmigrant
Educational and
Financial
Information

Program of study – educational
level and major, secondary major,
and minor)
School Registration Information
(major, course and registration
information, program completion
information, drop below full course
information) for F and M
nonimmigrants

Used to match nonimmigrant users to their own SEVIS
II records, and school/sponsor users to their
school/sponsor SEVIS II records. Required for South
Korean nationals as there are very few last names in
South Korea so the National Identity Number is needed
to identify records about the same person.
Used as secondary identifier to confirm unique
individual biographic information as passport
information is generally unique to an individual.
Required to ensure F and M nonimmigrants are
complying with immigration law related to the class of
admission. Used to conduct trend analysis for
counterintelligence and counterterrorism purposes.

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Category of
Information

F/M/J
Nonimmigrant
Status and
Benefit
Information

Personally Identifiable
Information

Purpose

Program completion or termination
information
Transfer information
Out of country information and
Study Abroad
Extensions
Change of Educational Level
Student ID Number (number issued
by U.S. school, optional, F/M only)

Used to confirm enrollment in SEVP-approved
institution and for monitoring compliance with
immigration laws.

I-901 Fee Payment Information.
Financial Information (For F and M
nonimmigrants financial
information includes data on source
of funds - personal or school, and
average annual cost – tuition,
books, fees, and living expenses.
For J nonimmigrants financial
information includes total estimated
financial support, financial
organization name and support
amount)
Fingerprint Identification Number

Required to determine individual’s ability to pay school
costs and related expenses, which is an eligibility
requirement for F and M status. DOS Consular Affairs
takes into account financial information when making a
visa issuance determination.

Visa (number, issuing country,
expiration date)
Class of Admission

Immigrant Benefit Application
Adjudication Information (212(e)
Waiver, etc.)
Arrival and departure information
(POE and date of entry/exit)

Homeland Security Flag

Optional information to help schools reconcile SEVIS II
data with school databases.

For nonimmigrants over 14 years of age, used to identify
records about the same individual and reduce fraud
through biometric verification. Fingerprints are not
collected on nonimmigrants under the age of 14.
Used as a primary data element in the generation of the
admissibility indicators and to conduct analysis
determining compliance with immigration law.
Used to identify F/M/J nonimmigrants; assists in
determining that nonimmigrants are remaining in status
and complying with all immigration laws applicable to
the appropriate class of admission.
Results of adjudication decisions maintain the personcentric data management methodology, and to ensure
consistency of information across immigration benefit
determination systems.
Used to ensure that F/M/J nonimmigrants are remaining
in status and complying with all immigration laws
applicable to the appropriate class of admission. Arrival
and departure information also helps to generate and
update the admissibility indicator.
Used to identify individuals that meet specified
homeland security threat criteria who may require
further investigation

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1.4

How is the information collected?

SEVIS II collects information from F/M/J nonimmigrants and school/sponsor officials through
SEVIS II and from other federal data systems (identified in Question 1.2 above) through electronic
system-to-system interfaces. Various forms used by DHS, DOS and other federal agencies collect the
information described in this PIA from individuals, schools, and sponsors. Table 3 lists the various forms
used, including the Office of Management and Budget (OMB) Control Number for each form pursuant to
the Paperwork Reduction Act.
Table 3: Information Collection Forms

Category of Information Collected

Form

F/M/J nonimmigrants

U.S. Department of Homeland Security Form I-20
“Certificate of Eligibility for Nonimmigrant (F-1) Student Status
for Academic and Language Students,‖ OMB Control No. 16530038
U.S. Department of State Form DS-2019, ―Certificate of
Eligibility for Exchange Visitor (J-1) Status,‖ OMB Control No.
1405-0119
U.S. Department of State Form DS-7002, "Training/Internship
Placement Plan", OMB Control No. 1405-0170
U.S. Department of Homeland Security SEVIS I-901 ―Student
and Exchange Visitor Program SEVIS I-901 Fee,‖ OMB Control
No. 1653-0034
U.S. Department of Homeland Security Form I-765,
―Application for Employment Authorization,‖ OMB Control No.
1615-0040
U.S. Department of Homeland Security Form I-539,
―Application to Extend/Change Nonimmigrant Status,‖ OMB
Control No. 1615-0003

School

Sponsor

U.S. Department of Homeland Security Form I-94,
―Arrival/Departure Record,‖ OMB Control No. 1651-0111
U.S. Department of Homeland Security Form I-17 ―Petition
for Approval of School for Attendance by Nonimmigrant
Student,‖ OMB Control No. 1653-0538
U.S. Department of State Form DS-3036, ―Exchange Visitor
Program Application,‖ OMB Control No. 1405-0147
U.S. Department of State Form DS-3037, "Update of
Information on Exchange Visitor Program Sponsor", OMB
Control No. 1405-0147
U.S. Department of State Form DS-3097, "Annual Report, J-1
Exchange Visitor Program," OMB Control No. 1405-0151

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1.5

How will the information be checked for accuracy?

SEVIS II obtains the information directly from the individual through direct user input or from
other federal agencies (identified in Question 1.2 above) that generate the information or collect the data
from the individual. For data received from other agencies, it is the responsibility of the original data
collector to ensure the accuracy of information provided to SEVIS II. Because the individual typically
serves as the source of SEVIS II data, the data is considered to be very accurate.
Data about F/M/J Nonimmigrants
To ensure the information provided by F/M/J nonimmigrants who input data into SEVIS II is
accurate, SEVIS II employs field-level validation that ensures that data inputs correspond with
appropriate field parameters (e.g., ensuring only a date will be entered into a date field or a name into a
name field). F/M/J nonimmigrants are able to access their own information through SEVIS II to see if
errors exist. All F/M/J nonimmigrants over the age of 14 must certify under penalty of perjury the
accuracy of information they enter into SEVIS II using an electronic signature. The electronic signature
will require the SEVIS II user to input their username and PIN to authenticate their identity and ensure
completion by the appropriate user.
Some data on nonimmigrants is verified through interfaces with other federal information systems
to ensure that information in SEVIS II is accurate. For example, U.S. consular officials often update the
spelling of nonimmigrants’ names in the DOS Consular Consolidated Database if they do not match the
spelling on the passport. SEVIS II will receive updates from this database to ensure that information in
SEVIS II matches what is on the passport. Additionally, CBP officers at the U.S. port of entry
electronically match the passport information to the existing SEVIS II record. If discrepancies exist, the
CBP-collected passport information overrides the existing information in SEVIS II, thereby ensuring the
most accurate information in SEVIS II.
If information in the SEVIS II system is inaccurate, an F/M/J nonimmigrant may submit a change
request to the SEVIS II help desk. The help desk will evaluate the request, make any changes deemed
appropriate to correct the data, and send a response approving or denying the request to the nonimmigrant
and their school or sponsor.
Data Received from other Federal Data Systems
SEVIS II software monitors information received through the electronic interfaces from other
DHS and DOS systems on a daily basis. SEVIS II software actively monitors interfaces and generates
reports on any errors encountered during data transfers, including discrepancies in the data. If the data is
not consistent with the information already in SEVIS II, SEVIS II rejects the record, an interface error log
documents the data, and the error log is available to the other DHS and DOS systems.
Data Migrated to SEVIS II
SEVP is conducting rigorous validation and accuracy checks on the information migrated from
the SEVIS legacy system to the SEVIS II system. During data migration, SEVP merges the legacy
records to create a one-person, one-record structure for F/M/J nonimmigrants using an entity resolution
process and software tools that rely on matching parameters and weights established by the SEVIS II Data

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Management Working Group (DMWG). The merging process will occur in an iterative fashion, with
results being reviewed by the DMWG and changes being made to the matching algorithms as needed to
enhance the accuracy of the matching and merging process. To further mitigate against the risk of
information corruption, SEVIS II will conduct address verification using commercial software during the
migration of SEVIS data.
Upon creating an account in SEVIS II, F/M/J nonimmigrants and school/sponsor officials must
validate whether or not any of the merged legacy records are in fact theirs. If they believe that certain data
in a merged record or that one or more of the merged records does not pertain to them, they can request to
have the erroneous records decoupled (i.e., unmerged) in their account. A request for decoupling made in
the individual’s account generates a ticket for the SEVIS II help desk. In addition, the system allows the
F/M/J nonimmigrant to provide information that is missing. If an F/M/J nonimmigrant recognizes that a
previous record that should appear in their account is missing, they can submit a SEVIS II help desk
ticket. The individual indicates which record is missing and is prompted to provide, to the best of their
ability, the missing information.
The merging and decoupling (i.e., correction) of records migrated from the SEVIS legacy
database is necessary to complete the transition from the SEVIS record-centric to SEVIS II person-centric
data management methodology. The migration of data will affect records pertaining to F/M/J
nonimmigrants, schools, and sponsors.
SEVIS II requires additional data elements about the F/M/J nonimmigrant that were not captured
in the legacy SEVIS database, specifically, the data elements collected as part of the customer account
information.4 Additionally, some data elements in SEVIS will not be used in SEVIS II and therefore will
not be migrated to the new system (i.e., Social Security Numbers, driver license information).

1.6

What specific legal authorities, arrangements, and/or
agreements defined the collection of information?

The legal authority to collect this information is Public Law 104-208, Illegal Immigration Reform
and Immigrant Responsibility Act of 1996; Public Law 106-215, Immigration and Naturalization Service
Data Management Improvement Act of 2000 (DMIA); Public Law 106-396, Visa Waiver Permanent
Program Act of 2000 (VWPPA); Public Law 107-56, U.S.A. PATRIOT Act; and Public Law 107-173,
Enhanced Border Security and Visa Entry Reform Act of 2002 (Border Security Act). The collection of
information is mandated by 8 CFR 214.2(f), (j), and (m), 214.3, and 214.4, and 22 CFR Part 62.

4

Those data elements are the IIN, national identity number, physical U.S. address, alternate names, multiple email
addresses, country of lawful residence, multiple countries of citizenship, and additional employment information
(employer name, EIN, and employment eligibility dates).

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1.7

Privacy Impact Analysis: Given the amount and type of
data collected, discuss the privacy risks identified and how
they were mitigated.

The collection of information presents inherent privacy risks, including the possible misuse and
inappropriate dissemination of data. Given the extent of the information collected within the SEVIS II
database, there is a risk of abuse if any individual(s) has access to the entirety of the system, or records in
the system that extend beyond the individual user’s need to know. To mitigate this risk, role-based
permissions determine a user’s access to SEVIS II records. F/M/J nonimmigrants will only be able to
access information contained within their own accounts for themselves and any dependents for which
they are inputting data. Proxies, parents, and guardians will be able to access only those records they have
created. School and sponsor officials will have access to only those SEVIS II records pertaining to F/M/J
nonimmigrants enrolled with that particular school or sponsor. For government SEVIS II users, the
system only provides access to users who need the information to effectively perform assigned job
functions. All authorized users must go through an approval process and only access SEVIS II through
approved equipment or through an appropriate web interface reflecting necessary role and responsibility
access privileges.
DHS has a legislative mandate to collect and maintain current information relating to F/M/J
nonimmigrants during the course of their stay in the U.S. SEVIS II collects information that effectively
and efficiently carries out the purposes of the program. Wherever possible, the individual directly
provides information about him or herself, thereby greatly enhancing the accuracy of information in the
system. In addition, the system uses information from other federal information systems to validate the
F/M/J nonimmigrant data and will allow information deemed to have greater accuracy to overwrite
SEVIS II data (e.g., passport data collected at the border). The most significant mitigation to the risk of
inaccurate data is the individual’s ability to view their own data in the system and request that SEVP
correct inaccurate information through the submission of a help desk ticket.
The migration of historical data from the legacy SEVIS to SEVIS II represents a privacy risk as
the potential exists that merging records will result in erroneous coupling of records that are not about the
same individual, or other information corruption or duplication. To mitigate this risk, ICE has undertaken
several procedural safeguards during the migration process to minimize the risk of data errors. At the end
of the process, the individuals that are the subjects of these records will be able to access the migrated
data and verify whether merged records are in fact theirs. Individuals may submit a request to the SEVIS
II help desk to correct any errors that arose out of the migration.
Finally, SEVIS II is reducing the collection of sensitive PII by eliminating the collection and
maintenance of both the Social Security Number and driver’s license information that was previously
collected by the legacy system. The removal of these two sensitive data elements enhances privacy by
minimizing collection of data and reducing the risk of identity theft if the SEVIS II database is
compromised.

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Section 2.0 Uses of the Information
2.1

Describe all the uses of information.

The U.S. Government uses SEVIS II to execute the legislative mandate requiring the collection of
information on F/M/J nonimmigrants. Specifically, ICE and DOS use information about F/M/J
nonimmigrants to ensure that they comply with the obligations of their U.S. admittance and to maintain a
history of their status-related activities. ICE, as well as DOS, uses the information to identify and act on
potential compliance violations by both schools and sponsors. ICE uses the information in statistical form
to publish a quarterly compilation of information concerning schools, sponsors, and F/M/J
nonimmigrants.
In the SEVIS II system, the F/M/J nonimmigrant biographic information populates a certificate of
eligibility (Form I-20 for F and M or Form DS-2019 for J) for F/M/J nonimmigrants accepted by a U.S.
school or sponsor. Additional programmatic information (i.e. educational record, financial information)
completes the certificate of eligibility. The completed certificate is a prerequisite for applying for a visa.
U.S. consulates use the information contained within the certificate of eligibility (Form I-20 or DS-2019)
as a component of the visa issuance decision-making process. U.S. consulates and schools also use F/M
nonimmigrants’ financial information to determine their ability to pay for the program, which is a
prerequisite to obtaining an F or M visa. DOS Consular Affairs also takes into account financial
information when making a visa issuance determination for F/M/J nonimmigrants.
SEVIS II uses the visa issuance information, other information already in the system, and a set of
business rules to generate an admissibility indicator. CBP officials use the admissibility indicator
(available to them through TECS) when the F/M/J nonimmigrant arrives at the port of entry and requests
admission. The admissibility indicator is a component of the CBP officials’ decision to admit the
nonimmigrant the U.S.
USCIS officials use SEVIS II information to assist in determining the eligibility for a change of
status or for benefits associated with their class of admission through SEVIS II interfaces with CLAIMS,
Verification Information System, and E-Verify. SEVIS II will use information in the system and
predefined business rules to determine employment eligibility when queried by E-Verify regarding a
nonimmigrant’s employment status.
FBI, FTTTF, and ICE use SEVIS II information to perform trend analysis for counterintelligence
and counterterrorism purposes, and for investigations of violations of criminal and immigration laws.
Finally, SEVIS II uses biographic information (i.e., name, citizenship, date of birth, etc.) to create
non-government SEVIS II accounts. SEVIS II then assigns an IIN to all non-government SEVIS II users,
including school and sponsor officials. Once an individual’s account is created, the IIN is used within
SEVIS II to maintain the ―one person-one record‖ data management methodology.

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2.2

What types of tools are used to analyze data and what type
of data may be produced?

SEVIS II provides information technology (IT) tools to assist users in monitoring the status of
F/M/J nonimmigrants. Specifically, SEVIS II has predefined business rules that use information in the
system to create simple reports and to generate the system’s admissibility indicator and employment
eligibility determination.
As discussed above, the admissibility indicator reflects whether an individual is eligible for
admission to the U.S. as an F/M/J nonimmigrant. This indicator is visible to F/M/J nonimmigrants
through SEVIS II and to CBP officers through TECS. The admissibility indicator has three possible
values:
Eligible for admission (Green)
Not eligible (Red)
May be eligible (Yellow)
The SEVIS II admissibility indicator is generated using business rules applied to information in
the F/M/J nonimmigrant record, resulting in the appropriate Green/Red/Yellow indicator as the value for
this field. For example, an F/M/J nonimmigrant will not be eligible for admission until thirty days prior to
their program start date, so the SEVIS II record will reflect a Red admissibility indicator until that time.5
Alternatively, SEVIS II will transmit the conditional entry indicator (Yellow) if there are outstanding
issues when an F/M/J nonimmigrant arrives at the POE (e.g., a student whose previous period of status
was terminated due to inability to pay tuition may be asked to prove financial ability before he will be
admitted). A Yellow indicator requires that the CBP officer should review additional information in
SEVIS II through the SIGMA interface (described in Question 4.0) to adjudicate the admission request.
The SEVIS II employment eligibility determination reflects whether an F/M/J nonimmigrant is
legally eligible for employment during their stay, the length of eligibility, and whether a nonimmigrant
can work for one or multiple employers. SEVIS II will transmit this information to the E-Verify system
upon request. Like the admissibility indicator, the employment eligibility determinations will also be
visible to F/M/J nonimmigrants through SEVIS II.

2.3

If the system uses commercial or publicly available data
please explain why and how it is used.

SEVIS II uses commercial data software to provide address verification. The software validates input
address information during the migration of historical data from the SEVIS database to SEVIS II. SEVIS
II also employs the software in the production environment, verifying the U.S. addresses of applicants.
The software does not create any connections outside of SEVIS II nor does it transmit any information.
When an applicant inputs an address that the software cannot validate (i.e., new construction), the system
5

F and M nonimmigrants in a short term program will not be eligible for admission until fifteen days prior to their
program start date.

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will allow the input, and flag the address for further inspection, either at a later date when the address
database is refreshed or by an ICE analyst.

2.4

Privacy Impact Analysis: Describe any types of controls
that may be in place to ensure that information is handled
in accordance with the above described uses.

Access to the information is restricted to authorized users from schools, sponsors, DHS, DOS,
and other government agencies. In addition, F/M/J nonimmigrants have limited access to individual
account information. Physical and computer safeguards are in place to prevent unauthorized persons from
gaining access to the data. To prevent inappropriate access by unauthorized personnel or misuse of data,
computer safeguards exist throughout the system, including password protection, firewalls, and extensive
audit trails. SEVIS II records and maintains information on session activity (e.g., user ID, log on time,
duration of session, and log off time) each time a user accesses the system.
SEVIS II generates decisions regarding admissibility and employment eligibility based upon
system information and preexisting business rules. To mitigate the risk that SEVIS II incorrectly indicates
a lack of employment eligibility, if the F/M/J nonimmigrant believes that a decision was made in error,
they may file an appeal through SEVIS II per the SEVIS SORN and the system’s determination will be
reviewed by SEVP personnel. If the F/M/J nonimmigrant believes the admissibility indicator displayed on
SEVIS II is inaccurate, the individual may submit a help desk ticket requesting that the indicator value be
reviewed. Government personnel review such requests and update SEVIS II records to correct errors.
SEVP personnel periodically review correction information and proactively addresses business rule errors
responsible for causing multiple incorrect benefit adjudication decisions.
During the initial months of SEVIS II operation, a SEVP task force will further mitigate the risk
that CBP officers at ports of entry may incorrectly deny access to an F/M/J nonimmigrant because of an
erroneous SEVIS II admissibility indicator. If a problem arises upon entry, CBP officers will be able to
contact the task force for guidance and clarification of the admissibility decision. In addition, a CBP
officer in secondary inspection at the port of entry will review any denial of admission initiated by a CBP
officer because of the SEVIS II indicator. The review by a secondary officer mitigates the risk that a
system-generated denial is an error, and provides a human validation of the denial determination.
In addition, SEVIS II maintains a record of all changes that a user makes to the data in the
system. These features provide an audit trail of all user actions. The audit trail allows for the monitoring
and analysis of user activity to identify inappropriate use of the system.

Section 3.0 Retention
3.1

What information is retained?

The SEVIS II retains system inputs (including ingests from other systems, online entries made by
F/M/J nonimmigrants and school and sponsor officials); the master file; outputs (reports); government
and non-government user account information; and user audit information.

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The data from legacy SEVIS will be migrated to SEVIS II but also retained separately.

3.2

How long is information retained?

Inputs will be deleted after the data has been transferred to the master file and verified. The
master file will be retained for 75 years. System outputs are deleted or destroyed when no longer needed
for agency business. Once SEVIS II terminates a non-government SEVIS II user account, the system
retains user information for 75 years from the date of last transaction. Government user audit information
will be retained for seven years from the date of last transaction.
A copy of the data from the original SEVIS system, which will be maintained separately retained
from SEVIS II, will be retained for seven (7) years.

3.3

Has the retention schedule been approved by the
component records officer and the National Archives and
Records Administration?

No. ICE has drafted a proposed retention schedule for SEVIS II. A retention schedule exists for
the original SEVIS system but it does not adequately describe all data maintained in SEVIS II.

3.4

Privacy Impact Analysis: Please discuss the risks
associated with the length of time data is retained and how
those risks are mitigated.

The 75-year retention period for the master file in SEVIS II is consistent with the policy of the
U.S. Government to retain records related to immigration for the approximate lifetime of an individual.
This information is necessary for the time indicated for historical purposes and because specific
immigration-related law enforcement or benefit activities can span decades. Security measures taken
mitigate the risk associated with the length of retention in accordance to DHS security policies, requiring
explicit roles and responsibilities limiting access to information exclusively to those individuals who
require access to complete essential job functions.

Section 4.0 Internal Sharing and Disclosure
4.1

With which internal organization(s) is the information
shared, what information is shared and for what purpose?

SEVIS II shares F/M/J nonimmigrant status information with US-VISIT’s ADIS. The
information shared with ADIS on F/M/J nonimmigrants determines which individuals are no longer in
active status and must exit the U.S. This information sharing is necessary for monitoring compliance with
immigration law.

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SEVIS II exports F/M/J nonimmigrant information to USCIS’s Verification Information System
(VIS) for determining immigration benefits entitlement. USCIS users can query SEVIS II data through
the USCIS Enterprise Service Bus (ESB) to help government agencies verify the immigration status of an
individual that has applied for a government benefit to ensure eligibility for federal, state, or local public
benefits and licenses.
SEVIS II sends employment eligibility information to USCIS’s E-Verify when queried by the
system. USCIS uses the employment eligibility information in the adjudication of employment benefit
decisions.
SEVIS II shares information with CBP’s TECS. Through TECS, CBP officers can view the latest
F/M/J admissibility indicator from SEVIS II for individuals who are at or about to arrive at the port of
entry.
Finally, SEVIS II shares information with CBP’s Secured Integrated Government Mainframe
Access (SIGMA) system. SIGMA users query SEVIS II data to retrieve additional information that is not
in TECS about an F/M/J nonimmigrant who has requested admission at the port of entry. CBP uses this
information to help determine whether to admit the nonimmigrant to the U.S.

4.2

How is the information transmitted or disclosed?

Information shared with VIS, E-Verify, TECS, and SIGMA transmits through the USCIS ESB
interface. Instead of accessing multiple federal information systems, the interface allows DHS users to
make a single query request. The interface accesses the individual systems including SEVIS II and
presents the responsive data as a consolidated set. The secure socket layer (SSL) protocol secures the
transmission of data. A separate PIA for the ESB is available on the Privacy Office website,
www.dhs.gov/privacy.
SEVIS II and US-VISIT/ADIS transmit information through a secure electronic web-based
interface. Information exchanges occur daily between ADIS and SEVIS II using US-VISIT’s proprietary
eXtensible markup language (XML).

4.3

Privacy Impact Analysis: Considering the extent of internal
information sharing, discuss the privacy risks associated
with the sharing and how they were mitigated.

Sharing of SEVIS II information within DHS is for carrying out activities related to the F/M/J
nonimmigrants travel to and from the U.S., and their requests for any immigration related benefits, such
as employment benefits. The sharing of this information with CBP supports the narrow purpose of
admitting the F/M/J nonimmigrants to the U.S. in accordance with the terms of their class of admission.
The sharing of information with USCIS is to support the appropriate determination of requests for
employment and other immigration benefits, or to support USCIS programs designed to ensure that only
nonimmigrants who are actually eligible for government benefits receive them. The sharing of this
information is therefore consistent with the purposes for which it was collected, namely to ensure the

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appropriate administration and enforcement of the student and exchange visitor laws and regulations, and
to track F/M/J nonimmigrants here in the U.S. and ensure they comply with the terms of their admission.
The privacy risks associated with each step of internal sharing, including system and network
security, data, usage, data transmission, and disclosure have been identified and mitigated through
adherence to DHS policies and procedures, such as System Design Lifecycle documentation and
Certification and Accreditation (C&A) documentation. Internal sharing of data is conducted over secured
networks controlled by DHS, utilizing DHS approved computers, services, and software. In addition, only
authorized users who need the information contained in SEVIS II have access to the system and all
authorized users are assigned appropriate roles and responsibility access appropriate to their functional
need.
There will always be the possibility of misuse and inappropriate dissemination of information
despite the above described technical security aspects. Security logs, audit logs of user activity, and strict
access controls help mitigate these risks. A user’s supervisor must approve system access. The
DHS/Office of the Chief Information Officer utilizes an Active Directory to authenticate a user to SEVIS
II. SEVP administers role-based access to ensure that only those users with a management-approved
functional need and appropriate security clearance receive approval for SEVIS II use.
SEVIS II records and maintains information on session activity (e.g., user ID, log on time,
duration of session, and log off time) each time a user accesses the system. In addition, SEVIS II
maintains a record of all changes that a user makes to the data in the system. These features provide an
audit trail of all user actions that monitor and analyze user activity for compliance. These features also
provide a means to ensure data integrity.

Section 5.0 External Sharing and Disclosure
5.1

With which external organization(s) is the information
shared, what information is shared, and for what purpose?

Personnel at two federal agencies outside DHS are granted direct user access to SEVIS II: DOS and the
FBI. DOS Office of Private Sector Exchange (OPSE) users directly access SEVIS II to administer the
Exchange Visitor Program, e.g., the processing of applications for designation of Exchange Visitor
Program sponsors. DOS Consular Affairs users access SEVIS II to verify the validity of information
when issuing visas to nonimmigrants and checking immigration benefit eligibility. DOS OPSE and
Consulate Affairs users may access all information contained within SEVIS II. FBI users directly access
SEVIS II to perform counterintelligence and counterterrorism analysis.
In addition, SEVIS II regularly exports data to the FBI’s FTTTF, which analyzes SEVIS II data to
support the FBI’s counterterrorism mission.
SEVIS II also sends the IIN for F/M/J nonimmigrants to the Treasury Department’s I-901 fee
payment interface to verify payment of the SEVP fee due to ICE from the F/M/J nonimmigrant. This
information sharing allows SEVIS II to ensure that payment information submitted through the I-901
system matches F/M/J data currently in SEVIS II.

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In addition, school and sponsor officials directly access SEVIS II to create user-generated reports
and extract data. The reports may contain F/M/J nonimmigrant biographic and status information, but the
school and sponsor access is limited to only those F/M/J nonimmigrants enrolled by that particular school
or sponsor. Schools and sponsors use this information to manage their responsibilities under federal law
with respect to the F/M/J nonimmigrants enrolled in their schools or Exchange Visitor Programs.

5.2

Is the sharing of PII outside the Department compatible
with the original collection? If so, is it covered by an
appropriate routine use in a SORN? If so, please describe.
If not, please describe under what legal mechanism the
program or system is allowed to share the personally
identifiable information outside of DHS.

The sharing of information with DOS, Treasury, and the schools and sponsors is compatible with
the purposes of the original collection, namely to ensure the appropriate administration and enforcement
of the student and exchange visitor laws and regulations, and to track F/M/J nonimmigrants here in the
U.S. and ensure they comply with the terms of their admission. Sharing of SEVIS II information with the
FBI is necessary to support counterterrorism and counterintelligence programs critical to national
security. All sharing of information from SEVIS II is pursuant to an applicable routine use in the SEVIS
SORN. Memoranda of Understanding exist between SEVIS II and DOS, U.S. Treasury (I-901), and the
FBI. These agreements appropriately define the information sharing and usage of information.

5.3

How is the information shared outside the Department and
what security measures safeguard its transmission?

SEVIS II shares information with FBI and DOS OPSE personnel, which have direct access as
users of SEVIS II. Security logs, audit logs, and strict access controls safeguard SEVIS II information
sharing occurring through government user accounts.
SEVIS II shares information electronically with DOS Consulate Affairs through the USCIS ESB
web service. Transmission of data sent through the USCIS ESB secures through the SSL protocol using
public key infrastructure (PKI) authentication measures.
Information is shared in bulk with the FBI FTTTF via an electronic export using a secure XML
web connection. Information shared with the U.S. Treasury’s I-901 web service interface takes place
through SSL and PKI authentication.
SEVIS II applies all sensitive data (e.g., PII data, passwords) identified and appropriate
encryption technologies to ensure the confidentiality and integrity of sensitive data. All SEVIS II
cryptographic operations perform using FIPS 180-2-approved algorithms.

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5.4

Privacy Impact Analysis: Given the external sharing,
explain the privacy risks identified and describe how they
were mitigated.

Allowing external users access to a system raises the risk of inappropriate use and access. In the
case of SEVIS II, this risk is mitigated by the fact that SEVIS II records and maintains session activity
(e.g., user ID, log on time, duration of session, and log off time) each time a user accesses the system. In
addition, SEVIS II maintains a record of all changes that a user makes to the data in the system. These
features provide an audit trail of all user actions that monitors and analyzes user activity for compliance.
SEVP reviews the audit trails through weekly security audit reports to ensure appropriate access to and
use of data. These features also provide a means to ensure data integrity.
Because SEVIS II is accessible by non-government users (i.e., schools, sponsors, and F/M/J
nonimmigrants), there is an additional privacy risk of access by unauthorized persons and inappropriate
use associated with this system. The measures and processes put in place for school certification, sponsor
designation, and ID/password issuance offsets and minimizes this privacy risk. In addition, the design of
SEVIS II separates critical system components from the public. The public will only interface with the
web-enabled front end of the system delivered via the DHS Portal. Business processes, logic functions,
and database access will not be publicly accessible.
In addition, the risks of external sharing of data are mitigated because SEVIS II sharing occurs
over secured networks. Only authorized users will handle biographic and biometric data. Sharing data
with DOS personnel will take place through the secured and encrypted web-based user interface. There is
a possibility of misuse and inappropriate dissemination despite the technical security considerations;
however, taking advantage of DHS security policies that require audit logs of user activities, security logs,
and strict access controls mitigates these risks.

Section 6.0 Notice
6.1

Was notice provided to the individual prior to collection of
information?

This PIA provides general notice about the collection of this information, the amended SEVIS
SORN, and the publication of a Notice of Public Rulemaking. Non-government SEVIS II users will be
notified by a Privacy Act Notice when completing the Form I-17, the Form I-20 and/or the Form DS3036, Form DS-3037, Form DS-3097, Form DS-2019 and Form DS-7002. All non-government SEVIS II
users will also receive notice through a Privacy Act Notice on SEVIS II that will display before asking to
provide any personal information.

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6.2

Do individuals have the opportunity and/or right to decline
to provide information?

Yes, however the failure to provide requested information would preclude the non-government
SEVIS II users from accessing the functionality of SEVIS II and prevent the individual from receiving the
benefits sought.

6.3

Do individuals have the right to consent to particular uses
of the information? If so, how does the individual exercise
the right?

No, system users consent to all uses of their information through electing to create an account and
the submission of information to SEVIS II. SEVIS II presents a Privacy Act Notice detailing authority
and uses of information to all non-government users. The form also contains a signature certification and
authorization to release any information from an applicant record that SEVIS II needs to determine
eligibility, which includes biographic and biometric data.

6.4

Privacy Impact Analysis: Describe how notice is provided
to individuals, and how the risks associated with
individuals being unaware of the collection are mitigated.

There is a risk that individuals may be unaware of the nature of information collected about them
for the SEVP, and how it will be used and shared. This risk is mitigated by the notice provided to
individuals whose information is collected by and maintained in the SEVIS II system at the time of
collection. In addition, this PIA and the SEVIS SORN provide additional public notice of the nature,
purpose, use, and sharing of the information about individuals. F/M/J nonimmigrants may also view the
information collected about them and verify portions of their information in SEVIS II.

Section 7.0 Access, Redress and Correction
7.1

What are the procedures that allow individuals to gain
access to their information?

F/M/J nonimmigrants can view information about themselves in the system by logging into
SEVIS II. School and sponsor SEVIS II users can view their own information provided for account setup
purposes through the system as well.
In addition, individuals may request access to records about them in SEVIS II by following the
procedures outlined in the SEVIS SORN. Some of the requested information may be exempt from access
pursuant to the Privacy Act to prevent harm to law enforcement investigations or interests. Providing
individual access to records contained in SEVIS II could inform the subject of an actual or potential
criminal, civil, or regulatory violation investigation or reveal investigative interest on the part of DHS or

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another agency. Access to the records could also permit the individual who is the subject of a record to
impede the investigation, to tamper with witnesses or evidence, and to avoid detection or apprehension.
Adverse determinations under the USCIS E-Verify program may be appealed pursuant to the E-Verify
appeal procedures, which are included in notices of adverse determinations provided to individuals and
described in the USCIS Verification Information System Privacy Impact Assessment dated April 2, 2007.
In instances where SEVIS II data is the basis for an adverse determination for employment authorization,
the individual may review their SEVIS II record and seek to correct information they believe to be in
error in accordance with the procedures described below in Question 7.2.
In addition to the procedures above, individuals seeking notification of and access to any record
contained in this system of records, or seeking to contest its content, may submit a request in writing to:
ICE FOIA Officer
800 North Capitol Street, N.W.
5th Floor, Suite 585
Washington, D.C. 20528
Individuals may also submit requests by fax at 202-732-0310 or by email at [email protected].
Please see the ICE FOIA Office’s website for additional information (http://www.ice.gov/foia/index.htm).
If an individual believes more than one component maintains Privacy Act records concerning him or her
the individual may submit the request to the Chief Privacy Officer, Department of Homeland Security,
245 Murray Drive, S.W., Building 410, STOP-0550, Washington, D.C. 20528.

7.2

What are the procedures for correcting inaccurate or
erroneous information?

To correct inaccurate or outdated information in the system, an F/M/J nonimmigrant will have the
opportunity to edit specific data fields including address and employment. If an error exists in information
fields they or their school or sponsor official are not able to correct, or if the F/M/J nonimmigrant believes
the admissibility indicator displayed in the system is in accurate, they will be able to submit a SEVIS II
help desk ticket to update the information. A government user at SEVP or DOS OPSE will review the
request, inspect the submitted information, and contact the nonimmigrant via email if additional
information or justifying documentation is required. The government user will then either deny the
request or accept and complete the account information modification. The government user will
communicate the final determination to the nonimmigrant user, and the nonimmigrant requestor may view
the determination by accessing the SEVIS II account.
During the initial months of SEVIS II’s operation, a SEVP task force will exist to mitigate the
risk that CBP officers at ports of entry may incorrectly deny access to an F/M/J nonimmigrant because of
an erroneous SEVIS II admissibility indicator. If a problem arises upon entry, CBP officers will be able to
contact the task force for guidance and clarification of the admissibility decision. In addition, a CBP
officer in secondary inspection at the port of entry will review any denial of admission initiated by a CBP
officer because of the SEVIS II indicator. The review by a secondary officer mitigates the risk that a
system-generated denial is an error, and provides a human validation of the denial determination.

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If individuals obtain access to the information in SEVIS II pursuant to the procedures outlined in
the SEVIS SORN and not through the web interface, they may seek correction of any incorrect
information in the system by submitting a written request to correct the data. The SEVIS SORN outlines
the data correction procedures. All or some of the requested information may be exempt from amendment
pursuant to the Privacy Act in order to prevent harm to law enforcement investigations or interests.
Amendment of the records could interfere with ongoing investigations and law enforcement activities and
may impose an impossible administrative burden on investigative agencies.
In addition to the procedures above, individuals seeking notification of and access to any record
contained in this system of records, or seeking to contest its content, may submit a request in writing to:
ICE FOIA Officer
800 North Capitol Street, N.W.
5th Floor, Suite 585
Washington, D.C. 20528
Individuals may also submit requests by fax at 202-732-0310 or by email at [email protected].
Please see the ICE FOIA Office’s website for additional information (http://www.ice.gov/foia/index.htm).
If an individual believes more than one component maintains Privacy Act records concerning him or her
the individual may submit the request to the Chief Privacy Officer, Department of Homeland Security,
245 Murray Drive, S.W., Building 410, STOP-0550, Washington, D.C. 20528.

7.3

How are individuals notified of the procedures for
correcting their information?

The SEVIS II website notifies individuals of the procedures for correction, as do the published
PIA and SORN.

7.4

If no formal redress is provided, what alternatives are
available to the individual?

Formal redress is provided, as described above, for information maintained in the SEVIS II
system. In addition, because SEVIS II generates decisions regarding employment eligibility, F/M/J
nonimmigrants who believe that an employment eligibility decision was made in error may file an appeal
through E-Verify and if necessary seek to correct their SEVIS II records in accordance with the
procedures described above.

7.5

Privacy Impact Analysis: Please discuss the privacy risks
associated with the redress available to individuals and
how those risks are mitigated.

The Privacy Act provides access and other procedural rights, with the exceptions noted above.
The risks associated with redress include misuse or abuse of the redress program, misuse or loss of data,
inadvertent release of data, and identity theft. The direct involvement of a government user in the

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evaluation and decision making process for each individual case mitigates the associated risks. The
existence of the robust SEVIS II auditing system further mitigates the risk of abuse. Beyond direct user
evaluation, the use of the auditing function will allow for monitoring and reporting on anomalous user
activity.

Section 8.0 Technical Access and Security
8.1

What procedures are in place to determine which users
may access the system and are they documented?

DHS has documented standard operating procedures to determine which users may access SEVIS
II. Access for SEVIS II internal and external users vary depending on their established role-based
privileges. SEVIS II will have three classes of users, with separate access protocols. The three classes are
as follows:
DHS Users: DHS users receive access to SEVIS II based upon role and relevant job need.
Users receive one of four permission levels: read only access, read and report access, limited
editing capability (primarily help desk support), and complete read/write access (super user).
Permissions also establish whether the user may access information pertaining to all SEVIS II
users, or to a limited subset.
Other Government Users (FBI, DOS Users): DOS users within OPSE receive permissions
similar to those assigned to DHS. Users may receive one of four permission levels; read only
access, read and report access, limited editing capability, and complete read/write access
(super user). FBI users all receive read-only access to SEVIS II.
Non-government SEVIS II Users (For F/M/J nonimmigrants, school and sponsor
officials, owners, chief executives, legal counsel, and/or proxies, parents, or guardians):
F/M/J users may only access information contained within their individual accounts, and have
the ability to update only certain fields in the system. School and sponsor officials may only
access information for those nonimmigrants enrolled or participating within their specific
program(s). School and sponsor officials may update certain information within the system
for F/M/J nonimmigrants enrolled or participating in their specific program(s), as well as
update information on the school and exchange visitor program sponsor. Proxies, parents, and
guardians may view only their own account and those they have created for an F/M/J
nonimmigrant.

8.2

Will Department contractors have access to the system?

Yes. Contractors who possess a favorably adjudicated clearance will have access as necessary to
maintain SEVIS II and provide technical support. The extent of access will vary based on the need to
fulfill the requirements of the contract under appropriate nondisclosure and use limitations. ICE personnel
will determine access levels.

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8.3

Describe what privacy training is provided to users either
generally or specifically relevant to the program or
system?

As detailed in Questions 8.1 and 8.2, all SEVIS II users will have limited role-based access.
SEVIS II users will receive role-based system-specific training intended to ensure compliance with use
limitations and other safeguards discussed in this PIA. Specifically, all SEVIS II government and nongovernment users will complete web-based, self-paced training designed to familiarize account holders
with the system. SEVP requires all school officials to complete training. OPSE also requires training for
all sponsors officials. Both SEVP and OPSE conduct training for school and sponsor officials at
conferences. SEVIS II will also provide specific training for users with a job requirement to create data
extracts or print reports. In addition, all internal DHS, DOS, and DOJ users will have to accept and sign
the system’s Rules of Behavior document.
In addition, all ICE personnel and contractors complete annual mandatory privacy and security
training and training on ―Securely Handling ICE Sensitive but Unclassified (SBU)/For Official Use Only
(FOUO) Information.‖

8.4

Has Certification & Accreditation been completed for the
system or systems supporting the program?

The C&A process is in progress but is expected to be complete in early 2010.

8.5

What auditing measures and technical safeguards are in
place to prevent misuse of data?

SEVIS II audits all user activity to prevent misuse of SEVIS II data. For each user session,
SEVIS II logs the user ID, log on time, duration of session, and the log off time. The SEVIS II audit log
additionally tracks data entry, modification, and/or deletion of existing data by the individual responsible
for the action. SEVP reviews the audit trails through a weekly security audit report to ensure appropriate
access to and use of SEVIS II data. If a SEVP user’s account activity appears inconsistent with task
requirements, SEVP will follow up with the user to determine the root cause of the anomaly. In
circumstances where SEVP determines that unauthorized access to or misuse of data has occurred, SEVP
terminates any user account responsible for the activity.
Ensuring that all SEVIS II data is stored in compliance with the requirements of the DHS IT
security policy (e.g., DHS 4300A Sensitive System Handbook) further mitigates the risk of data misuse.
In accordance with the program dictated by the DHS 4300A Sensitive System Handbook, management,
operational, and technical controls instituted ensure that all information contained within SEVIS II is
protected according to best practice standards. The system’s C&A, based on NIST 800-53
―Recommended Security Controls for Federal Information Systems,‖ will fully examine the system for
security vulnerabilities. Identified critical vulnerabilities will be addressed before the system is deployed;
a Plan of Action and Milestones will track acceptable risks.

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8.6

Privacy Impact Analysis: Given the sensitivity and scope of
the information collected, as well as any information
sharing conducted on the system, what privacy risks were
identified and how do the security controls mitigate them?

The security risks include unauthorized system access or use, inadequate system security, the
extensive external and internal data sharing required to perform the functions legislatively prescribed to
the SEVIS II database; however, the issuance of guidance restricting data access and establishing strict
user authentication and role-based access have substantially mitigated these risks. The required system
specific privacy and security training that all users must complete and recertify on an annual basis further
mitigate these risks. Extensive audit trails and data use monitoring are in place to prevent the abuse of
system access and data use.

Section 9.0 Technology
9.1

What type of project is the program or system?

SEVIS II is an enterprise-wide, operational IT system supporting DHS ICE.

9.2

What stage of development is the system in and what
project development lifecycle was used?

SEVIS II is in the Development stage of the ICE Enterprise Architecture Lifecycle Management
System. SEVIS II development is using an iterative design methodology. The system development will be
broken into 12 unique products. The finalized products will build upon each other. This PIA will be
updated if any significant changes are made to the design as identified when SEVIS II is deployed.

9.3

Does the project employ technology that may raise privacy
concerns? If so, please discuss their implementation.

SEVIS II uses business rules and data that exists in the system to generate data that will be relied
upon to assist in determining whether to admit an F/M/J nonimmigrant to the U.S. at a port of entry, or
whether an F/M/J nonimmigrant is eligible for an employment benefit (eligible to work while in the U.S.).
The privacy risk presented by this SEVIS II capability is that if the rules are improperly developed, or the
information in the system is inaccurate, F/M/J nonimmigrants may be improperly denied a benefit or
denied admission to the U.S. ICE has implemented appropriate controls to mitigate these risks (fully
described in 2.0), specifically, the careful review and testing of the business rules prior to deployment of
the system, redress procedures for individuals who believe they have been adversely affected, and the
ability for individuals to see and correct their own data in the system on which these system-generated
decisions are based.

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Responsible Officials
Lyn Rahilly
Privacy Officer
U.S. Immigration and Customs Enforcement
Department of Homeland Security

Approval Signature Page

Original signed and on file with the DHS Privacy Office
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security