I-20 Forms/PTA

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]
Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:

I-20

Form Title:
Component:

Certificate of Eligibility for Nonimmigrant Student Status
Immigration and
Office:
Student & Exchange
Customs Enforcement
Visitor Program
(ICE)
(SEVP)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Certificate of Eligibility for Nonimmigrant Student Status
OMB Control
Number:
Collection status:

1653-0038
Revision

OMB Expiration
Date:
Date of last PTA (if
applicable):

April 30, 2021
December 20,
2017

PROJECT OR PROGRAM MANAGER
Name:
Office:
Phone:

Name:
Office:

Michael Hallanan

SEVP Policy
202.560.9180

Title:
Email:

Policy analyst
[email protected].
gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Scott Elmore
ICE OCIO
Title:
ICE Forms Manager

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Phone:

(202) 732-2601
Email:
[email protected]
SPECIFIC IC/Forms PTA QUESTIONS

1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
This U.S. Department of Homeland Security (DHS) Form I-20, Certificate of Eligibility for
Nonimmigrant Student Status, OMB Control Number 1653-0038, is being submitted for a
three-year renewal. ICE is updating this form with the “City of Birth” for nonimmigrants.
This data element is being added to the I-20 Form as a required field for the purpose
establishing a person-centric system.
The Student and Exchange Visitor Program (SEVP) was established as part of the
Homeland Security Investigations (HSI) National Security Investigations Division (NSID)
within U.S. Immigration and Customs Enforcement (ICE). SEVP supports the application
and admission of foreign nationals (and their dependents) seeking entry into the United
States as nonimmigrant students under F and M classes of admission (hereinafter, “F and
M nonimmigrants”). To facilitate the program’s work, SEVP collects, uses, shares, and
maintains personally identifiable information (PII) on nonimmigrant students and their
dependents to ensure compliance with immigration laws and regulations.
In order to study in the United States, a nonimmigrant student must first apply to an
SEVP-certified school in the United States. As evidence of the school’s acceptance, the
designated school official (DSO) issues the student a Form I-20 using the Student and
Exchange Visitor Information System (SEVIS). The Form I-20 is used to determine
eligibility for F and M nonimmigrant student status and to complete the following tasks:
1. Pay the I-901 SEVIS Fee: Prior to entering the United States, a completed Form I20 is necessary to pay the I-901 SEVIS fee.
2. Apply for a nonimmigrant visa. A completed Form I-20 is required to obtain a visa
from the Department of State.
3. Enter the United States: Form I-20 must be presented to the U.S. Customs and
Border Protection at the port of entry. The Form I-20 lists the program start date.
Nonimmigrant students may enter the United States up to 30 days prior to this
date. A separate Form I-20 is required for any eligible dependents (F2 and M2
nonimmigrans) that will accompany F1 and M1 nonimmigrants into the United
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

States. For a F2 or M2 nonimmigrant that enter the United States without the
F1/M1, he or she must also provide a copy of the F1/M1 nonimmigrant’s Form I20.
4. Apply for benefits: F and M nonimmigrants must present a Form I-20 with DSO
recommendation to apply for any nonimmigrant benefits (such as change of
status, transfer, or employment (e.g. Optional Practical Training [OPT]) through
USCIS .
Upon completion of a program of study, F and M students that participate in OPT may
choose to create an SEVP Portal account that enables the student to update a subset of
the initial information collected on the form (e.g., address) in his or her SEVIS record via
the portal or request their DSO update their SEVIS record directly (if applicable).
b. List the DHS (or component) authorities to collect, store, and use this information.
If this information will be stored and used by a specific DHS component, list the
component-specific authorities.
1. Section 641 of the Illegal Immigration Reform and Immigrant Responsibility Act
(IIRIRA) of 1996 (codified at 8 U.S.C. 1372), Public Law 104-208;
2. The Omnibus Consolidated Appropriations Act of 1997, Pub. L. No. 104-208, 110
Stat 3009;
3. U.S.A. PATRIOT Act of 2001, Public Law 107-56;
4. 8 U.S.C. § 1732; 8 U.S.C. § 1761, 8 U.S.C. § 1762;
5. Homeland Security Presidential Directive-2 (HSPD 2, Combating Terrorism
Through Immigration Policies, as amended by HSPD-5, Management of Domestic
Incidents, Compilation of HSPDs);
6. 8 C.F.R. § 214.2(f)(10)-(12); 8 C.F.R. § 214.13; and, 8 C.F.R. § 274a.12(b)(6)(iv).

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?
b. From which type(s) of
individuals does this form

☒ Yes
☐ No
☒ Members of the public
☐ U.S. citizens or lawful permanent
residents

1

Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which is linked or linkable to that individual regardless of whether the individual is a U.S. citizen, lawful permanent resident,
visitor to the U.S., or employee or contractor to the Department.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

collect information?
(Check all that apply.)

☒ Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.

c. Who will complete and
submit this form? (Check
all that apply.)

☐ The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney,
etc.).
☐ Business entity.
If a business entity, is the only
information collected business contact
information?
☐ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☒ Other individual/entity/organization that is
NOT the record subject. Please describe.
As noted above, the DSO completes the Form I-20
in SEVIS for nonimmigrants. F and M students in
OPT may use the SEVP Portal to update a subset
of the initial information collected on the form
provided by the DSO during the acceptance
process or request the DSO update the SEVIS
record.

d. How do individuals
complete the form? Check
all that apply.

☐ Paper.
☐ Electronic. (ex: fillable PDF)
☒ Online web form.2 (available and submitted
using the internet)
Provide link: https://egov.ice.gov/sevis/

2

The Form I-20 is a document issued by SEVP-certified schools that provides information on an F or M student’s
nonimmigrant status. Currently, the Form I-20 is completed by a DSO in SEVIS and issued in hard-copy. As paperless
processes of data collection and verification mature, Form I-20 information will be managed entirely electronically
through the web.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

School officials complete the Form I-20 in SEVIS
and send the Form I-20 to the student via mail.
e. What information will DHS collect on the form? List all PII data elements on the
form. If the form will collect information from more than one type of individual,
please break down list of data elements collected by type of individual.
Non-immigrant PII collected:
• Name (surname/primary name, passport name, and preferred name)
• Signature (Student, and Parent or Guardian)
• Date of Birth
• City of birth
• Country of birth
• Country of citizenship
• Gender
• Address (foreign address, U.S. physical address, and U.S. mailing address)
• Email address
• Telephone number (foreign and U.S.)
• School funding
• Student’s personal funds
• Funds from other sources
• On-campus employement funds
Non-immigrant’s Dependents PII Collected:
• Name (surname/primary name, given name, passport name, preferred name)
• Relationship to nonimmigrant (Minor child/Spouse)
• City of birth
• Country of birth
• Country of citizenship
• Address
• Email address
• Birth date
• Gender
• Telephone number (foreign and U.S.)
Non-immigrant’s Employer (and Supervisor) PII collected:
• Student Employment Identification Number
• Employment Status Duration of Employment
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

• Employer Name
• Employer Location
•
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply.
☐ DHS Electronic Data Interchange
☐ Social Security number
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number

☐ Visa Number
☐ Passport Number

☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:
g. List the specific authority to collect SSN or these other SPII elements.
N/A
h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
N/A
i. Are individuals
☐ Yes. Please describe how notice is provided.
provided notice at the
time of collection by
DHS (Does the records
☒ No. F and M nonimmigrants are made aware of the
subject have notice of
initial information collection upon acceptance and
the collection or is
receipt of the Form I-20 sent by the DSO.
form filled out by
third party)?

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. N/A
the original,
☒ Electronic. Please describe the IT system that will
completed IC/forms?
store the data from the form. SEVIS maintains and
tracks all nonimmigrant information.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository. I-20 Forms may be uploaded
into SEVP’s Student and Exchange Visitor Program
Automated Management System (SEVPAMS) where
an update is required by a school official.
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). School
officials complete the Form I-20 in SEVIS. As noted
above, a student participating in OPT may choose to
create a SEVP Portal account where he or she will
have limited access to update information maintained
in their SEVIS record.
☒ Automatically. Batch processing is available to
schools when multiple Form I-20s need to be updated
and/or completed. Schools create a batch file and it is
imported into SEVIS.

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

☒ By a unique identifier.3If information is retrieved
by personal identifier, please submit a Privacy Act
Statement with this PTA.
SEVIS ID is the primary identifier used to retrieve a
student’s SEVIS record/information collection. The
student’s name can also be used to retrieve a SEVIS
record.
☒ By a non-personal identifier. Additionally, SEVIS
users can conduct high level data searches or filter
information using multiple non-personal identifiers
such as country of birth, country of citizenship, or
employer identification number (EIN) to view a list of
students associated with an employer.
Records in SEVIS are currently unscheduled and will
be retained indefinitely until a records schedule is
approved by the National Archives and Records
Administration.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
3

Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which is linked or linkable to that individual regardless of
whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to the Department.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

e. How do you ensure
See above.
that records are
disposed of or deleted
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☒ Yes, information is shared with other DHS components or offices. Please describe.
SEVP shares Form I-20 information with the following ICE program offices and
other DHS components for audit, enrolmment, compliance, enforcement,
investigatory, litigation and other purposes:
• HSI Operational Systems Development and Management (OSDM) Unit and
its system, FALCON Search and Analysis
• Counterterrorism and Criminal Exploitation Unit, LeadTrac
• Enforcement and Removal Operations
• U.S. Customs and Border Protection, and
• U.S. Citizenship and Immigration Services.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
SEVP shares Form I-20 information the following external federal agencies for
audit, enrolmment, compliance, enforcement, investigatory, litigation and other
purposes:
• The Department of State, Consular Affairs
• The Department of Treasury, Financial Management Services
• The Department of Justice, Federal Bureau of Investigation
• The Department of Defense, United States Airforce
• The National Counterterrorism Center
• The Commerce Department, Census Bureau, and
• The information may also be shared external DHS with federal, state, local,
tribal, territorial, and foreign law enforcement; other government agencies;
and other parties for audit, enrollment, enforcement, investigatory, litigation,
or other purposes.
☐ No. Information on this form is not shared outside of the collecting office.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Kevin Mullinx, Nicole LaCicero

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:

December 14, 2020

Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

January 6, 2021
☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
ICE Privacy recommends that the DHS Form I-17, Petition for Approval of School for
Attendance by Nonimmigrant Student, has PIA coverage under DHS/ICE/PIA-001 SEVP and
SORN coverage under DHS/ICE-001 SEVIS, and the publication of the forthcoming
DHS/ICE-001 SEVP SORN.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Sean McGuinness

Approved by:
PRIVCATS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

Riley Dean
0015862
January 8, 2021
January 8, 2024

DESIGNATION
Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☒ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☒ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

Privacy Act
Statement:
PTA:
PIA:

SORN:

Choose an item.
e(3) statement in Appendix is approved.
No system PTA required.
Click here to enter text.
System covered by existing PIA
If covered by existing PIA, please list: DHS/ICE/PIA-001 Student and
Exchange Visitor Program
If a PIA update is required, please list: Click here to enter text.
System covered by existing SORN

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

If covered by existing SORN, please list: DHS/ICE 001 Student and
Exchange Visitor Information System, January 5, 2010, 75 FR 412 and
forthcoming SEVP SORN.
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
ICE Privacy is submitting this PTA because DHS Form I-20 is used to determine
eligibility for F and M nonimmigrant student status and benefits. Nonimmigrant
students must provide a Form I-20 for any eligible dependents that they plan on
bringing to the United States. SEVP shares Form I-20 information with U.S. Customs
and Border Protection and U.S. Citizenship and Immigration Services.
The DHS Privacy Office (PRIV) finds that Form I-20 is privacy sensitive as it collects
PII from members of the public requiring PIA/SORN coverage.
PRIV agrees with ICE Privacy that the SEVIS PIA and subsequent updates provides
coverage. DHS/ICE/PIA-001(c) discusses the privacy risks associated with
submitting the Form I-20 for F-1 and M-1 nonimmigrants.
PRIV finds that SORN coverage is required as Form I-20 retrieves information by a
personal identifier. PRIV agrees with ICE Privacy that DHS/ICE-001 SEVIS SORN
covers the collection of SEVIS data.
PRIV finds that an e(3) statement is required because it is DHS policy is to provide a
Privacy Act Statement to all persons asked to provide personal information about
themselves. PRIV approves the e(3) statement in the Appendix.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Appendix A – Privacy Notice
SEVIS – Certification and Eligibility of Nonimmigrant Status
Form I-20: Certificate of Eligibility for Nonimmigrant Student Status
Privacy Notice
Authority: U.S. Immigration and Customs Enforcement (ICE) is authorized to collect
information by Section 641 of the Illegal Immigration Reform and Immigrant
Responsibility Act (IIRIRA) of 1996 (codified at 8 U.S.C. § 1372); the Omnibus Consolidated
Appropriations Act of 1997, Pub. L. No. 104-208, 110 Stat 3009; USA PATRIOT Act of 2001,
Pub. L. No. 107-56, 115 Stat 284; 8 U.S.C. § 1732; 8 U.S.C. § 1761, 8 U.S.C. § 1762;
Homeland Security Presidential Directive-2 (HSPD 2, Combating Terrorism Through
Immigration Policies), as amended by HSPD-5, Management of Domestic Incidents,
Compilation of HSPDs); 8 C.F.R. § 214.2(f)(10)-(12); 8 C.F.R. § 214.13; and, 8 C.F.R. §
274a.12(b)(6)(iv).
Purpose: The primary purpose for solicitating this information from F and M
nonimmigrants is to determine elibility in a vocational or academic program and ensure
compliance with federal immigrations laws, rules and regulations required for
participation in the Student and Exchange Visitor Program (SEVP). ICE SEVP uses the ICE
Student and Exchange Visitor Program Information System (SEVIS) to collect and maintain
nonimmigrant information provided by designated school officials (DSO). Additionally, F
and M nonimmigrants participating in Optional Pratical Training (OPT) may choose to
create a student account in the SEVP Portal. The SEVP Portal enables students to update
certain information collected and/or employer information in SEVIS via the portal or
request the DSO update their information directly through SEVIS.
Routine Uses: The information will be used by and disclosed to DHS personnel for agency
purposes. Additionally, information may be used or disclosed to federal, state, local, tribal,
territorial, and foreign government and law enforcement entities and other parties for
audit, enforcement, investigatory, litigation, or pursuant to all laws and in accordance with
departmental policies.
For United States Citizens or Lawful Permanent Residents, or individuals whose records
are covered by the Judicial Redress Act of 2015 (5 U.S.C. § 552a note) at the time of
disclosure, information will be used or disclosed by DHS in accordance with the Privacy Act
of 1974, 5 U.S.C. § 552a(b), including pursuant to the routine uses published in the
DHS/ICE-001 Student and Exchange Visitor Information System (SEVIS) System of Records,
which can be viewed at https://www.dhs.gov/system-records-notices-sorns.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Disclosure: The information collection is voluntary. However, failure to provide the
information requested may delay or interfere with the certification and eligibility of the
nonimmigrant’s status and program of study.

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