I-20 Forms PTA

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
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
PIA@hq.dhs.gov

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, pia@hq.dhs.gov
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:
Form Title:
Component:

I-20
Certificate of Eligibility for Nonimmigrant Student Status
Immigration and
Office:
Student & Exchange
Customs Enforcement
Visitor Program (SEVP)
(ICE)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Certificate of Eligibility for Nonimmigrant Student Status
March 31, 2018
OMB Control
1653-0038
OMB Expiration
Number:
Date:
Collection status:
Revision
Date of last PTA (if
N/A
applicable):
Name:
Office:

Phone:
Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
Ezequiel Vasquez
Student and Exchange
Title:
Project Lead
Visitor Program (SEVP)
+(703) 603-3469
Email:
Ezequiel.vasquez@ice.dhs.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Scott Elmore
ICE OCIO
Title:
ICE Forms Manager
+2027322601
Email:
Scott.A.Elmore@ice.dhs.gov

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form.
DHS Form I-20, “Certificate of Eligibility for Nonimmigrant Student Status,” OMB
Control No. 1653-0038, is used to determine eligibility for F 1 and M 2 nonimmigrant
student status and benefits. Also, nonimmigrant students must provide a Form I-20 for
any eligible dependents that they plan on bringing to the United States.

In order to study in the United States, a nonimmigrant student must first apply to an
SEVP-certified school in the United States and be accepted by that school. Once a
nonimmigrant student is accepted into a SEVP-certified school, the respective school
enters the nonimmigrant’s data per the Form I-20 via the Student and Exchange Visitor
Information System (SEVIS). The school official then issues that nonimmigrant student
with a copy of the completed Form I-20, otherwise known as a Certificate of Eligibility
(COE). The nonimmigrant student is then responsible to verify that the information is
correct and to use that COE 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 nonimmigrant visa: Prior to entering the United States, Form I-20 lists
the program start date. Nonimmigrant students may enter the United States 30
days prior to this date.
3. Enter the United States: Form I-20 must be presented to the U.S. Customs and
Border Protection at the port of entry.
4. Change of status to F or M while in United States: Nonimmigrant students must
provide Form I-20 when applying to USCIS to change status to F or M.
5. Apply for benefits: Nonimmigrant students may need to present Form I-20 to
apply for a driver’s license, social security number, or other benefits.

At this time, nonimmigrant students with practical training can verify and update some
of the information collected using Form I-20 through the SEVP Portal, a SEVIS subsystem. Information that is entered in SEVP Portal directly updates the nonimmigrant
student’s SEVIS record. Details related to SEVP Portal are laid out in the DHS/ICE/PIA001(c) Student and Exchange and Visitor Information System (SEVIS) PIA.
Form I-20 is being reviewed and revised.

1
2

F Students: Form I-20, “Certificate of Eligibility for Nonimmigrant Student Status – For Academic and Language Students.”
M Students: Form I-20, “Certificate of Eligibility for Nonimmigrant Student Status – For Vocational Students.”

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

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.
Authority for collecting Form I-20 information as follows:
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. Public Law 107-56, U.S.A. PATRIOT Act;
3. 8 U.S.C. 1372;
4. Homeland Security Presidential Directive-2 (HSPD 2, Combating Terrorism
Through Immigration Policies), as amended by HSPD-5, Management of Domestic
Incidents, Compilation of HSPDs);
5. 8 CFR 214.2(f)(10)-(12); and
6. 8 CFR 274a.12(b)(6)(iv).
2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 3)?

b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

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

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.

☒ The record subject of the form (e.g., the
individual applicant). Updates Form I-20
information inputted by the school official in
SEVIS.
☐ Legal Representative (preparer, attorney,
etc.).
☐ Business entity.

3
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, pia@hq.dhs.gov
www.dhs.gov/privacy

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

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.
School official inputs the information requested by
the Form I-20 into SEVIS.
☐ Paper. (See attached. See Appendix A)
☐ Electronic. (ex: fillable PDF)
☒ Online web form. 4 (available and submitted
via the internet)
Access via SEVIS and SEVP Portal

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.
Below are links that outline all the information collected under Form I-20 via SEVIS.
•
•

https://studyinthestates.dhs.gov/sevis-help-hub/student-records
https://studyinthestates.dhs.gov/sevis-help-hub/student-records/certificates-ofeligibility
• https://studyinthestates.dhs.gov/sevis-help-hub/student-records/updatestudent-records
Dependents: https://studyinthestates.dhs.gov/sevis-help-hub/studentrecords/dependents
• https://studyinthestates.dhs.gov/sevis-help-hub/studentrecords/dependents/add-dependent-to-student-record
Student Employment:
• https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-studentemployment

4
Currently, Form I-20 is a paper form completed by a designated school official. Eventually with the first release of SEVIS Mod, Form I-20 will
become a web form for designated school officials to complete. (See SEVISNIM-263).

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Optional Practical Training (OPT):
• https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-studentemployment/f-1-optional-practical-training
• https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-studentemployment/add-edit-delete-opt-employer
M-1 Practical Training:
• https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-studentemployment/m-1-practical-training
CPT:
• https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-studentemployment/curricular-practical-training-cpt
Off-Campus Employment:
https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-studentemployment/off-campus-employment-and-international-organization-internship
Non-immigrant PII collected:
• Name (surname/primary name, passport name, and preferred name)
• Date 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.)
• Financial support information
o Funding
 Student’s personal funds
 Funds from other sources

Non-immigrant’s Dependents PII Collected:
• Name (surname/primary name, given name, passport name, preferred name)
• Relationship to non-immigrant
• Email address
• Birth date
• Country of birth
• Country of citizenship
• Gender

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Employer PII Collected:
• Employer Identification Number (EIN) 5
• Supervisor Name
• Supervisor Phone number
• Supervisor Email address

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.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other:
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.

5

Are individuals
provided notice at the
time of collection by
DHS (Does the records
subject have notice of
the collection or is

☒ Yes. Please describe how notice is provided.
Privacy statement is provided to nonimmigrants
that enter their information directly into the SEVP
Portal, a sub-system of SEVIS.
☐ No.

Please note that EIN may be a social security number for sole proprietors.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

form filled out by
third party)?

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will

b. If electronic, how
does DHS input the
responses into the IT
system?

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

store the data from the form.
Student & Exchange Visitor Information System
(SEVIS) and SEVP Portal, a SEVIS sub-system.
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.
☒ Manually (data elements manually entered). Please
describe.
School officials (via SEVIS)
Students with OPT or STEM OPT (via SEVP Portal)
☒ Automatically. Please describe.
Batch processing is available to schools when
multiple Form I-20s need to be completed. Schools
create a batch file and it is imported into SEVIS.
☒ By a unique identifier. 6 Please describe. Name, EIN
If information is retrieved by personal identifier,
please submit a Privacy Act Statement with this PTA.
See Appendix A for a copy of the Privacy Statement.

☒ By a non-personal identifier. Please describe.
For high level data searches, non-personal identifiers
such as country of birth, country of citizenship, and
gender may be used.

6

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, pia@hq.dhs.gov
www.dhs.gov/privacy

d. What is the records
The SEVIS records retention schedule is in draft. Until
retention
the schedule is approved by NARA, SEVIS records are
schedule(s)? Include
maintained permanently.
the records schedule
number.
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 U.S. Customs and Border Protection and U.S.
Citizenship and Immigration Services. Portal information may be shared internally
within the DHS for audit, enrollment, enforcement, investigatory, litigation, or other
purposes.
☒ 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 to Department of State when the nonimmigrant goes
to apply for an F or M visa, so to enter the country and attend the SEVP certified school.
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.

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, pia@hq.dhs.gov
www.dhs.gov/privacy

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

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

Michelle Escobar

November 3, 2017
December 8, 2017

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

See Appendix A for a copy of the Privacy
Statement.
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 PTA is sufficient at this time. The information collected
by the Form-20 is covered under DHS/ICE/PIA-001 and DHS/ICE/PIA-001(c) Student and
Exchange and Visitor Information System (SEVIS) PIA and the DHS/ICE-001 SEVIS SORN.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

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

Max Binstock

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

1154894
December 20, 2017
December 20, 2020

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

DHS PRIV has commented on this ICR/Form.

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.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
New e(3) statement is required.
Statement:
e(3) statement in Appendix is approved.
PTA:
No system PTA required.
Click here to enter text.
PIA:
System covered by existing PIA
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

If covered by existing PIA, please list: DHS/ICE/PIA-001 Student And
Exchange Visitor Information System (SEVIS) and subsequent updates
If a PIA update is required, please list: Click here to enter text.
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/ICE 001 Student and
Exchange Visitor Information System, January 5, 2010, 75 FR 412
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.
PRIV finds that is a privacy sensitive system and a PIA is required because the Form
I-20 collects PII from members of the public. 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 a SORN is required because Form I-20 retrieves information by a
unique 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, pia@hq.dhs.gov
www.dhs.gov/privacy

Appendix A – Privacy Statement
SEVP Portal

Form I-20: Certificate of Eligibility for Nonimmigrant Student Status
Form I-983: Training Plan for STEM OPT Students

Privacy Statement

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), Public Law 104-208; Public
Law 107-56, U.S.A. PATRIOT Act; 8 U.S.C. 1372; 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 CFR 214.2(f)(10)-(12) and 8
CFR 274a.12(b)(6)(iv).

Purpose: Your information collected through the ICE Student and Exchange Visitor
Program (SEVP) Portal is used to assist with the administration of practical training. The
designated school officials (DSO) may use your information to review and manage practical
training opportunities for you.
Agency Disclosure of Information: Your information may be shared internally within the
U.S. Department of Homeland Security (DHS), as well as 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.

If you become a United States Citizen or Lawful Permanent Resident, your information may
be shared internally within the DHS, as well as with federal, state, local, tribal, territorial,
and foreign law enforcement; other government agencies; and other parties for audit,
enforcement, investigatory, litigation, or other purposes. This disclosure is 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 www.dhs.gov/privacy.
Providing Information to DHS: The information you provide is voluntary. However,
failure to provide the information requested may delay or interfere with the approval or
maintenance of your practical training. Failure to provide your information could also limit
or terminate your practical training opportunity.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Appendix B – PII Collected
Non-Immigrant PII Collected:

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Non-Immigrant Financial PII Collected:

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Non-Immigrant’s Dependent PII Collected:

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Employer PII Collected:

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