I-17 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:

I-17

Form Title:

Petition For Approval of School for Attendance by
Nonimmigrant Student
Immigration and
Office:
Student and Exchange
Customs Enforcement
Visitor Program (SEVP)
(ICE)

Component:

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Petition For Approval of School for Attendance by Nonimmigrant
Student
April 30, 2021
OMB Control
1653-0038
OMB Expiration
Number:
Date:
Collection status:
Revision
Date of last PTA (if
December 18, 2017
applicable):
PROJECT OR PROGRAM MANAGER
Name:
Office:
Phone:

Name:

Michael Hallanan

SEVP Policy
202.560.9180

Title:
Email:

Policy analyst
Michael.P.Hallanan@ice.dhs.
gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Scott Elmore

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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

Office:
Phone:

ICE OCIO
Title:
ICE Forms Manager
(202) 732-2601
Email:
Scott.A.Elmore@ice.dhs.gov
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-17, Petition for Approval of
School for Attendance by Nonimmigrant Student, OMB Control No. 1653-0038, is being
submitted for a three-year renewal. There are no changes to this information collection.
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’s School Certification Unit
(SCU) oversees the certification of public and private schools that enroll foreign
nationals (and their dependents) seeking entry into the United States as nonimmigrant
students under F and M classes of admission.
Schools file the Form I-17 petiton as part of the school certification and recertification
processes using SEVP’s Student and Exchange Visitor Information System (SEVIS) after
creating a SEVIS account. The Form I-17 petition consists of three parts:
• The first part of the I-17 contains the information to evaluate for adjudication.
• The second part of the I-17 is the I-17A, the “Record of Designated School Officials.”
The I-17A lists the employees who will serve as Desginated School Officials (DSO),
one of whom must be identified as the Principal Designated School Official (PDSO).
• The third part of the I-17 is the I-17B, the “Record of School Campuses.” The I-17B is
one (1) page and has four (4) slots to record different campuses and locations. If more
than four campuses are included, the school can print additional pages through SEVIS.
The president, owner, or head of school selects the PDSO and any other DSO listed on the
Form I-17A. The PDSO is the point of contact for the school and is required to print out
the Form I-17 and all supporting documentation, obtain necessary signatures, scan all

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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

documents into PDF files and upload these documents via SEVIS. Any updates to the
Form I-17 petition for certification or recertification are also completed via SEVIS.
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. 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 C.F.R. § 214.2(f); 8 C.F.R. § 214.2(m);
6. Approval of schools for enrollment of F and M nonimmigrants, 8 C.F.R Section
214.3;
7. Denial of certification, denial of recertification, or withdrawal of SEVP
certification, 8 C.F.R Section 214.4

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
collect information?
(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.

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

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

☒ The record subject of the form (e.g., the
individual applicant).
1. Individuals with the authority to complete
and submit a Form I-17 petition on behalf
of the school that are identified as:
a. a School owner (e.g., president, private
owner); or
b. a Primary Designated School Official
for the school (pending SEVP
approval).
☒ Legal Representative (preparer, attorney, etc.).
Individuals authorized to prepare a Form I-17
petition on behalf of the school, which only
includes contact information for purposes of the
initial certification process.
☐ 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.
Individuals authorized to prepare a Form I-17
petition on behalf of the school for the initial
certification process may complete and submit
information related to DSO nominees once signed
by the DSO.

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

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

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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

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.
PII collected:
• Private School Owner Name (or president of board of trustees)
• Private School Owner Address
• School Official Name (PDSOs and/or DSOs)
• School Official Title
• School Official Address (i.e., school address)
• School Official Telephone Number
• School Official Email address
• School Official status – U.S. Citizen or Lawful Permanent Resident (LPR)
See Appendix B for screenshots of the PII collected under Form I-17 via SEVIS.
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
☐ Alien Number (A-Number)

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ 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

☐ Bank Account, Credit Card, or other
financial account number
☐ Biometrics
☐ Other. Please list:
g. List the specific authority to collect SSN or these other SPII elements.
8 U.S.C. § 1103, 8 U.S.C. § 1360, and 8 C.F.R. Part 214.3(l)(1)(i) authorize collection of the
Alien Registration Number (A-number).
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.
Per SEVP Fact Sheet: Designated School Official (DSO) Submissions (effective May 21,
2018; https://www.ice.gov/doclib/sevis/pdf/factSheetDsoSubmissions.pdf), section 4.1
“For a Principal Designated School Official (PDSO) or DSO submission, submit one of the
following as proof of U.S. citizenship or LPR:
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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

• U.S. passport or passport card.
• U.S. birth certificate or birth certificate card.
• Alien registration card.
• Naturalization/citizenship certificate.”
Submission of the Alien registration number is an alternative for verification that the
applicant is a U.S. citizen or LPR, as required by 8 C.F.R. Part 214.3(l)(1)(i).
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the
Notice is provided at the time of collection. Schools
time of collection by
officials and owners that complete the form are
DHS (Does the records
aware of the requirements and are provided
subject have notice of
notice at the time of collection. PDSO and/or DSO
the collection or is
nominees are required to sign the Form I-17
form filled out by third
petition before submission and thus, are aware
party)?
that his or her information is being shared to to
certify them as part of the school certification and
recertification process before submission of the
Form I-17.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original, completed
N/A
IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form. SEVIS
☒ Scanned forms (completed forms are scanned into an
electronic repository). Please describe the electronic
repository. SEVIS allows the school to scan signed
documents and other supporting documentation into
SEVP’s Student and Exchange Visitor Program
Automated Management System (SEVPAMS).
b. If electronic, how does
DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe. Schools manually enter this information
directly into SEVIS.
☐ Automatically. N/A

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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

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

☒ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA. Although
retrieval is primarily done on the school name, the name
of a private school owner may identify the name of an
individual, such as the president of a board of trustees. ☒
By a non-personal identifier. SEVIS allows authorized
users to search information maintained on this form
using a number of non-identifiers, such as school name,
district, pending application, or school code.
Additionally, the school name is linked or linkable to an
individual (name of public shool official or sole
proprietor), and may be used to retrieve information
related to a single individual for compliance and/or
investigative purposes.
Records in SEVIS are currently unscheduled and will be
retained indefinitely until a records schedule is approved by
the National Archives and Records Administration (NARA).

d. What is the records
retention schedule(s)?
Include the records
schedule number.
e. How do you ensure that
See above.
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.
For investigative purposes, information may be shared to such offices as ICE/HSI
Counterterrorism and Criminal Exploitation Unit (CTCEU).
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities.
ICE shares information with external agencies and entities in accordance with SORN
routine uses (e.g., investigative and program compliance purposes) and the Privacy Act
2

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

Act of 1974. ICE continually shares information with the Department of Justice, Federal
Bureau of Investigation via a SEVIS interface.
☐ 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:

Kevin Mullinix, 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 5, 2021
☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.

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, pia@hq.dhs.gov
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
0015861
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.
Privacy Act Statement found in Appendix approved along with this PTA
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, pia@hq.dhs.gov
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-17 is used by SEVP as part of
the school certification process. SEVP certification is the result of an adjudication
process that includes a review of the Form I-17 application, submission of
supporting documentation, payment of the application fee, site visits, research and
federal adjudication. Form I-17 collects Private School Owner name and address,
school officials name, title, address, telephone number, and email address, and
school official status – whether or not U.S. Citizen or LPR.
The DHS Privacy Office (PRIV) finds that Form I-17 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 provides coverage. DHS/ICE/PIA001 discusses the privacy risks associated with submitting the Form I-17 for initial
certification, recertification, and update petitions, as well as appeals.
PRIV finds that a SORN is required because Form I-17 retrieves information by a
personal identifier. PRIV agrees with ICE Privacy that DHS/ICE-001 SEVIS SORN
covers the collection of SEVIS data. The forthcoming SEVP SORN will provide
additional coverage.
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 Act Statement
SEVIS – School Certification & Recertification
Form I-17: Petition for Approval of School for Attendance by Nonimmigrant Student
Privacy Act Statement
Authority: U.S. Immigration and Customs Enforcement (ICE) Student and Exchange Visitor
Program (SEVP) 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); 8 C.F.R. § 214.2(m); 8
C.F.R. § 214.3; and 8 C.F.R. § 214.4.
Purpose: The primary purpose for solicitating this information is for the adjudication of
public and private schools seeking to enroll foreign nationals in a vocational or academic
program and is required for participation in the Student and Exchange Visitor Program
(SEVP). ICE SEVP uses the Student and Exchange Visitor Information System (SEVIS) to
collect and maintain information as part of the school certification and recertification
process to certify schools, Designated School Officials (DSO) and Principal DSOs (PDSO)
nominated by schools, and to affirm knowledge of and compliance with federal
immigration rules and regulations related to the admission and maintenance of status for F
and M nonimmigrants, including requirements to maintain updated school and
nonimmigrant student records in SEVIS.
Routine Uses: The information will be used by and disclosed to DHS personnel for agency
purposes and with external parties in accordance with the Privacy Act of 1974, 5 U.S.C. §
552a(b). Additionally, information may be shared with external parties, including federal,
state, local, tribal, territorial, and foreign government and law enforcement entities and
other parties for audit, enforcement, investigatory, litigation purposes, and pursuant to its
published Privacy Act system of records notice. The DHS/ICE-001 SEVIS System of Records
Notice (SORNs) and subsequent SORNs can be viewed at https://www.dhs.gov/systemrecords-notices-sorns.
Disclosure: The information collected is voluntary. However, where failure to provide the
information requested may result in the denial of the initial school certification or school
recertification process and the instituition’s and/or school official’s eligibility to participate
in the Student and Exchange Visitor Program.
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