SEVP has provided the following clarification regarding their 2005 Batch Processing Rules for Schools.
The school must be responsible for the data, but servers do not need to be on their premises. Utilizing a hosted software as a service (SaaS) by a vendor, in which the vendor has direct access to the data, is not supported by SEVP. Vended batch products can be administered on a cloud-based architecture (i.e., Amazon Web Services, etc.), but the data must remain under the sole control of the school/institution, on U.S. -based clouds, a third-party vendor cannot initiate batch from the vendor’s cloud-based servers.
For this reason and because we at IU believe you should have full and unfettered access to your data, we do not provide sunapsis under the Software as a Service model and maintain your student data on our servers.