SEVP has provided the following clarification regarding their 2005 Batch Processing Rules for Schools <LINK to HTML Version>.
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.