CJIS policy diff procedure

CJIS Policy diff.md

1. Download the PDF and pass new and old versions through: http://pdftotext.com/

2. Take each text file and run the following bash file on it to strip out the pagination, which can really muck with the diff. Call it with < file strip-pages major.minor > file-stripped

#!/bin/bash

version=${1}
footer=CJISD-ITS-DOC-08140-$version

infooter=0
while IFS='' read -r line || [ -n "$line" ]; do
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    infooter=1 && \
    dateline=$line && \
    continue

  [ $infooter -eq 0 ] && echo $line && continue

  # We're in a footer. $date is the date line
  [[ $line =~ ^CJISSD-ITS-DOC-08140-${version}$ ]] && versionline=$line && continue
  [[ -z "$line" ]] && blankline=1 && continue
  [[ $line =~ ^[0-9ixv]*$ ]] && pagenumber=$line && continue
#[[ $line =~ ^\cl.* ]] && \
  [[ $line =~ ^.*$ ]] && \
    infooter=0 &&            \
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    echo ${line:1}
done

CJIS-5.5 (stripped).txt

U. S. Department of Justice
Federal Bureau of Investigation
Criminal Justice Information Services Division

Criminal Justice Information Services (CJIS)
Security Policy
Version 5.5
EXECUTIVE SUMMARY
Law enforcement needs timely and secure access to services that provide data wherever and
whenever for stopping and reducing crime. In response to these needs, the Advisory Policy Board
(APB) recommended to the Federal Bureau of Investigation (FBI) that the Criminal Justice
Information Services (CJIS) Division authorize the expansion of the existing security management
structure in 1998. Administered through a shared management philosophy, the CJIS Security
Policy contains information security requirements, guidelines, and agreements reflecting the will
of law enforcement and criminal justice agencies for protecting the sources, transmission, storage,
and generation of Criminal Justice Information (CJI). The Federal Information Security
Management Act of 2002 provides further legal basis for the APB approved management,
operational, and technical security requirements mandated to protect CJI and by extension the
hardware, software and infrastructure required to enable the services provided by the criminal
justice community.
The essential premise of the CJIS Security Policy is to provide appropriate controls to protect the
full lifecycle of CJI, whether at rest or in transit. The CJIS Security Policy provides guidance for
the creation, viewing, modification, transmission, dissemination, storage, and destruction of CJI.
This Policy applies to every individual—contractor, private entity, noncriminal justice agency
representative, or member of a criminal justice entity—with access to, or who operate in support
of, criminal justice services and information.
The CJIS Security Policy integrates presidential directives, federal laws, FBI directives and the
criminal justice community’s APB decisions along with nationally recognized guidance from the
National Institute of Standards and Technology. The Policy is presented at both strategic and
tactical levels and is periodically updated to reflect the security requirements of evolving business
models. The Policy features modular sections enabling more frequent updates to address emerging
threats and new security measures. The provided security criteria assists agencies with designing
and implementing systems to meet a uniform level of risk and security protection while enabling
agencies the latitude to institute more stringent security requirements and controls based on their
business model and local needs.
The CJIS Security Policy strengthens the partnership between the FBI and CJIS Systems Agencies
(CSA), including, in those states with separate authorities, the State Identification Bureaus (SIB).
Further, as use of criminal history record information for noncriminal justice purposes continues
to expand, the CJIS Security Policy becomes increasingly important in guiding the National Crime
Prevention and Privacy Compact Council and State Compact Officers in the secure exchange of
criminal justice records.
The Policy describes the vision and captures the security concepts that set the policies, protections,
roles, and responsibilities with minimal impact from changes in technology. The Policy empowers
CSAs with the insight and ability to tune their security programs according to their risks, needs,
budgets, and resource constraints while remaining compliant with the baseline level of security set
forth in this Policy. The CJIS Security Policy provides a secure framework of laws, standards, and
elements of published and vetted policies for accomplishing the mission across the broad spectrum
of the criminal justice and noncriminal justice communities.

CHANGE MANAGEMENT
Revision

Change Description

Created/Changed by

Date

Approved By

5.0

Policy Rewrite

Security Policy
Working Group

SUMMARY OF CHANGES
Version 5.5
APB Approved Changes
1. Section 5.2 Policy Area 2: Security Awareness Training: added language, Spring 2015,
APB20, SA2, Security Awareness Training Requirements.
2. Section 5.2.1.1 All Personnel: change section title to “Level One Security Awareness
Training”, modify language and required training topics, Spring 2015, APB20, SA2,
Security Awareness Training Requirements.
3. Section 5.2.1.2 Personnel with Physical and Logical Access: change section title to
“Level Two Security Awareness Training”, modify language and moved required
training topics from previous Section 5.2.1.1, Spring 2015, APB20, SA2, Security
Awareness Training Requirements.
4. Section 5.2.1.3 Personnel with Information Technology Roles: change section title to
“Level Three Security Awareness Training”, modify language and moved required
training topics from previous Section 5.2.1.2, Spring 2015, APB20, SA2, Security
Awareness Training Requirements.
5. Section 5.2.1.4 Level Four Security Awareness Training: added section and moved
required training topics from previous Section 5.2.1.3, Spring 2015, APB20, SA2,
Security Awareness Training Requirements.
6. Section 5.2 Figure 4: changed figure title and added a use case for each level of security
awareness training, Fall 2015, APB12, SA4, Security Awareness Training Requirements.
7. Section 5.3 Incident Response: modified language to indicate any incident involving
criminal justice information, Fall 2015, APB12, SA3, Security Incident Response
Reporting.
8. Section 5.6.2.2 Advanced Authentication: add language describing the use of out-of-band
authenticator, Spring 2015, APB 20, SA4, Clarification of Out-of-Band Authentication
for Advanced Authentication (AA).
9. Section 5.9.1 Physically Secure Location: modified language to include security
awareness training reference, Spring 2015, APB20, SA2, Security Awareness Training
Requirements.
10. Section 5.10.2 Facsimile Transmission of CJI: modified language and introduced a new
requirement, Fall 2015, APB12, SA1, Faxing Requirements in the CJIS Security Policy.
11. Section 5.11.2 Audits by the CSA: add language allowing CSA audits of vendor
facilities, Spring 2015, APB 20, SA3, CJIS Systems Agency (CSA) Audit of Contractor
Facilities.
12. Section 5.12.1.1(7) Minimum Screening Requirements for Individuals Requiring Access
to CJI: add language allowing CSO delegation of continuing access determination for
non-felony offenses, Spring 2015, APB 20, SA5, CJIS Systems Officer (CSO)
Delegation of Personnel Screening Requirements.
13. Section 5.13 Policy Area 13: Mobile Devices: modify language throughout the entire
section based on Mobile Security Task Force recommendations, Fall 2015, APB12, SA2,
Request to Modify CJIS Security Policy Section 5.13 Mobile Devices.
14. Appendix A Terms and Definitions: add definitions for “Out-of-band” and “In-band”,
Spring 2015, APB 20, SA4, Clarification of Out-of-Band Authentication for Advanced
Authentication (AA).
15. Appendix A Terms and Definitions: add definition for “Facsimile (Fax)”, Fall 2015,
APB12, SA1, Faxing Requirements in the CJIS Security Policy.
16. Appendix A Terms and Definitions: add definitions for “Full-feature Operating System”,
“Limited-feature Operating System”, “Mobile (WiFi) Hotspot”, “Wireless Access Point”,
and “Wireless (WiFi) Hotspot”, Fall 2015, APB12, SA2, Request to Modify CJIS
Security Policy Section 5.13 Mobile Devices.
17. Appendix F.1 Security Incident Response Form: modified form to indicate any incident
involving criminal justice information, Fall 2015, APB12, SA3, Security Incident
Response Reporting.
18. Appendix K Criminal Justice Agency Supplemental Guidance: replace current appendix
with new appendix, Spring 2015, APB 20, SA8, Evaluation of Appendix K.
Administrative Changes1
1. Figure 14 – A Local Police Department’s Information Systems & Communications
Protections: change the title of the figure and add use faxing cases. Security and Access
Subcommittee requested the use cases be added.
2. Appendix C Network Topology Diagrams, Figures C.1-A, B, C, and D: added required
information from Section 5.7.1.2 Network Diagram to diagrams. Sample diagrams did
not contain the required elements of agency name, effective date of drawing, and “For
Official Use Only” marking.
3. Appendix G Best Practices: added new Appendix G.5 Administrator Accounts for Least
Privilege and Separation of Duties, Spring 2015, SA6 (info only). Security and Access
Subcommittee approved the appendix to be added under the APB approved ISO latitude
for administrative changes.

KEY TO APB APPROVED CHANGES (e.g. “Fall 2013, APB11, SA6, Future CSP for Mobile
Devices”):
Fall 2013 – Advisory Policy Board cycle and year
APB## – Advisory Policy Board Topic number
SA# – Security and Access Subcommittee Topic number
Topic Title

1

Administrative changes are vetted through the Security and Access Subcommittee and not the entire APB process.

TABLE OF CONTENTS
Executive Summary ....................................................................................................................... i
Change Management .................................................................................................................... ii
Summary of Changes ................................................................................................................... iii
Table of Contents ...........................................................................................................................v
List of Figures .................................................................................................................................x
1 Introduction ............................................................................................................................1
1.1 Purpose.................................................................................................................................1
1.2 Scope ....................................................................................................................................1
1.3 Relationship to Local Security Policy and Other Policies ...................................................1
1.4 Terminology Used in This Document..................................................................................2
1.5 Distribution of the CJIS Security Policy ..............................................................................2
2 CJIS Security Policy Approach ............................................................................................3
2.1 CJIS Security Policy Vision Statement................................................................................3
2.2 Architecture Independent .....................................................................................................3
2.3 Risk Versus Realism ............................................................................................................3
3 Roles and Responsibilities .....................................................................................................4
3.1 Shared Management Philosophy..........................................................................................4
3.2 Roles and Responsibilities for Agencies and Parties ...........................................................4
3.2.1 CJIS Systems Agencies (CSA) ..................................................................................5
3.2.2 CJIS Systems Officer (CSO) ......................................................................................5
3.2.3 Terminal Agency Coordinator (TAC) ........................................................................6
3.2.4 Criminal Justice Agency (CJA)..................................................................................6
3.2.5 Noncriminal Justice Agency (NCJA) .........................................................................6
3.2.6 Contracting Government Agency (CGA) ..................................................................7
3.2.7 Agency Coordinator (AC) ..........................................................................................7
3.2.8 CJIS Systems Agency Information Security Officer (CSA ISO) ..............................7
3.2.9 Local Agency Security Officer (LASO) ....................................................................8
3.2.10 FBI CJIS Division Information Security Officer (FBI CJIS ISO) .............................8
3.2.11 Repository Manager ...................................................................................................9
3.2.12 Compact Officer .........................................................................................................9
4 Criminal Justice Information and Personally Identifiable Information ........................10
4.1 Criminal Justice Information (CJI) ....................................................................................10
4.1.1 Criminal History Record Information (CHRI) .........................................................10
4.2 Access, Use and Dissemination of Criminal History Record Information (CHRI), NCIC
Restricted Files Information, and NCIC Non-Restricted Files Information ......................11
4.2.1 Proper Access, Use, and Dissemination of CHRI ....................................................11
4.2.2 Proper Access, Use, and Dissemination of NCIC Restricted Files Information ......11
4.2.3 Proper Access, Use, and Dissemination of NCIC Non-Restricted Files
Information.....................................................................................................................11
4.2.3.1 For Official Purposes .........................................................................................11
4.2.3.2 For Other Authorized Purposes .........................................................................12
4.2.3.3 CSO Authority in Other Circumstances ............................................................12
4.2.4 Storage ......................................................................................................................12
4.2.5 Justification and Penalties ........................................................................................12
4.2.5.1 Justification ........................................................................................................12
4.2.5.2 Penalties .............................................................................................................12
4.3 Personally Identifiable Information (PII)...........................................................................12
5 Policy and Implementation .................................................................................................14
5.1 Policy Area 1: Information Exchange Agreements ...........................................................15
5.1.1 Information Exchange ..............................................................................................15
5.1.1.1 Information Handling.........................................................................................15
5.1.1.2 State and Federal Agency User Agreements .....................................................15
5.1.1.3 Criminal Justice Agency User Agreements .......................................................16
5.1.1.4 Interagency and Management Control Agreements ..........................................16
5.1.1.5 Private Contractor User Agreements and CJIS Security Addendum.................16
5.1.1.6 Agency User Agreements ..................................................................................17
5.1.1.7 Outsourcing Standards for Channelers ..............................................................17
5.1.1.8 Outsourcing Standards for Non-Channelers ......................................................18
5.1.2 Monitoring, Review, and Delivery of Services ........................................................18
5.1.2.1 Managing Changes to Service Providers ...........................................................18
5.1.3 Secondary Dissemination .........................................................................................18
5.1.4 Secondary Dissemination of Non-CHRI CJI ...........................................................18
5.1.5 References/Citations/Directives ...............................................................................19
5.2 Policy Area 2: Security Awareness Training .....................................................................20
5.2.1 Awareness Topics ....................................................................................................20
5.2.1.1 Level One Security Awareness Training ...........................................................20
5.2.1.2 Level Two Security Awareness Training ..........................................................20
5.2.1.3 Level Three Security Awareness Training ........................................................20
5.2.1.4 Level Four Security Awareness Training ..........................................................21
5.2.2 Security Training Records ........................................................................................22
5.2.3 References/Citations/Directives ...............................................................................22
5.3 Policy Area 3: Incident Response ......................................................................................24
5.3.1 Reporting Security Events ........................................................................................24
5.3.1.1 Reporting Structure and Responsibilities...........................................................24
5.3.1.1.1 FBI CJIS Division Responsibilities ............................................................ 24
5.3.1.1.2 CSA ISO Responsibilities ........................................................................... 24
5.3.2 Management of Security Incidents ...........................................................................25
5.3.2.1 Incident Handling...............................................................................................25
5.3.2.2 Collection of Evidence .......................................................................................25
5.3.3 Incident Response Training ......................................................................................25
5.3.4 Incident Monitoring..................................................................................................25
5.3.5 References/Citations/Directives ...............................................................................26
5.4 Policy Area 4: Auditing and Accountability ......................................................................27
5.4.1 Auditable Events and Content (Information Systems) .............................................27
5.4.1.1 Events .................................................................................................................27
5.4.1.1.1 Content ........................................................................................................ 28
5.4.2 Response to Audit Processing Failures ....................................................................28
5.4.3 Audit Monitoring, Analysis, and Reporting .............................................................28
5.4.4 Time Stamps .............................................................................................................28
5.4.5 Protection of Audit Information ...............................................................................28
5.4.6 Audit Record Retention ............................................................................................28
5.4.7 Logging NCIC and III Transactions .........................................................................29
5.4.8 References/Citations/Directives ...............................................................................29
5.5 Policy Area 5: Access Control ...........................................................................................30
5.5.1 Account Management ..............................................................................................30
5.5.2 Access Enforcement .................................................................................................30
5.5.2.1 Least Privilege ...................................................................................................31
5.5.2.2 System Access Control ......................................................................................31
5.5.2.3 Access Control Criteria ......................................................................................31
5.5.2.4 Access Control Mechanisms ..............................................................................31
5.5.3 Unsuccessful Login Attempts ..................................................................................32
5.5.4 System Use Notification...........................................................................................32
5.5.5 Session Lock ............................................................................................................32
5.5.6 Remote Access .........................................................................................................33
5.5.6.1 Personally Owned Information Systems ............................................................33
5.5.6.2 Publicly Accessible Computers .........................................................................34
5.5.7 References/Citations/Directives ...............................................................................34
5.6 Policy Area 6: Identification and Authentication ..............................................................35
5.6.1 Identification Policy and Procedures ........................................................................35
5.6.1.1 Use of Originating Agency Identifiers in Transactions and Information
Exchanges ..................................................................................................................35
5.6.2 Authentication Policy and Procedures .....................................................................35
5.6.2.1 Standard Authenticators .....................................................................................36
5.6.2.1.1 Password ..................................................................................................... 36
5.6.2.1.2 Personal Identification Number (PIN) ........................................................ 36
5.6.2.2 Advanced Authentication...................................................................................37
5.6.2.2.1 Advanced Authentication Policy and Rationale ......................................... 37
5.6.2.2.2 Advanced Authentication Decision Tree .................................................... 38
5.6.3 Identifier and Authenticator Management ...............................................................39
5.6.3.1 Identifier Management .......................................................................................40
5.6.3.2 Authenticator Management ................................................................................40
5.6.4 Assertions .................................................................................................................40
5.6.5 References/Citations/Directives ...............................................................................40
5.7 Policy Area 7: Configuration Management .......................................................................46
5.7.1 Access Restrictions for Changes ..............................................................................46
5.7.1.1 Least Functionality.............................................................................................46
5.7.1.2 Network Diagram...............................................................................................46
5.7.2 Security of Configuration Documentation ...............................................................46
5.7.3 References/Citations/Directives ...............................................................................46
5.8 Policy Area 8: Media Protection ........................................................................................48
5.8.1 Media Storage and Access .......................................................................................48
5.8.2 Media Transport .......................................................................................................48
5.8.2.1 Digital Media during Transport .........................................................................48
5.8.2.2 Physical Media in Transit ..................................................................................48
5.8.3 Digital Media Sanitization and Disposal ..................................................................48
5.8.4 Disposal of Physical Media ......................................................................................48
5.8.5 References/Citations/Directives ...............................................................................49
5.9 Policy Area 9: Physical Protection ....................................................................................50
5.9.1 Physically Secure Location ......................................................................................50
5.9.1.1 Security Perimeter ..............................................................................................50
5.9.1.2 Physical Access Authorizations .........................................................................50
5.9.1.3 Physical Access Control ....................................................................................50
5.9.1.4 Access Control for Transmission Medium ........................................................50
5.9.1.5 Access Control for Display Medium .................................................................50
5.9.1.6 Monitoring Physical Access ..............................................................................51
5.9.1.7 Visitor Control ...................................................................................................51
5.9.1.8 Delivery and Removal .......................................................................................51
5.9.2 Controlled Area ........................................................................................................51
5.9.3 References/Citations/Directives ...............................................................................51
5.10 Policy Area 10: System and Communications Protection and Information Integrity .......52
5.10.1 Information Flow Enforcement ................................................................................52
5.10.1.1 Boundary Protection ..........................................................................................52
5.10.1.2 Encryption ..........................................................................................................53
5.10.1.3 Intrusion Detection Tools and Techniques ........................................................54
5.10.1.4 Voice over Internet Protocol ..............................................................................55
5.10.1.5 Cloud Computing ...............................................................................................55
5.10.2 Facsimile Transmission of CJI .................................................................................55
5.10.3 Partitioning and Virtualization .................................................................................55
5.10.3.1 Partitioning.........................................................................................................56
5.10.3.2 Virtualization .....................................................................................................56
5.10.4 System and Information Integrity Policy and Procedures ........................................57
5.10.4.1 Patch Management .............................................................................................57
5.10.4.2 Malicious Code Protection .................................................................................57
5.10.4.3 Spam and Spyware Protection ...........................................................................57
5.10.4.4 Security Alerts and Advisories ..........................................................................58
5.10.4.5 Information Input Restrictions ...........................................................................58
5.10.5 References/Citations/Directives ...............................................................................58
5.11 Policy Area 11: Formal Audits ..........................................................................................60
5.11.1 Audits by the FBI CJIS Division..............................................................................60
5.11.1.1 Triennial Compliance Audits by the FBI CJIS Division ...................................60
5.11.1.2 Triennial Security Audits by the FBI CJIS Division .........................................60
5.11.2 Audits by the CSA....................................................................................................60
5.11.3 Special Security Inquiries and Audits ......................................................................61
5.11.4 References/Citations/Directives ...............................................................................61
5.12 Policy Area 12: Personnel Security ...................................................................................62
5.12.1 Personnel Security Policy and Procedures ...............................................................62
5.12.1.1 Minimum Screening Requirements for Individuals Requiring Access to CJI:..62
5.12.1.2 Personnel Screening for Contractors and Vendors ............................................63
5.12.2 Personnel Termination .............................................................................................63
5.12.3 Personnel Transfer ....................................................................................................64
5.12.4 Personnel Sanctions..................................................................................................64
5.12.5 References/Citations/Directives ...............................................................................64
5.13 Policy Area 13: Mobile Devices ........................................................................................65
5.13.1 Wireless Communications Technologies .................................................................65
5.13.1.1 802.11 Wireless Protocols .................................................................................65
5.13.1.2 Cellular Devices .................................................................................................66
5.13.1.2.1 Cellular Service Abroad .............................................................................. 67
5.13.1.2.2 Voice Transmissions Over Cellular Devices .............................................. 67
5.13.1.3 Bluetooth ............................................................................................................67
5.13.1.4 Mobile Hotspots .................................................................................................67
5.13.2 Mobile Device Management (MDM) ......................................................................68
5.13.3 Wireless Device Risk Mitigations ............................................................................68
5.13.4 System Integrity .......................................................................................................69
5.13.4.1 Patching/Updates ...............................................................................................69
5.13.4.2 Malicious Code Protection .................................................................................69
5.13.4.3 Personal Firewall ...............................................................................................69
5.13.5 Incident Response ....................................................................................................70
5.13.6 Access Control .........................................................................................................70
5.13.7 Identification and Authentication .............................................................................70
5.13.7.1 Local Device Authentication .............................................................................70
5.13.7.2 Advanced Authentication...................................................................................70
5.13.7.2.1 Compensating Controls ............................................................................... 71
5.13.7.3 Device Certificates .............................................................................................71
Appendices ................................................................................................................................. A-1
Appendix A Terms and Definitions ...................................................................................... A-1
Appendix B Acronyms ............................................................................................................B-1
Appendix C Network Topology Diagrams ........................................................................... C-1
Appendix D Sample Information Exchange Agreements ................................................... D-1
D.1 CJIS User Agreement ..................................................................................................... D-1
D.2 Management Control Agreement .................................................................................... D-9
D.3 Noncriminal Justice Agency Agreement & Memorandum of Understanding.............. D-10
D.4 Interagency Connection Agreement ............................................................................. D-16
Appendix E Security Forums and Organizational Entities .................................................E-1
Appendix F Sample Forms ..................................................................................................... F-1
F.1 Security Incident Response Form .................................................................................... F-2
Appendix G Best practices ..................................................................................................... G-1
G.1 Virtualization .................................................................................................................. G-1
G.2 Voice over Internet Protocol ........................................................................................... G-4
G.3 Cloud Computing .......................................................................................................... G-15
G.4 Mobile Appendix .......................................................................................................... G-30
G.5 Administrator Accounts for Least Privilege and Separation of Duties ......................... G-51
Appendix H Security Addendum .......................................................................................... H-1
Appendix I References ............................................................................................................I-1
Appendix J Noncriminal Justice Agency Supplemental Guidance ................................... J-1
Appendix K Criminal Justice Agency Supplemental Guidance ........................................ K-1

LIST OF FIGURES
Figure 1 – Overview Diagram of Strategic Functions and Policy Components ..............................4
Figure 2 – Dissemination of restricted and non-restricted NCIC data...........................................13
Figure 3 – Information Exchange Agreements Implemented by a Local Police Department .......19
Figure 4 – Security Awareness Training Use Cases ......................................................................22
Figure 5 – Incident Response Process Initiated by an Incident in a Local Police Department .....26
Figure 6 – Local Police Department's Use of Audit Logs .............................................................29
Figure 7 – A Local Police Department’s Access Controls ............................................................34
Figure 8 – Advanced Authentication Use Cases............................................................................40
Figure 9 – Authentication Decision for Known Location .............................................................44
Figure 10 – Authentication Decision for Unknown Location .......................................................45
Figure 11 – A Local Police Department’s Configuration Management Controls .........................47
Figure 12 – A Local Police Department’s Media Management Policies.......................................49
Figure 13 – A Local Police Department's Physical Protection Measures ......................................51
Figure 14 – System and Communications Protection and Information Integrity Use Cases.........58
Figure 15 – The Audit of a Local Police Department ....................................................................61
Figure 16 – A Local Police Department's Personnel Security Controls ........................................64

1 INTRODUCTION
This section details the purpose of this document, its scope, relationship to other information
security policies, and its distribution constraints.

1.1 Purpose
The CJIS Security Policy provides Criminal Justice Agencies (CJA) and Noncriminal Justice
Agencies (NCJA) with a minimum set of security requirements for access to Federal Bureau of
Investigation (FBI) Criminal Justice Information Services (CJIS) Division systems and
information and to protect and safeguard Criminal Justice Information (CJI). This minimum
standard of security requirements ensures continuity of information protection. The essential
premise of the CJIS Security Policy is to provide the appropriate controls to protect CJI, from
creation through dissemination; whether at rest or in transit.
The CJIS Security Policy integrates presidential directives, federal laws, FBI directives, the
criminal justice community’s Advisory Policy Board (APB) decisions along with nationally
recognized guidance from the National Institute of Standards and Technology (NIST) and the
National Crime Prevention and Privacy Compact Council (Compact Council).

1.2 Scope
At the consent of the advisory process, and taking into consideration federal law and state statutes,
the CJIS Security Policy applies to all entities with access to, or who operate in support of, FBI
CJIS Division’s services and information. The CJIS Security Policy provides minimum security
requirements associated with the creation, viewing, modification, transmission, dissemination,
storage, or destruction of CJI.
Entities engaged in the interstate exchange of CJI data for noncriminal justice purposes are also
governed by the standards and rules promulgated by the Compact Council.

1.3 Relationship to Local Security Policy and Other Policies
The CJIS Security Policy may be used as the sole security policy for the agency. The local agency
may complement the CJIS Security Policy with a local policy, or the agency may develop their
own stand-alone security policy; however, the CJIS Security Policy shall always be the minimum
standard and local policy may augment, or increase the standards, but shall not detract from the
CJIS Security Policy standards.
The agency shall develop, disseminate, and maintain formal, documented procedures to facilitate
the implementation of the CJIS Security Policy and, where applicable, the local security policy.
The policies and procedures shall be consistent with applicable laws, executive orders, directives,
policies, regulations, standards, and guidance. Procedures developed for CJIS Security Policy
areas can be developed for the security program in general, and for a particular information system,
when required.
This document is a compendium of applicable policies in providing guidance on the minimum
security controls and requirements needed to access FBI CJIS information and services. These
policies include presidential directives, federal laws, FBI directives and the criminal justice
community’s APB decisions. State, local, and Tribal CJA may implement more stringent policies
and requirements. Appendix I contains the references while Appendix E lists the security forums
and organizational entities referenced in this document.

1.4 Terminology Used in This Document
The following terms are used interchangeably throughout this document:
Agency and Organization: The two terms in this document refer to any entity that submits
or receives information, by any means, to/from FBI CJIS systems or services.
Information and Data: Both terms refer to CJI.
System, Information System, Service, or named applications like NCIC: all refer to
connections to the FBI’s criminal justice information repositories and the equipment used
to establish said connections.
Appendix A and B provide an extensive list of the terms and acronyms.

1.5 Distribution of the CJIS Security Policy
The CJIS Security Policy, version 5.0 and later, is a publically available document and may be
posted and shared without restrictions.

2 CJIS SECURITY POLICY APPROACH
The CJIS Security Policy represents the shared responsibility between FBI CJIS, CJIS Systems
Agency (CSA), and the State Identification Bureaus (SIB) of the lawful use and appropriate
protection of CJI. The Policy provides a baseline of security requirements for current and planned
services and sets a minimum standard for new initiatives.

2.1 CJIS Security Policy Vision Statement
The executive summary of this document describes the vision in terms of business needs for
confidentiality, integrity, and availability of information. The APB collaborates with the FBI CJIS
Division to ensure that the Policy remains updated to meet evolving business, technology and
security needs.

2.2 Architecture Independent
Due to advancing technology and evolving business models, the FBI CJIS Division is transitioning
from legacy stovepipe systems and moving toward a flexible services approach. Systems such as
National Crime Information Center (NCIC), National Instant Criminal Background Check System
(NICS), and Integrated Automated Fingerprint Identification System (IAFIS) will continue to
evolve and may no longer retain their current system platforms, hardware, or program name.
However, the data and services provided by these systems will remain stable.
The CJIS Security Policy looks at the data (information), services, and protection controls that
apply regardless of the implementation architecture. Architectural independence is not intended
to lessen the importance of systems, but provide for the replacement of one technology with
another while ensuring the controls required to protect the information remain constant. This
objective and conceptual focus on security policy areas provide the guidance and standards while
avoiding the impact of the constantly changing landscape of technical innovations. The
architectural independence of the Policy provides agencies with the flexibility for tuning their
information security infrastructure and policies to reflect their own environments.

2.3 Risk Versus Realism
Every “shall” statement contained within the CJIS Security Policy has been scrutinized for risk
versus the reality of resource constraints and real-world application. The purpose of the CJIS
Security Policy is to establish the minimum security requirements; therefore, individual agencies
are encouraged to implement additional controls to address agency specific risks. Each agency
faces risk unique to that agency. It is quite possible that several agencies could encounter the same
type of risk however depending on resources would mitigate that risk differently. In that light, a
risk-based approach can be used when implementing requirements.

3 ROLES AND RESPONSIBILITIES
3.1 Shared Management Philosophy
In the scope of information security, the FBI CJIS Division employs a shared management
philosophy with federal, state, local, and tribal law enforcement agencies. Although an advisory
policy board for the NCIC has existed since 1969, the Director of the FBI established the CJIS
APB in March 1994 to enable appropriate input and recommend policy with respect to CJIS
services. Through the APB and its Subcommittees and Working Groups, consideration is given
to the needs of the criminal justice and law enforcement community regarding public policy,
statutory and privacy aspects, as well as national security relative to CJIS systems and information.
The APB represents federal, state, local, and tribal law enforcement and criminal justice agencies
throughout the United States, its territories, and Canada.
The FBI has a similar relationship with the Compact Council, which governs the interstate
exchange of criminal history records for noncriminal justice purposes. The Compact Council is
mandated by federal law to promulgate rules and procedures for the use of the Interstate
Identification Index (III) for noncriminal justice purposes. To meet that responsibility, the
Compact Council depends on the CJIS Security Policy as the definitive source for standards
defining the security and privacy of records exchanged with noncriminal justice practitioners.

3.2 Roles and Responsibilities for Agencies and Parties
It is the responsibility of all agencies covered under this Policy to ensure the protection of CJI
between the FBI CJIS Division and its user community. The following figure provides an abstract
representation of the strategic functions and roles such as governance and operations.

Governance

Operations

Policy Structure/Design

CJIS Advisory Policy
Board

CSA Information
Security Officers

Laws and Directives

CJIS Systems Officers

CJIS Systems Agencies

Security Policy and
Implementation Standards

CJIS Working Groups

CJIS Subcommittees
FBI CJIS Information
Security Officer
FBI Director

Compact Officers
Local Agency Security
Officers

Security Standards: National
Institute of Standards and
Technology, International
Standards Organization,
Institute of Electrical and
Electronics Engineers

Repository Managers
Terminal Agency
Coordinators

Figure 1 – Overview Diagram of Strategic Functions and Policy Components

This section provides a description of the following entities and roles:
1. CJIS Systems Agency.
2. CJIS Systems Officer.
3. Terminal Agency Coordinator.
4. Criminal Justice Agency.
5. Noncriminal Justice Agency.
6. Contracting Government Agency.
7. Agency Coordinator.
8. CJIS Systems Agency Information Security Officer.
9. Local Agency Security Officer.
10. FBI CJIS Division Information Security Officer.
11. Repository Manager.
12. Compact Officer.
3.2.1 CJIS Systems Agencies (CSA)
The CSA is responsible for establishing and administering an information technology security
program throughout the CSA’s user community, to include the local levels. The head of each CSA
shall appoint a CJIS Systems Officer (CSO). The CSA may impose more stringent protection
measures than outlined in this document. Such decisions shall be documented and kept current.
3.2.2 CJIS Systems Officer (CSO)
The CSO is an individual located within the CSA responsible for the administration of the CJIS
network for the CSA. Pursuant to the Bylaws for the CJIS Advisory Policy Board and Working
Groups, the role of CSO shall not be outsourced. The CSO may delegate responsibilities to
subordinate agencies. The CSO shall set, maintain, and enforce the following:
1. Standards for the selection, supervision, and separation of personnel who have access to
CJI.
2. Policy governing the operation of computers, access devices, circuits, hubs, routers,
firewalls, and other components that comprise and support a telecommunications network
and related CJIS systems used to process, store, or transmit CJI, guaranteeing the priority,
confidentiality, integrity, and availability of service needed by the criminal justice
community.
a. Ensure appropriate use, enforce system discipline, and ensure CJIS Division
operating procedures are followed by all users of the respective services and
information.
b. Ensure state/federal agency compliance with policies approved by the APB and
adopted by the FBI.

c. Ensure the appointment of the CSA ISO and determine the extent of authority to
the CSA ISO.
d. The CSO, or designee, shall ensure that a Terminal Agency Coordinator (TAC) is
designated within each agency that has devices accessing CJIS systems.
e. Ensure each agency having access to CJI has someone designated as the Local
Agency Security Officer (LASO).
f. Approve access to FBI CJIS systems.
g. Assume ultimate responsibility for managing the security of CJIS systems within
their state and/or agency.
h. Perform other related duties outlined by the user agreements with the FBI CJIS
Division.
3. Outsourcing of Criminal Justice Functions
a. Responsibility for the management of the approved security requirements shall
remain with the CJA. Security control includes the authority to enforce the
standards for the selection, supervision, and separation of personnel who have
access to CJI; set and enforce policy governing the operation of computers, circuits,
and telecommunications terminals used to process, store, or transmit CJI; and to
guarantee the priority service needed by the criminal justice community.
b. Responsibility for the management control of network security shall remain with
the CJA. Management control of network security includes the authority to enforce
the standards for the selection, supervision, and separation of personnel who have
access to CJI; set and enforce policy governing the operation of circuits and
network equipment used to transmit CJI; and to guarantee the priority service as
determined by the criminal justice community.
3.2.3 Terminal Agency Coordinator (TAC)
The TAC serves as the point-of-contact at the local agency for matters relating to CJIS information
access. The TAC administers CJIS systems programs within the local agency and oversees the
agency’s compliance with CJIS systems policies.
3.2.4 Criminal Justice Agency (CJA)
A CJA is defined as a court, a governmental agency, or any subunit of a governmental agency
which performs the administration of criminal justice pursuant to a statute or executive order and
which allocates a substantial part of its annual budget to the administration of criminal justice.
State and federal Inspectors General Offices are included.
3.2.5 Noncriminal Justice Agency (NCJA)
A NCJA is defined (for the purposes of access to CJI) as an entity or any subunit thereof that
provides services primarily for purposes other than the administration of criminal justice.

3.2.6 Contracting Government Agency (CGA)
A CGA is a government agency, whether a CJA or a NCJA, that enters into an agreement with a
private contractor subject to the CJIS Security Addendum. The CGA entering into an agreement
with a contractor shall appoint an agency coordinator.
3.2.7 Agency Coordinator (AC)
An AC is a staff member of the CGA who manages the agreement between the Contractor and
agency. The AC shall be responsible for the supervision and integrity of the system, training and
continuing education of employees and operators, scheduling of initial training and testing, and
certification testing and all required reports by NCIC. The AC shall:
1. Understand the communications, records capabilities, and needs of the Contractor which
is accessing federal and state records through or because of its relationship with the CGA.
2. Participate in related meetings and provide input and comments for system improvement.
3. Receive information from the CGA (e.g., system updates) and disseminate it to appropriate
Contractor employees.
4. Maintain and update manuals applicable to the effectuation of the agreement, and provide
them to the Contractor.
5. Maintain up-to-date records of Contractor’s employees who access the system, including
name, date of birth, social security number, date fingerprint card(s) submitted, date security
clearance issued, and date initially trained, tested, certified or recertified (if applicable).
6. Train or ensure the training of Contractor personnel. If Contractor personnel access NCIC,
schedule the operators for testing or a certification exam with the CSA staff, or AC staff
with permission from the CSA staff. Schedule new operators for the certification exam
within six (6) months of assignment. Schedule certified operators for biennial recertification testing within thirty (30) days prior to the expiration of certification. Schedule
operators for other mandated class.
7. The AC will not permit an untrained/untested or non-certified Contractor employee to
access CJI or systems supporting CJI where access to CJI can be gained.
8. Where appropriate, ensure compliance by the Contractor with NCIC validation
requirements.
9. Provide completed applicant fingerprint cards on each Contractor employee who accesses
the system to the CGA (or, where appropriate, CSA) for criminal background investigation
prior to such employee accessing the system.
10. Any other responsibility for the AC promulgated by the FBI.
3.2.8 CJIS Systems Agency Information Security Officer (CSA ISO)
The CSA ISO shall:
1. Serve as the security point of contact (POC) to the FBI CJIS Division ISO.

2. Document technical compliance with the CJIS Security Policy with the goal to assure the
confidentiality, integrity, and availability of criminal justice information to the user
community throughout the CSA’s user community, to include the local level.
3. Document and provide assistance for implementing the security-related controls for the
Interface Agency and its users.
4. Establish a security incident response and reporting procedure to discover, investigate,
document, and report to the CSA, the affected criminal justice agency, and the FBI CJIS
Division ISO major incidents that significantly endanger the security or integrity of CJI.
3.2.9 Local Agency Security Officer (LASO)
Each LASO shall:
1. Identify who is using the CSA approved hardware, software, and firmware and ensure no
unauthorized individuals or processes have access to the same.
2. Identify and document how the equipment is connected to the state system.
3. Ensure that personnel security screening procedures are being followed as stated in this
Policy.
4. Ensure the approved and appropriate security measures are in place and working as
expected.
5. Support policy compliance and ensure the CSA ISO is promptly informed of security
incidents.
3.2.10 FBI CJIS Division Information Security Officer (FBI CJIS ISO)
The FBI CJIS ISO shall:
1. Maintain the CJIS Security Policy.
2. Disseminate the FBI Director approved CJIS Security Policy.
3. Serve as a liaison with the CSA’s ISO and with other personnel across the CJIS community
and in this regard provide technical guidance as to the intent and implementation of
operational and technical policy issues.
4. Serve as a point-of-contact (POC) for computer incident notification and distribution of
security alerts to the CSOs and ISOs.
5. Assist with developing audit compliance guidelines as well as identifying and reconciling
security-related issues.
6. Develop and participate in information security training programs for the CSOs and ISOs,
and provide a means by which to acquire feedback to measure the effectiveness and success
of such training.
7. Maintain a security policy resource center (SPRC) on FBI.gov and keep the CSOs and
ISOs updated on pertinent information.

3.2.11 Repository Manager
The State Identification Bureau (SIB) Chief, i.e. Repository Manager or Chief Administrator, is
the designated manager of the agency having oversight responsibility for a state’s fingerprint
identification services. If both state fingerprint identification services and CJIS systems control
are managed within the same state agency, the SIB Chief and CSO may be the same person.
3.2.12 Compact Officer
Pursuant to the National Crime Prevention and Privacy Compact, each party state shall appoint a
Compact Officer who shall ensure that Compact provisions and rules, procedures, and standards
established by the Compact Council are complied with in their respective state.

4 CRIMINAL JUSTICE INFORMATION AND PERSONALLY
IDENTIFIABLE INFORMATION
4.1 Criminal Justice Information (CJI)
Criminal Justice Information is the term used to refer to all of the FBI CJIS provided data necessary
for law enforcement and civil agencies to perform their missions including, but not limited to
biometric, identity history, biographic, property, and case/incident history data. The following
categories of CJI describe the various data sets housed by the FBI CJIS architecture:
1. Biometric Data—data derived from one or more intrinsic physical or behavioral traits of
humans typically for the purpose of uniquely identifying individuals from within a
population. Used to identify individuals, to include: fingerprints, palm prints, iris scans,
and facial recognition data.
2. Identity History Data—textual data that corresponds with an individual’s biometric data,
providing a history of criminal and/or civil events for the identified individual.
3. Biographic Data—information about individuals associated with a unique case, and not
necessarily connected to identity data. Biographic data does not provide a history of an
individual, only information related to a unique case.
4. Property Data—information about vehicles and property associated with crime when
accompanied by any personally identifiable information (PII).
5. Case/Incident History—information about the history of criminal incidents.
The following type of data are exempt from the protection levels required for CJI: transaction
control type numbers (e.g., ORI, NIC, FNU, etc.) when not accompanied by information that
reveals CJI or PII.
The intent of the CJIS Security Policy is to ensure the protection of the aforementioned CJI until
the information is: released to the public via authorized dissemination (e.g. within a court system;
presented in crime reports data; released in the interest of public safety); purged or destroyed in
accordance with applicable record retention rules.
4.1.1 Criminal History Record Information (CHRI)
Criminal History Record Information (CHRI), sometimes informally referred to as “restricted
data”, is a subset of CJI. Due to its comparatively sensitive nature, additional controls are required
for the access, use and dissemination of CHRI. In addition to the dissemination restrictions
outlined below, Title 28, Part 20, Code of Federal Regulations (CFR), defines CHRI and provides
the regulatory guidance for dissemination of CHRI. While the CJIS Security Policy attempts to
be architecturally independent, the III and the NCIC are specifically identified in Title 28, Part 20,
CFR, and the NCIC Operating Manual, as associated with CHRI.

4.2 Access, Use and Dissemination of Criminal History Record
Information (CHRI), NCIC Restricted Files Information, and
NCIC Non-Restricted Files Information
This section describes the requirements for the access, use and dissemination of CHRI, NCIC
restricted files information, and NCIC non-restricted files information.
4.2.1 Proper Access, Use, and Dissemination of CHRI
Information obtained from the III is considered CHRI. Rules governing the access, use, and
dissemination of CHRI are found in Title 28, Part 20, CFR. The III shall be accessed only for an
authorized purpose. Further, CHRI shall only be used for an authorized purpose consistent with
the purpose for which III was accessed. Dissemination to another agency is authorized if (a) the
other agency is an Authorized Recipient of such information and is being serviced by the accessing
agency, or (b) the other agency is performing personnel and appointment functions for criminal
justice employment applicants.
4.2.2 Proper Access, Use, and Dissemination of NCIC Restricted Files
Information
The NCIC hosts restricted files and non-restricted files. NCIC restricted files are distinguished
from NCIC non-restricted files by the policies governing their access and use. Proper access to,
use, and dissemination of data from restricted files shall be consistent with the access, use, and
dissemination policies concerning the III described in Title 28, Part 20, CFR, and the NCIC
Operating Manual. The restricted files, which shall be protected as CHRI, are as follows:
1. Gang Files
2. Known or Appropriately Suspected Terrorist Files
3. Supervised Release Files
4. National Sex Offender Registry Files
5. Historical Protection Order Files of the NCIC
6. Identity Theft Files
7. Protective Interest Files
8. Person With Information (PWI) data in the Missing Person Files
9. Violent Person File
10. NICS Denied Transactions File
The remaining NCIC files are considered non-restricted files.
4.2.3 Proper Access, Use, and Dissemination of NCIC Non-Restricted Files
Information
4.2.3.1 For Official Purposes

NCIC non-restricted files are those not listed as restricted files in Section 4.2.2. NCIC nonrestricted files information may be accessed and used for any authorized purpose consistent with
the inquiring agency’s responsibility. Information obtained may be disseminated to (a) other
government agencies or (b) private entities authorized by law to receive such information for any
purpose consistent with their responsibilities.
4.2.3.2 For Other Authorized Purposes

NCIC non-restricted files may be accessed for other purposes consistent with the resources of the
inquiring agency; however, requests for bulk data are discouraged. Information derived from
NCIC non-restricted files for other than law enforcement purposes can be used by authorized
criminal justice personnel only to confirm the status of a person or property (i.e., wanted or stolen).
An inquiring agency is authorized to charge a nominal administrative fee for such service. Nonrestricted files information shall not be disseminated commercially.
A response to a NCIC person inquiry may include NCIC restricted files information as well as
NCIC non-restricted files information. Agencies shall not disseminate restricted files information
for purposes other than law enforcement.
4.2.3.3 CSO Authority in Other Circumstances

If no federal, state or local law or policy prohibition exists, the CSO may exercise discretion to
approve or deny dissemination of NCIC non-restricted file information.
4.2.4 Storage
When CHRI is stored, agencies shall establish appropriate administrative, technical and physical
safeguards to ensure the security and confidentiality of the information. These records shall be
stored for extended periods only when they are key elements for the integrity and/or utility of case
files and/or criminal record files. See Section 5.9 for physical security controls.
4.2.5 Justification and Penalties
4.2.5.1 Justification

In addition to the use of purpose codes and logging information, all users shall provide a reason
for all III inquiries whenever requested by NCIC System Managers, CSAs, local agency
administrators, or their representatives.
4.2.5.2 Penalties

Improper access, use or dissemination of CHRI and NCIC Non-Restricted Files information is
serious and may result in administrative sanctions including, but not limited to, termination of
services and state and federal criminal penalties.

4.3 Personally Identifiable Information (PII)
For the purposes of this document, PII is information which can be used to distinguish or trace an
individual’s identity, such as name, social security number, or biometric records, alone or when
combined with other personal or identifying information which is linked or linkable to a specific
individual, such as date and place of birth, or mother’s maiden name. Any FBI CJIS provided data
maintained by an agency, including but not limited to, education, financial transactions, medical
history, and criminal or employment history may include PII. A criminal history record for

example inherently contains PII as would a Law Enforcement National Data Exchange (N-DEx)
case file.
PII shall be extracted from CJI for the purpose of official business only. Agencies shall develop
policies, based on state and local privacy rules, to ensure appropriate controls are applied when
handling PII extracted from CJI. Due to the expansive nature of PII, this Policy does not specify
auditing, logging, or personnel security requirements associated with the life cycle of PII.
Figure 2 – Dissemination of restricted and non-restricted NCIC data
A citizen of Springfield went to the Springfield Police Department to request whether his new
neighbor, who had been acting suspiciously, had an outstanding warrant. The Springfield Police
Department ran an NCIC persons inquiry, which produced a response that included a Wanted
Person File (non-restricted file) record and a Known or Appropriately Suspected Terrorist File
(restricted file) record. The Springfield Police Department advised the citizen of the
outstanding warrant, but did not disclose any information concerning the subject being a known
or appropriately suspected terrorist.

5 POLICY AND IMPLEMENTATION
The policy areas focus upon the data and services that the FBI CJIS Division exchanges and
provides to the criminal justice community and its partners. Each policy area provides both
strategic reasoning and tactical implementation requirements and standards.
While the major theme of the policy areas is concerned with electronic exchange directly with the
FBI, it is understood that further dissemination of CJI to Authorized Recipients by various means
(hard copy, e-mail, web posting, etc.) constitutes a significant portion of CJI exchanges.
Regardless of its form, use, or method of dissemination, CJI requires protection throughout its life.
Not every consumer of FBI CJIS services will encounter all of the policy areas therefore the
circumstances of applicability are based on individual agency/entity configurations and usage. Use
cases within each of the policy areas will help users relate the Policy to their own agency
circumstances. The policy areas are:
Policy Area 1—Information Exchange Agreements
Policy Area 2—Security Awareness Training
Policy Area 3—Incident Response
Policy Area 4—Auditing and Accountability
Policy Area 5—Access Control
Policy Area 6—Identification and Authentication
Policy Area 7—Configuration Management
Policy Area 8—Media Protection
Policy Area 9—Physical Protection
Policy Area 10—Systems and Communications Protection and Information Integrity
Policy Area 11—Formal Audits
Policy Area 12—Personnel Security
Policy Area 13—Mobile Devices

5.1 Policy Area 1: Information Exchange Agreements
The information shared through communication mediums shall be protected with appropriate
security safeguards. The agreements established by entities sharing information across systems
and communications mediums are vital to ensuring all parties fully understand and agree to a set
of security standards.
5.1.1 Information Exchange
Before exchanging CJI, agencies shall put formal agreements in place that specify security
controls. The exchange of information may take several forms including electronic mail, instant
messages, web services, facsimile, hard copy, and information systems sending, receiving and
storing CJI.
Information exchange agreements outline the roles, responsibilities, and data ownership between
agencies and any external parties. Information exchange agreements for agencies sharing CJI data
that is sent to and/or received from the FBI CJIS shall specify the security controls and conditions
described in this document.
Information exchange agreements shall be supported by documentation committing both parties
to the terms of information exchange. As described in subsequent sections, different agreements
and policies apply, depending on whether the parties involved are CJAs or NCJAs. See Appendix
D for examples of Information Exchange Agreements.
There may be instances, on an ad-hoc basis, where CJI is authorized for further dissemination to
Authorized Recipients not covered by an information exchange agreement with the releasing
agency. In these instances the dissemination of CJI is considered to be secondary dissemination.
Law Enforcement and civil agencies shall have a local policy to validate a requestor of CJI as an
authorized recipient before disseminating CJI. See Section 5.1.3 for secondary dissemination
guidance.
5.1.1.1 Information Handling

Procedures for handling and storage of information shall be established to protect that information
from unauthorized disclosure, alteration or misuse. Using the requirements in this Policy as a
starting point, the procedures shall apply to the handling, processing, storing, and communication
of CJI. These procedures apply to the exchange of CJI no matter the form of exchange.
The policies for information handling and protection also apply to using CJI shared with or
received from FBI CJIS for noncriminal justice purposes. In general, a noncriminal justice purpose
includes the use of criminal history records for purposes authorized by federal or state law other
than purposes relating to the administration of criminal justice, including – but not limited to employment suitability, licensing determinations, immigration and naturalization matters, and
national security clearances.
5.1.1.2 State and Federal Agency User Agreements

Each CSA head or SIB Chief shall execute a signed written user agreement with the FBI CJIS
Division stating their willingness to demonstrate conformity with this Policy before accessing and
participating in CJIS records information programs. This agreement shall include the standards
and sanctions governing utilization of CJIS systems. As coordinated through the particular CSA
or SIB Chief, each Interface Agency shall also allow the FBI to periodically test the ability to
penetrate the FBI’s network through the external network connection or system per authorization
of Department of Justice (DOJ) Order 2640.2F. All user agreements with the FBI CJIS Division
shall be coordinated with the CSA head.
5.1.1.3 Criminal Justice Agency User Agreements

Any CJA receiving access to CJI shall enter into a signed written agreement with the appropriate
signatory authority of the CSA providing the access. The written agreement shall specify the FBI
CJIS systems and services to which the agency will have access, and the FBI CJIS Division
policies to which the agency must adhere. These agreements shall include:
1. Audit.
2. Dissemination.
3. Hit confirmation.
4. Logging.
5. Quality Assurance (QA).
6. Screening (Pre-Employment).
7. Security.
8. Timeliness.
9. Training.
10. Use of the system.
11. Validation.
5.1.1.4 Interagency and Management Control Agreements

A NCJA (government) designated to perform criminal justice functions for a CJA shall be eligible
for access to the CJI. Access shall be permitted when such designation is authorized pursuant to
executive order, statute, regulation, or inter-agency agreement. The NCJA shall sign and execute
a management control agreement (MCA) with the CJA, which stipulates management control of
the criminal justice function remains solely with the CJA. The MCA may be a separate document
or included with the language of an inter-agency agreement. An example of an NCJA
(government) is a city information technology (IT) department.
5.1.1.5 Private Contractor User Agreements and CJIS Security Addendum

The CJIS Security Addendum is a uniform addendum to an agreement between the government
agency and a private contractor, approved by the Attorney General of the United States, which
specifically authorizes access to CHRI, limits the use of the information to the purposes for which
it is provided, ensures the security and confidentiality of the information is consistent with existing
regulations and the CJIS Security Policy, provides for sanctions, and contains such other
provisions as the Attorney General may require.
Private contractors who perform criminal justice functions shall meet the same training and
certification criteria required by governmental agencies performing a similar function, and shall
be subject to the same extent of audit review as are local user agencies. All private contractors
who perform criminal justice functions shall acknowledge, via signing of the CJIS Security
Addendum Certification page, and abide by all aspects of the CJIS Security Addendum. The CJIS
Security Addendum is presented in Appendix H. Modifications to the CJIS Security Addendum
shall be enacted only by the FBI.
1. Private contractors designated to perform criminal justice functions for a CJA shall be
eligible for access to CJI. Access shall be permitted pursuant to an agreement which
specifically identifies the agency’s purpose and scope of providing services for the
administration of criminal justice. The agreement between the CJA and the private
contractor shall incorporate the CJIS Security Addendum approved by the Director of the
FBI, acting for the U.S. Attorney General, as referenced in Title 28 CFR 20.33 (a)(7).
2. Private contractors designated to perform criminal justice functions on behalf of a NCJA
(government) shall be eligible for access to CJI. Access shall be permitted pursuant to an
agreement which specifically identifies the agency’s purpose and scope of providing
services for the administration of criminal justice. The agreement between the NCJA and
the private contractor shall incorporate the CJIS Security Addendum approved by the
Director of the FBI, acting for the U.S. Attorney General, as referenced in Title 28 CFR
20.33 (a)(7).
5.1.1.6 Agency User Agreements

A NCJA (public) designated to request civil fingerprint-based background checks, with the full
consent of the individual to whom a background check is taking place, for noncriminal justice
functions, shall be eligible for access to CJI. Access shall be permitted when such designation is
authorized pursuant to federal law or state statute approved by the U.S. Attorney General. A NCJA
(public) receiving access to CJI shall enter into a signed written agreement with the appropriate
signatory authority of the CSA/SIB providing the access. An example of a NCJA (public) is a
county school board.
A NCJA (private) designated to request civil fingerprint-based background checks, with the full
consent of the individual to whom a background check is taking place, for noncriminal justice
functions, shall be eligible for access to CJI. Access shall be permitted when such designation is
authorized pursuant to federal law or state statute approved by the U.S. Attorney General. A NCJA
(private) receiving access to CJI shall enter into a signed written agreement with the appropriate
signatory authority of the CSA, SIB, or authorized agency providing the access. An example of a
NCJA (private) is a local bank.
All NCJAs accessing CJI shall be subject to all pertinent areas of the CJIS Security Policy (see
Appendix J for supplemental guidance). Each NCJA that directly accesses FBI CJI shall also
allow the FBI to periodically test the ability to penetrate the FBI’s network through the external
network connection or system per authorization of Department of Justice (DOJ) Order 2640.2F.
5.1.1.7 Outsourcing Standards for Channelers

Channelers designated to request civil fingerprint-based background checks or noncriminal justice
ancillary functions on behalf of a NCJA (public) or NCJA (private) for noncriminal justice
functions shall be eligible for access to CJI. Access shall be permitted when such designation is
authorized pursuant to federal law or state statute approved by the U.S. Attorney General. All
Channelers accessing CJI shall be subject to the terms and conditions described in the Compact
Council Security and Management Control Outsourcing Standard. Each Channeler that directly
accesses CJI shall also allow the FBI to conduct periodic penetration testing.
Channelers leveraging CJI to perform civil functions on behalf of an Authorized Recipient shall
meet the same training and certification criteria required by governmental agencies performing a
similar function, and shall be subject to the same extent of audit review as are local user agencies.
5.1.1.8 Outsourcing Standards for Non-Channelers

Contractors designated to perform noncriminal justice ancillary functions on behalf of a NCJA
(public) or NCJA (private) for noncriminal justice functions shall be eligible for access to CJI.
Access shall be permitted when such designation is authorized pursuant to federal law or state
statute approved by the U.S. Attorney General. All contractors accessing CJI shall be subject to
the terms and conditions described in the Compact Council Outsourcing Standard for NonChannelers. Contractors leveraging CJI to perform civil functions on behalf of an Authorized
Recipient shall meet the same training and certification criteria required by governmental agencies
performing a similar function, and shall be subject to the same extent of audit review as are local
user agencies.
5.1.2 Monitoring, Review, and Delivery of Services
As specified in the inter-agency agreements, MCAs, and contractual agreements with private
contractors, the services, reports and records provided by the service provider shall be regularly
monitored and reviewed. The CJA, authorized agency, or FBI shall maintain sufficient overall
control and visibility into all security aspects to include, but not limited to, identification of
vulnerabilities and information security incident reporting/response.
The incident
reporting/response process used by the service provider shall conform to the incident
reporting/response specifications provided in this Policy.
5.1.2.1 Managing Changes to Service Providers

Any changes to services provided by a service provider shall be managed by the CJA, authorized
agency, or FBI. This includes provision of services, changes to existing services, and new services.
Evaluation of the risks to the agency shall be undertaken based on the criticality of the data, system,
and the impact of the change.
5.1.3 Secondary Dissemination
If CHRI is released to another authorized agency, and that agency was not part of the releasing
agency’s primary information exchange agreement(s), the releasing agency shall log such
dissemination.
5.1.4 Secondary Dissemination of Non-CHRI CJI
If CJI does not contain CHRI and is not part of an information exchange agreement then it does
not need to be logged. Dissemination shall conform to the local policy validating the requestor of
the CJI as an employee and/or contractor of a law enforcement agency or civil agency requiring
the CJI to perform their mission or a member of the public receiving CJI via authorized
dissemination.

5.1.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 3 – Information Exchange Agreements Implemented by a Local Police Department
A local police department executed a Memorandum of Understanding (MOU) for the interface
with their state CSA. The local police department also executed an MOU (which included an
MCA) with the county information technology (IT) department for the day-to-day operations of
their criminal-justice infrastructure. The county IT department, in turn, outsourced operations
to a local vendor who signed the CJIS Security Addendum.

5.2 Policy Area 2: Security Awareness Training
Basic security awareness training shall be required within six months of initial assignment, and
biennially thereafter, for all personnel who have access to CJI to include all personnel who have
unescorted access to a physically secure location. The CSO/SIB Chief may accept the
documentation of the completion of security awareness training from another agency. Accepting
such documentation from another agency means that the accepting agency assumes the risk that
the training may not meet a particular requirement or process required by federal, state, or local
laws.
5.2.1 Awareness Topics
A significant number of topics can be mentioned and briefly discussed in any awareness session
or campaign. To help further the development and implementation of individual agency security
awareness training programs the following baseline guidance is provided.
5.2.1.1 Level One Security Awareness Training

At a minimum, the following topics shall be addressed as baseline security awareness training for
all personnel who have unescorted access to a physically secure location:
1. Individual responsibilities and expected behavior with regard to being in the vicinity of CJI
usage and/or terminals.
2. Implications of noncompliance.
3. Incident response (Identify points of contact and individual actions).
4. Visitor control and physical access to spaces—discuss applicable physical security policy
and procedures, e.g., challenge strangers, report unusual activity, etc.
5.2.1.2 Level Two Security Awareness Training

In addition to 5.2.1.1 above, the following topics, at a minimum, shall be addressed as baseline
security awareness training for all authorized personnel with access to CJI:
1. Media protection.
2. Protect information subject to confidentiality concerns — hardcopy through destruction.
3. Proper handling and marking of CJI.
4. Threats, vulnerabilities, and risks associated with handling of CJI.
5. Social engineering.
6. Dissemination and destruction.
5.2.1.3 Level Three Security Awareness Training

In addition to 5.2.1.1 and 5.2.1.2 above, the following topics, at a minimum, shall be addressed as
baseline security awareness training for all authorized personnel with both physical and logical
access to CJI:
1. Rules that describe responsibilities and expected behavior with regard to information
system usage.
2. Password usage and management—including creation, frequency of changes, and
protection.
3. Protection from viruses, worms, Trojan horses, and other malicious code.
4. Unknown e-mail/attachments.
5. Web usage—allowed versus prohibited; monitoring of user activity.
6. Spam.
7. Physical Security—increases in risks to systems and data.
8. Handheld device security issues—address both physical and wireless security issues.
9. Use of encryption and the transmission of sensitive/confidential information over the
Internet—address agency policy, procedures, and technical contact for assistance.
10. Laptop security—address both physical and information security issues.
11. Personally owned equipment and software—state whether allowed or not (e.g.,
copyrights).
12. Access control issues—address least privilege and separation of duties.
13. Individual accountability—explain what this means in the agency.
14. Use of acknowledgement statements—passwords, access to systems and data, personal use
and gain.
15. Desktop security—discuss use of screensavers, restricting visitors’ view of information on
screen (mitigating “shoulder surfing”), battery backup devices, allowed access to systems.
16. Protect information subject to confidentiality concerns—in systems, archived, on backup
media, and until destroyed.
17. Threats, vulnerabilities, and risks associated with accessing CJIS Service systems and
services.
5.2.1.4 Level Four Security Awareness Training

In addition to 5.2.1.1, 5.2.1.2, and 5.1.2.3 above, the following topics at a minimum shall be
addressed as baseline security awareness training for all Information Technology personnel
(system administrators, security administrators, network administrators, etc.):
1. Protection from viruses, worms, Trojan horses, and other malicious code—scanning,
updating definitions.
2. Data backup and storage—centralized or decentralized approach.
3. Timely application of system patches—part of configuration management.
4. Access control measures.
5. Network infrastructure protection measures.

5.2.2 Security Training Records
Records of individual basic security awareness training and specific information system security
training shall be documented, kept current, and maintained by the CSO/SIB Chief/Compact
Officer. Maintenance of training records can be delegated to the local level.
5.2.3 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 4 – Security Awareness Training Use Cases
Use Case 1 - Security Awareness Training Program Implementation by a Local Police
Department

A local police department with a staff of 20 sworn criminal justice professionals and 15 support
personnel worked with a vendor to develop role-specific security-awareness training, and
required all staff to complete this training upon assignment and every two years thereafter. The
local police department scheduled the sworn law-enforcement training to coincide with their
NCIC certification training. The vendor maintained the training records for the police
department’s entire staff, and provided reporting to the department to help it ensure compliance
with the CJIS Security Policy.
Use Case 2 - Level One Security Awareness Training
A local police department hires custodial staff that will have physical access throughout the PD
(a physically secure location) after normal business hours to clean the facility. These personnel
have unescorted access to a physically secure location and therefore must be given the baseline
security awareness training on all the topics identified in CSP Section 5.2.1.1 Level One
Security Awareness Training.
Use Case 3 – Level Two Security Awareness Training
A school district maintains a locked file cabinet with hard copies of background check results of
all teachers and employees which may include CJI (CHRI). Only authorized personnel who have
the ability to open the cabinet are required to be given the baseline security awareness training
on all the topics identified in CSP Sections 5.2.1.1 and 5.2.1.2.
Use Case 4 – Level Three Security Awareness Training
A County Sheriff’s Office has employed a number of dispatchers. Part of the function of these
dispatchers is to run CJI queries at the request of the Sheriff and deputies. As part of their daily
duties, the dispatchers have access to CJI both logically (running queries) and physically
(printed copies of reports containing CJI). These dispatchers are entrusted with direct access to
CJI and are therefore required to be given the baseline security awareness training on all the
topics identified in CSP Sections 5.2.1.1, 5.2.1.2, and 5.2.1.3.
Use Case 5 – Level Four Security Awareness Training
The State Police has hired a number of system and network administrator personnel to help
bolster security of the state network. Part of their daily duties may include creating accounts for
new personnel, implementing security patches for existing systems, creating backups of existing
systems, and implementing access controls throughout the network. These administrators have
privileged access to CJI and CJI-processing systems, and are therefore required to be given the
baseline security awareness training on all the topics identified in CSP Sections 5.2.1.1, 5.2.1.2,
5.2.1.3, and 5.2.1.4.

5.3 Policy Area 3: Incident Response
The security risk of both accidental and malicious attacks against government and private agencies,
remains persistent in both physical and logical environments. To ensure protection of CJI, agencies
shall: (i) establish operational incident handling procedures that include adequate preparation,
detection, analysis, containment, recovery, and user response activities; (ii) track, document, and
report incidents to appropriate agency officials and/or authorities.
ISOs have been identified as the POC on security-related issues for their respective agencies and
shall ensure LASOs institute the CSA incident response reporting procedures at the local level.
Appendix F contains a sample incident notification letter for use when communicating the details
of a CJI-related incident to the FBI CJIS ISO.
Refer to Section 5.13.5 for additional incident response requirements related to mobile devices
used to access CJI.
5.3.1 Reporting Security Events
The agency shall promptly report incident information to appropriate authorities. Security events,
including identified weaknesses associated with the event, shall be communicated in a manner
allowing timely corrective action to be taken. Formal event reporting and escalation procedures
shall be in place. Wherever feasible, the agency shall employ automated mechanisms to assist in
the reporting of security incidents. All employees, contractors and third party users shall be made
aware of the procedures for reporting the different types of event and weakness that might have an
impact on the security of agency assets and are required to report any security events and
weaknesses as quickly as possible to the designated point of contact.
5.3.1.1 Reporting Structure and Responsibilities
5.3.1.1.1 FBI CJIS Division Responsibilities

The FBI CJIS Division shall:
1. Manage and maintain the CJIS Division's Computer Security Incident Response Capability
(CSIRC).
2. Serve as a central clearinghouse for all reported intrusion incidents, security alerts,
bulletins, and other security-related material.
3. Ensure additional resources for all incidents affecting FBI CJIS Division controlled
systems as needed.
4. Disseminate prompt advisories of system threats and operating system vulnerabilities via
the security policy resource center on FBI.gov, to include but not limited to: Product
Security Bulletins, Virus Bulletins, and Security Clips.
5. Track all reported incidents and/or trends.
6. Monitor the resolution of all incidents.
5.3.1.1.2 CSA ISO Responsibilities

The CSA ISO shall:

1. Assign individuals in each state, federal, and international law enforcement organization
to be the primary point of contact for interfacing with the FBI CJIS Division concerning
incident handling and response.
2. Identify individuals who are responsible for reporting incidents within their area of
responsibility.
3. Collect incident information from those individuals for coordination and sharing among
other organizations that may or may not be affected by the incident.
4. Develop, implement, and maintain internal incident response procedures and coordinate
those procedures with other organizations that may or may not be affected.
5. Collect and disseminate all incident-related information received from the Department of
Justice (DOJ), FBI CJIS Division, and other entities to the appropriate local law
enforcement POCs within their area.
6. Act as a single POC for their jurisdictional area for requesting incident response assistance.
5.3.2 Management of Security Incidents
A consistent and effective approach shall be applied to the management of security incidents.
Responsibilities and procedures shall be in place to handle security events and weaknesses
effectively once they have been reported.
5.3.2.1 Incident Handling

The agency shall implement an incident handling capability for security incidents that includes
preparation, detection and analysis, containment, eradication, and recovery. Wherever feasible,
the agency shall employ automated mechanisms to support the incident handling process.
Incident-related information can be obtained from a variety of sources including, but not limited
to, audit monitoring, network monitoring, physical access monitoring, and user/administrator
reports. The agency should incorporate the lessons learned from ongoing incident handling
activities into the incident response procedures and implement the procedures accordingly.
5.3.2.2 Collection of Evidence

Where a follow-up action against a person or agency after an information security incident involves
legal action (either civil or criminal), evidence shall be collected, retained, and presented to
conform to the rules for evidence laid down in the relevant jurisdiction(s).
5.3.3 Incident Response Training
The agency shall ensure general incident response roles responsibilities are included as part of
required security awareness training.
5.3.4 Incident Monitoring
The agency shall track and document security incidents on an ongoing basis. The CSA ISO shall
maintain completed security incident reporting forms until the subsequent FBI triennial audit or
until legal action (if warranted) is complete; whichever time-frame is greater.

5.3.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 5 – Incident Response Process Initiated by an Incident in a Local Police Department
A state ISO received a notification from a local police department that suspicious network
activity from a known botnet was detected on their network. The state ISO began the process
of collecting all pertinent information about this incident, e.g. incident date/time, points-ofcontact, systems affected, nature of the incident, actions taken, etc. and requested that the local
police department confirm that their malware signatures were up to date. The state ISO
contacted both the FBI CJIS ISO and state CSO to relay the preliminary details of this incident.
The FBI CJIS ISO instructed the involved parties to continue their investigation and to submit
an incident response form once all the information had been gathered. The FBI CJIS ISO
contacted the lead for the FBI CSIRC to inform them that an incident response form was
forthcoming. The state ISO gathered the remainder of the information from the local police
department and submitted a completed incident response form to the FBI CJIS ISO who
subsequently provided it to the FBI CSIRC. The FBI CSIRC notified the Department of Justice
Computer Incident Response Team (DOJCIRT). The state ISO continued to monitor the
situation, passing relevant details to the FBI CJIS ISO, ultimately determining that the botnet
was eliminated from the local police department’s infrastructure. Subsequent investigations
determined that the botnet was restricted to the department’s administrative infrastructure and
thus no CJI was compromised.

5.4 Policy Area 4: Auditing and Accountability
Agencies shall implement audit and accountability controls to increase the probability of
authorized users conforming to a prescribed pattern of behavior. Agencies shall carefully assess
the inventory of components that compose their information systems to determine which security
controls are applicable to the various components.
Auditing controls are typically applied to the components of an information system that provide
auditing capability (servers, etc.) and would not necessarily be applied to every user-level
workstation within the agency. As technology advances, more powerful and diverse functionality
can be found in such devices as personal digital assistants and cellular telephones, which may
require the application of security controls in accordance with an agency assessment of risk.
Refer to Section 5.13.6 for additional audit requirements related to mobile devices used to access
CJI.
5.4.1 Auditable Events and Content (Information Systems)
The agency’s information system shall generate audit records for defined events. These defined
events include identifying significant events which need to be audited as relevant to the security
of the information system. The agency shall specify which information system components carry
out auditing activities. Auditing activity can affect information system performance and this issue
must be considered as a separate factor during the acquisition of information systems.
The agency’s information system shall produce, at the application and/or operating system level,
audit records containing sufficient information to establish what events occurred, the sources of
the events, and the outcomes of the events. The agency shall periodically review and update the
list of agency-defined auditable events. In the event an agency does not use an automated system,
manual recording of activities shall still take place.
5.4.1.1 Events

The following events shall be logged:
1. Successful and unsuccessful system log-on attempts.
2. Successful and unsuccessful attempts to use:
a. access permission on a user account, file, directory or other system resource;
b. create permission on a user account, file, directory or other system resource;
c. write permission on a user account, file, directory or other system resource;
d. delete permission on a user account, file, directory or other system resource;
e. change permission on a user account, file, directory or other system resource.
3. Successful and unsuccessful attempts to change account passwords.
4. Successful and unsuccessful actions by privileged accounts.
5. Successful and unsuccessful attempts for users to:
a. access the audit log file;
b. modify the audit log file;
c. destroy the audit log file.
5.4.1.1.1 Content

The following content shall be included with every audited event:
1. Date and time of the event.
2. The component of the information system (e.g., software component, hardware
component) where the event occurred.
3. Type of event.
4. User/subject identity.
5. Outcome (success or failure) of the event.
5.4.2 Response to Audit Processing Failures
The agency’s information system shall provide alerts to appropriate agency officials in the event
of an audit processing failure. Audit processing failures include, for example: software/hardware
errors, failures in the audit capturing mechanisms, and audit storage capacity being reached or
exceeded.
5.4.3 Audit Monitoring, Analysis, and Reporting
The responsible management official shall designate an individual or position to review/analyze
information system audit records for indications of inappropriate or unusual activity, investigate
suspicious activity or suspected violations, to report findings to appropriate officials, and to take
necessary actions. Audit review/analysis shall be conducted at a minimum once a week. The
frequency of review/analysis should be increased when the volume of an agency’s processing
indicates an elevated need for audit review. The agency shall increase the level of audit monitoring
and analysis activity within the information system whenever there is an indication of increased
risk to agency operations, agency assets, or individuals based on law enforcement information,
intelligence information, or other credible sources of information.
5.4.4 Time Stamps
The agency’s information system shall provide time stamps for use in audit record generation. The
time stamps shall include the date and time values generated by the internal system clocks in the
audit records. The agency shall synchronize internal information system clocks on an annual basis.
5.4.5 Protection of Audit Information
The agency’s information system shall protect audit information and audit tools from modification,
deletion and unauthorized access.
5.4.6 Audit Record Retention
The agency shall retain audit records for at least one (1) year. Once the minimum retention time
period has passed, the agency shall continue to retain audit records until it is determined they are
no longer needed for administrative, legal, audit, or other operational purposes. This includes, for
example, retention and availability of audit records relative to Freedom of Information Act (FOIA)
requests, subpoena, and law enforcement actions.
5.4.7 Logging NCIC and III Transactions
A log shall be maintained for a minimum of one (1) year on all NCIC and III transactions. The III
portion of the log shall clearly identify both the operator and the authorized receiving agency. III
logs shall also clearly identify the requester and the secondary recipient. The identification on the
log shall take the form of a unique identifier that shall remain unique to the individual requester
and to the secondary recipient throughout the minimum one year retention period.
5.4.8 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 6 – Local Police Department's Use of Audit Logs
A state CSO contacted a local police department regarding potentially inappropriate use of
CHRI that was retrieved using the local department’s ORI. The state CSO requested all relevant
information from the police department to reconcile state NCIC and III logs against local police
department logs. The police department provided the combination of their CJI processing
application’s logs with relevant operating system and network infrastructure logs to help verify
the identity of the users conducting these queries. The review of these logs substantiated the
CSO’s suspicion.

5.5 Policy Area 5: Access Control
Access control provides the planning and implementation of mechanisms to restrict reading,
writing, processing and transmission of CJIS information and the modification of information
systems, applications, services and communication configurations allowing access to CJIS
information.
Refer to Section 5.13.7 for additional access control requirements related to mobile devices used
to access CJI.
5.5.1 Account Management
The agency shall manage information system accounts, including establishing, activating,
modifying, reviewing, disabling, and removing accounts. The agency shall validate information
system accounts at least annually and shall document the validation process. The validation and
documentation of accounts can be delegated to local agencies.
Account management includes the identification of account types (i.e., individual, group, and
system), establishment of conditions for group membership, and assignment of associated
authorizations. The agency shall identify authorized users of the information system and specify
access rights/privileges. The agency shall grant access to the information system based on:
1. Valid need-to-know/need-to-share that is determined by assigned official duties.
2. Satisfaction of all personnel security criteria.
The agency responsible for account creation shall be notified when:
1. A user’s information system usage or need-to-know or need-to-share changes.
2. A user is terminated or transferred or associated accounts are removed, disabled, or
otherwise secured.
5.5.2 Access Enforcement
The information system shall enforce assigned authorizations for controlling access to the system
and contained information. The information system controls shall restrict access to privileged
functions (deployed in hardware, software, and firmware) and security-relevant information to
explicitly authorized personnel.
Explicitly authorized personnel include, for example, security administrators, system and network
administrators, and other privileged users with access to system control, monitoring, or
administration functions (e.g., system administrators, information system security officers,
maintainers, system programmers).
Access control policies (e.g., identity-based policies, role-based policies, rule-based policies) and
associated access enforcement mechanisms (e.g., access control lists, access control matrices,
cryptography) shall be employed by agencies to control access between users (or processes acting
on behalf of users) and objects (e.g., devices, files, records, processes, programs, domains) in the
information system.

5.5.2.1 Least Privilege

The agency shall approve individual access privileges and shall enforce physical and logical access
restrictions associated with changes to the information system; and generate, retain, and review
records reflecting all such changes. The agency shall enforce the most restrictive set of
rights/privileges or access needed by users for the performance of specified tasks. The agency
shall implement least privilege based on specific duties, operations, or information systems as
necessary to mitigate risk to CJI. This limits access to CJI to only authorized personnel with the
need and the right to know.
Logs of access privilege changes shall be maintained for a minimum of one year or at least equal
to the agency’s record retention policy – whichever is greater.
5.5.2.2 System Access Control

Access control mechanisms to enable access to CJI shall be restricted by object (e.g., data set,
volumes, files, records) including the ability to read, write, or delete the objects. Access controls
shall be in place and operational for all IT systems to:
1. Prevent multiple concurrent active sessions for one user identification, for those
applications accessing CJI, unless the agency grants authority based upon operational
business needs. Agencies shall document the parameters of the operational business needs
for multiple concurrent active sessions.
2. Ensure that only authorized personnel can add, change, or remove component devices, dialup connections, and remove or alter programs.
5.5.2.3 Access Control Criteria

Agencies shall control access to CJI based on one or more of the following:
1. Job assignment or function (i.e., the role) of the user seeking access.
2. Physical location.
3. Logical location.
4. Network addresses (e.g., users from sites within a given agency may be permitted greater
access than those from outside).
5. Time-of-day and day-of-week/month restrictions.
5.5.2.4 Access Control Mechanisms

When setting up access controls, agencies shall use one or more of the following mechanisms:
1. Access Control Lists (ACLs). ACLs are a register of users (including groups, machines,
processes) who have been given permission to use a particular object (system resource)
and the types of access they have been permitted.
2. Resource Restrictions. Access to specific functions is restricted by never allowing users
to request information, functions, or other resources for which they do not have access.
Three major types of resource restrictions are: menus, database views, and network
devices.

3. Encryption. Encrypted information can only be decrypted, and therefore read, by those
possessing the appropriate cryptographic key. While encryption can provide strong access
control, it is accompanied by the need for strong key management. Follow the guidance in
Section 5.10.2 for encryption requirements if encryption of stored information is employed
as an access enforcement mechanism.
4. Application Level. In addition to controlling access at the information system level, access
enforcement mechanisms are employed at the application level to provide increased
information security for the agency.
5.5.3 Unsuccessful Login Attempts
Where technically feasible, the system shall enforce a limit of no more than 5 consecutive invalid
access attempts by a user (attempting to access CJI or systems with access to CJI). The system
shall automatically lock the account/node for a 10 minute time period unless released by an
administrator.
5.5.4 System Use Notification
The information system shall display an approved system use notification message, before granting
access, informing potential users of various usages and monitoring rules. The system use
notification message shall, at a minimum, provide the following information:
1. The user is accessing a restricted information system.
2. System usage may be monitored, recorded, and subject to audit.
3. Unauthorized use of the system is prohibited and may be subject to criminal and/or civil
penalties.
4. Use of the system indicates consent to monitoring and recording.
The system use notification message shall provide appropriate privacy and security notices (based
on associated privacy and security policies or summaries) and remain on the screen until the user
acknowledges the notification and takes explicit actions to log on to the information system.
Privacy and security policies shall be consistent with applicable laws, executive orders, directives,
policies, regulations, standards, and guidance. System use notification messages can be
implemented in the form of warning banners displayed when individuals log in to the information
system. For publicly accessible systems:
(i) the system use information is available and when appropriate, is displayed before
granting access;
(ii) any references to monitoring, recording, or auditing are in keeping with privacy
accommodations for such systems that generally prohibit those activities; and
(iii) the notice given to public users of the information system includes a description of the
authorized uses of the system.
5.5.5 Session Lock
The information system shall prevent further access to the system by initiating a session lock after
a maximum of 30 minutes of inactivity, and the session lock remains in effect until the user
reestablishes access using appropriate identification and authentication procedures. Users shall
directly initiate session lock mechanisms to prevent inadvertent viewing when a device is
unattended. A session lock is not a substitute for logging out of the information system. In the
interest of safety, devices that are: (1) part of a criminal justice conveyance; or (2) used to perform
dispatch functions and located within a physically secure location; or (3) terminals designated
solely for the purpose of receiving alert notifications (i.e. receive only terminals or ROT) used
within physically secure location facilities that remain staffed when in operation, are exempt from
this requirement. Note: an example of a session lock is a screen saver with password.
5.5.6 Remote Access
The agency shall authorize, monitor, and control all methods of remote access to the information
system. Remote access is any temporary access to an agency’s information system by a user (or
an information system) communicating temporarily through an external, non-agency-controlled
network (e.g., the Internet).
The agency shall employ automated mechanisms to facilitate the monitoring and control of remote
access methods. The agency shall control all remote accesses through managed access control
points. The agency may permit remote access for privileged functions only for compelling
operational needs but shall document the technical and administrative process for enabling remote
access for privileged functions in the security plan for the information system.
Virtual escorting of privileged functions is permitted only when all the following conditions are
met:
1.
2.
3.
4.

The session shall be monitored at all times by an authorized escort
The escort shall be familiar with the system/area in which the work is being performed.
The escort shall have the ability to end the session at any time.
The remote administrative personnel connection shall be via an encrypted (FIPS 140-2
certified) path.
5. The remote administrative personnel shall be identified prior to access and authenticated
prior to or during the session. This authentication may be accomplished prior to the
session via an Advanced Authentication (AA) solution or during the session via active
teleconference with the escort throughout the session.
5.5.6.1 Personally Owned Information Systems

A personally owned information system shall not be authorized to access, process, store or transmit
CJI unless the agency has established and documented the specific terms and conditions for
personally owned information system usage. When personally owned mobile devices (i.e. bring
your own device [BYOD]) are authorized, they shall be controlled in accordance with the
requirements in Policy Area 13: Mobile Devices.
This control does not apply to the use of personally owned information systems to access agency’s
information systems and information that are intended for public access (e.g., an agency’s public
website that contains purely public information).

5.5.6.2 Publicly Accessible Computers

Publicly accessible computers shall not be used to access, process, store or transmit CJI. Publicly
accessible computers include but are not limited to: hotel business center computers, convention
center computers, public library computers, public kiosk computers, etc.
5.5.7 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.

Figure 7 – A Local Police Department’s Access Controls
A local police department purchased a new computer-assisted dispatch (CAD) system that
integrated with their state CSA’s CJI interfaces. In doing so, the police department employed
least-privilege practices to ensure that its employees were only given those privileges needed to
perform their jobs, and as such, excluding IT administrators, employees had only nonadministrative privileges on all equipment they used. The police department also used ACLs in
the operating systems to control access to the CAD client’s executables. The CAD system used
internal role-based access controls to ensure only those users that needed access to CJI were
given it. The police department performed annual audits of user accounts on all systems under
their control including remote access mechanisms, operating systems, and the CAD system to
ensure all accounts were in valid states. The police department implemented authenticationfailure account lockouts, system use notification via login banners, and screen-saver passwords
on all equipment that processes CJI.

5.6 Policy Area 6: Identification and Authentication
The agency shall identify information system users and processes acting on behalf of users and
authenticate the identities of those users or processes as a prerequisite to allowing access to agency
information systems or services.
5.6.1 Identification Policy and Procedures
Each person who is authorized to store, process, and/or transmit CJI shall be uniquely identified.
A unique identification shall also be required for all persons who administer and maintain the
system(s) that access CJI or networks leveraged for CJI transit. The unique identification can take
the form of a full name, badge number, serial number, or other unique alphanumeric identifier.
Agencies shall require users to identify themselves uniquely before the user is allowed to perform
any actions on the system. Agencies shall ensure that all user IDs belong to currently authorized
users. Identification data shall be kept current by adding new users and disabling and/or deleting
former users.
5.6.1.1 Use of Originating Agency Identifiers in Transactions and Information
Exchanges

An FBI authorized originating agency identifier (ORI) shall be used in each transaction on CJIS
systems in order to identify the sending agency and to ensure the proper level of access for each
transaction. The original identifier between the requesting agency and the CSA/SIB/Channeler
shall be the ORI, and other agency identifiers, such as user identification or personal identifier, an
access device mnemonic, or the Internet Protocol (IP) address.
Agencies may act as a servicing agency and perform transactions on behalf of authorized agencies
requesting the service. Servicing agencies performing inquiry transactions on behalf of another
agency may do so using the requesting agency’s ORI. Servicing agencies may also use their own
ORI to perform inquiry transactions on behalf of a requesting agency if the means and procedures
are in place to provide an audit trail for the current specified retention period. Because the agency
performing the transaction may not necessarily be the same as the agency requesting the
transaction, the CSA/SIB/Channeler shall ensure that the ORI for each transaction can be traced,
via audit trail, to the specific agency which is requesting the transaction.
Audit trails can be used to identify the requesting agency if there is a reason to inquire into the
details surrounding why an agency ran an inquiry on a subject. Agencies assigned a P (limited
access) ORI shall not use the full access ORI of another agency to conduct an inquiry transaction.
5.6.2 Authentication Policy and Procedures
Authentication refers to mechanisms or processes that verify users are valid once they are uniquely
identified. The CSA/SIB may develop an authentication strategy which centralizes oversight but
decentralizes the establishment and daily administration of the security measures for access to CJI.
Each individual’s identity shall be authenticated at either the local agency, CSA, SIB or Channeler
level. The authentication strategy shall be part of the agency’s audit for policy compliance. The
FBI CJIS Division shall identify and authenticate all individuals who establish direct web-based
interactive sessions with FBI CJIS Services. The FBI CJIS Division shall authenticate the ORI of
all message-based sessions between the FBI CJIS Division and its customer agencies but will not

further authenticate the user nor capture the unique identifier for the originating operator because
this function is performed at the local agency, CSA, SIB or Channeler level.
5.6.2.1 Standard Authenticators

Authenticators are (the something you know, something you are, or something you have) part of
the identification and authentication process. Examples of standard authenticators include
passwords, tokens, biometrics, and personal identification numbers (PIN). Users shall not be
allowed to use the same password or PIN in the same logon sequence.
5.6.2.1.1 Password

Agencies shall follow the secure password attributes, below, to authenticate an individual’s unique
ID. Passwords shall:
1. Be a minimum length of eight (8) characters on all systems.
2. Not be a dictionary word or proper name.
3. Not be the same as the Userid.
4. Expire within a maximum of 90 calendar days.
5. Not be identical to the previous ten (10) passwords.
6. Not be transmitted in the clear outside the secure location.
7. Not be displayed when entered.
5.6.2.1.2 Personal Identification Number (PIN)

When agencies implement the use of a PIN as a standard authenticator, the PIN attributes shall
follow the guidance in section 5.6.2.1.1 (password). When agencies utilize a PIN in conjunction
with a certificate or a token (e.g. key fob with rolling numbers) for the purpose of advanced
authentication, agencies shall follow the PIN attributes described below. For example: A user
certificate is installed on a smartphone for the purpose of advanced authentication (AA). As the
user invokes that certificate, a PIN meeting the below attributes shall be used to access the
certificate for the AA process.
1.
2.
3.
4.
5.

Be a minimum of six (6) digits
Have no repeating digits (i.e., 112233)
Have no sequential patterns (i.e., 123456)
Not be the same as the Userid.
Expire within a maximum of 365 calendar days.
a. If a PIN is used to access a soft certificate which is the second factor of
authentication, AND the first factor is a password that complies with the
requirements in Section 5.6.2.1.1, then the 365 day expiration requirement can be
waived by the CSO.

6. Not be identical to the previous three (3) PINs.
7. Not be transmitted in the clear outside the secure location.
8. Not be displayed when entered.
EXCEPTION: When a PIN is used for local device authentication, the only requirement is that it
be a minimum of six (6) digits.

5.6.2.2 Advanced Authentication

Advanced Authentication (AA) provides for additional security to the typical user identification
and authentication of login ID and password, such as: biometric systems, user-based digital
certificates (e.g. public key infrastructure (PKI)), smart cards, software tokens, hardware tokens,
paper (inert) tokens, out-of-band authenticators (retrieved via a separate communication service
channel – e.g., authenticator is sent on demand via text message, phone call, etc.), or “Risk-based
Authentication” that includes a software token element comprised of a number of factors, such as
network information, user information, positive device identification (i.e. device forensics, user
pattern analysis and user binding), user profiling, and high-risk challenge/response questions.
When user-based certificates are used for authentication purposes, they shall:
1. Be specific to an individual user and not to a particular device.
2. Prohibit multiple users from utilizing the same certificate.
3. Require the user to “activate” that certificate for each use in some manner (e.g.,
passphrase or user-specific PIN).
5.6.2.2.1 Advanced Authentication Policy and Rationale

The requirement to use or not use AA is dependent upon the physical, personnel, and technical
security controls associated with the user location and whether CJI is accessed directly or
indirectly. AA shall not be required for users requesting access to CJI from within the perimeter
of a physically secure location (Section 5.9), when the technical security controls have been met
(Sections 5.5 and 5.10), or when the user has no ability to conduct transactional activities on state
and national repositories, applications, or services (i.e. indirect access). Conversely, if the
technical security controls have not been met, AA shall be required even if the request for CJI
originates from within a physically secure location. Section 5.6.2.2.2 provides agencies with a
decision tree to help guide AA decisions. The CSO will make the final determination of whether
access is considered indirect.
The intent of AA is to meet the standards of two-factor authentication. Two-factor authentication
employs the use of two of the following three factors of authentication: something you know (e.g.
password), something you have (e.g. hard token), something you are (e.g. biometric). The two
authentication factors shall be unique (i.e. password/token or biometric/password but not
password/password or token/token).
EXCEPTION:
AA shall be required when the requested service has built AA into its processes and requires a user
to provide AA before granting access. EXAMPLES:
a. A user, irrespective of his/her location, accesses the LEEP portal. The LEEP
has AA built into its services and requires AA prior to granting access. AA is
required.

b. A user, irrespective of their location, accesses a State’s portal through which
access to CJI is facilitated. The State Portal has AA built into its processes and
requires AA prior to granting access. AA is required.
5.6.2.2.2 Advanced Authentication Decision Tree

The following AA Decision Tree, coupled with figures 9 and 10 below, assists decision makers in
determining whether or not AA is required.
1. Can request’s physical originating location be determined?
If either (a) or (b) below are true the answer to the above question is “yes”. Proceed to
question 2.
a. The IP address is attributed to a physical structure; or
b. The mnemonic is attributed to a specific device assigned to a specific location
that is a physical structure.
If neither (a) or (b) above are true then the answer is “no”. Skip to question number 4.
2. Does request originate from within a physically secure location as described in Section
5.9.1?
If either (a) or (b) below are true the answer to the above question is “yes”. Proceed to
question 3.
a. The IP address is attributed to a physically secure location; or
b. If a mnemonic is used it is attributed to a specific device assigned to a specific
physically secure location.
If neither (a) or (b) above are true then the answer is “no”. Decision tree completed.
AA required.
3. Are all required technical controls implemented at this location or at the controlling
agency?
If either (a) or (b) below are true the answer to the above question is “yes”. Decision
tree completed. AA requirement waived.
a. Appropriate technical controls listed in Sections 5.5 and 5.10 are implemented;
or
b. The controlling agency (i.e. parent agency or agency leveraged as conduit to
CJI) extends its wide area network controls down to the requesting agency and
the extended controls provide assurance equal or greater to the controls listed
in Sections 5.5 and 5.10.
If neither (a) or (b) above are true then the answer is “no”. Decision tree completed.
AA required.
4. Does request originate from an agency-controlled user device?
If either (a) or (b) below are true the answer to the above question is “yes”. Proceed to
question 5.

a. The static IP address or MAC address can be traced to registered device; or
b. Certificates are issued to agency managed devices only and certificate exchange
is allowed only between authentication server and agency issued devices.
If neither (a) or (b) above are true then the answer is “no”. Decision tree completed.
AA required.
5. Is the agency managed user device associated with and located within a criminal justice
conveyance?
If any of the (a), (b), or (c) statements below is true the answer to the above question is
“yes”. Proceed to Figure 9 Step 3.
a. The static IP address or MAC address is associated with a device associated
with a criminal justice conveyance; or
b. The certificate presented is associated with a device associated with a criminal
justice conveyance; or
c. The mnemonic presented is associated with a specific device assigned and that
device is attributed to a criminal justice conveyance.
If none of the (a), (b), or (c) statements above are true then the answer is “no”. Skip to
question number 7.
6. Is the user device an agency-issued and controlled smartphone or tablet?
If both (a) and (b) below are true, the answer to the above question is “yes.” Proceed
to question number 7.
a. The law enforcement agency issued the device to an individual; and
b. The device is subject to administrative management control of the issuing
agency.
If either (a) or (b) above is false, then the answer is “no.” Decision tree completed.
AA required.
7. Does the agency-issued smartphone or tablet have CSO-approved AA compensating
controls implemented?
If (a) and (b) below are true, the answer to the above question is “yes.” Decision tree
completed. AA requirement is waived.
a. An agency cannot meet a requirement due to legitimate technical or business
constraints; and
b. The CSO has given written approval permitting AA compensating controls to
be implemented in lieu of the required AA control measures.
If either (a) or (b) above is false then the answer is “no.” Decision tree completed. AA
required.
5.6.3 Identifier and Authenticator Management
The agency shall establish identifier and authenticator management processes.
5.6.3.1 Identifier Management

In order to manage user identifiers, agencies shall:
1. Uniquely identify each user.
2. Verify the identity of each user.
3. Receive authorization to issue a user identifier from an appropriate agency official.
4. Issue the user identifier to the intended party.
5. Disable the user identifier after a specified period of inactivity.
6. Archive user identifiers.
5.6.3.2 Authenticator Management

In order to manage information system authenticators, agencies shall:
1. Define initial authenticator content.
2. Establish administrative procedures for initial authenticator distribution, for
lost/compromised, or damaged authenticators, and for revoking authenticators.
3. Change default authenticators upon information system installation.
4. Change/refresh authenticators periodically.
Information system authenticators include, for example, tokens, user-based PKI certificates,
biometrics, passwords, and key cards. Users shall take reasonable measures to safeguard
authenticators including maintaining possession of their individual authenticators, not loaning or
sharing authenticators with others, and immediately reporting lost or compromised authenticators.
5.6.4 Assertions
Identity providers can be leveraged to identify individuals and assert the individual’s identity to a
service or to a trusted broker who will in-turn assert the identity to a service. Assertion
mechanisms used to communicate the results of a remote authentication to other parties shall be:
1. Digitally signed by a trusted entity (e.g., the identity provider).
2. Obtained directly from a trusted entity (e.g. trusted broker) using a protocol where the
trusted entity authenticates to the relying party using a secure protocol (e.g. transport
layer security [TLS]) that cryptographically authenticates the verifier and protects the
assertion.
Assertions generated by a verifier shall expire after 12 hours and shall not be accepted thereafter
by the relying party.
5.6.5 References/Citations/Directives
Appendix C contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 8 – Advanced Authentication Use Cases
Use Case 1 - A Local Police Department Authentication Control Scenario
During the course of an investigation, a detective attempts to access Criminal Justice
Information (CJI) from a hotel room using an agency issued mobile broadband card. To gain
access, the detective first establishes the remote session via a secure virtual private network
(VPN) tunnel (satisfying the requirement for encryption). Upon connecting to the agency
network, the detective is challenged for a username (identification), password (“something
you know”), and a one-time password OTP (“something you have”) from a hardware token
to satisfy the requirement for advanced authentication. Once the detective’s credentials are
validated, his identity is asserted by the infrastructure to all authorized applications needed to
complete his queries.
Use Case 2 – Use of a Smart Card
A user is issued a smart card that is loaded with user-specific digital certificates from a
terminal within a controlled area. The user selects an application that will provide access to
Criminal Justice Information (CJI) then enters the proper username (identification) and
password (“something you know”). Once prompted, the user connects the smart card
(“something you have”) to the terminal. The user is prompted to enter a personal
identification number (PIN) to unlock the smart card. Once unlocked, the smart card sends
the certificates to the authentication management server at the local agency where the
combined username, password, and digital user certificates are validated. The user has
satisfied the requirement for AA and is granted access to CJI.
Use Case 3 – Out of Band One-Time-Password (OTP) – Mobile phone-based
Using an agency- issued laptop, a user connects to the agency network via an agency-issued
mobile broadband card and an encrypted virtual private network (VPN) tunnel. As part of an
on-going investigation, the user initiates an application that will permit access to Criminal
Justice Information (CJI). The user is prompted to enter a username (identification) and a
password (“something you know”). Once that has been completed, a text message containing
a one-time password (OTP) is sent via text message (out of band) to the user’s agency-issued
cell phone. The user is challenged via the CJI application for that OTP. The user enters the
OTP (“something you have”) then the username, password, and OTP are validated. The user
has satisfied the requirement for AA and is granted access to CJI.
Use Case 4 – Improper Use of a One-Time-Password (OTP) – Laptop
Using an agency- issued laptop, a user connects to the agency network via an agency-issued
mobile broadband card and an encrypted virtual private network (VPN) tunnel. As part of an
on-going investigation, the user initiates an application that will permit access to Criminal
Justice Information (CJI). The user is prompted to enter a username (identification) and a
password (“something you know”). Once that has been completed, a one-time password
(OTP) is sent to the user’s agency-issued laptop (in band) via pop-up message. The user is
challenged via the CJI application for that OTP; however, the delivery of the OTP to the
device that is being used to access CJI (in band) defeats the purpose of the second factor. This

method does not satisfy the requirement for AA, and therefore the user should not be granted
access to CJI. See the below explanation:
This method of receiving the necessary OTP (in band) does not guarantee the authenticity of
the user’s identity because anyone launching the CJI application and entering a valid
username/password combination is presented the OTP via a pop-up which is intend to be the
second factor of authentication. This method makes the application accessible to anyone with
knowledge of the valid username and password. Potentially, this is no more secure than using
only a single factor of authentication.
Use Case 5 – Risk-based Authentication (RBA) Implementation
A user has moved office locations and requires email access (containing Criminal Justice
Information) via an Outlook Web Access (OWA) client utilizes a risk-based authentication
(RBA) solution. The user launches the OWA client and is prompted to enter a username
(identification) and a password (“something you know”). The RBA detects this computer has
not previously been used by the user, is not listed under the user’s profile, and then presents
high-risk challenge/response question(s) which the user is prompted to answer. Once the
questions have been verified as correct, the user is authenticated and granted access to the
email. Meanwhile, the RBA logs and collects a number of device forensic information and
captures the user pattern analysis to update the user’s profile. The CJIS Security Policy
requirements for RBA have been satisfied.
Use Case 6 – Improper Risk-based Authentication (RBA) Implementation
A user has moved office locations and requires access to email containing Criminal Justice
Information (CJI) via an Outlook Web Access (OWA) client utilizing a risk-based
authentication (RBA) solution. The user launches the OWA client and is prompted to enter
a username (identification) and a password (“something you know”). The RBA detects this
computer has not previously been used by the user and is not listed under the user’s profile.
The user is prompted to answer high-risk challenge/response questions for verification and
authorization to access to the email; however, if the second authentication factor is to answer
additional questions presented every time the user logs on, then this solution is referred to as
a knowledge-based authentic on (KBA) solution. A KBA solution does not satisfy the
requirement for AA, and therefore the user should not be granted access to CJI.
See the below explanation:
A KBA solution is not a viable advanced authentication (AA) solution per the CJIS Security
Policy (CSP). The KBA asks questions and compares the answers to those stored within the
user’s profile. A KBA is neither a CSP compliant two factor authentication solution, nor does
it meet the CSP criteria of a risk-based authentication (RBA) solution which logs and collects
a number of device forensic information and captures the user pattern analysis to update the
user’s profile. Using this collected data, the RBA presents challenge/response questions when
changes to the user’s profile are noted versus every time the user logs in.

Use Case 7 – Advanced Authentication Compensating Controls on Agency-Issued
Smartphones
An authorized user is issued a smartphone that is administratively managed by the agencyinstalled mobile device management (MDM) solution to ensure device compliance with the
CJIS Security Policy. The user initiates an email client on the smartphone that contains emails
with CJI. The email client challenges the user to enter a username (identification) and a
password (one factor: something you know) which are forwarded to the local agency for
authentication. The smartphone lacks the technical capability to challenge the user for a
second factor of authentication. This email client is used across the state agency so access is
a necessity for the user’s job functions.
An audit by the CSA identifies the agency’s use of the agency smartphone as not compliant
with AA requirements due to the authorized user authenticating with only one factor instead
of the required two factors.
Subsequently, the agency performs a risk assessment of their smartphone authentication
solution and document a legitimate technical constraint due to the lack of technical solutions
for smartphone-based two-factor authentication. The risk assessment identifies the following
compensating controls that, when combined with the authorized user authenticating to the
local agency with their password, meet the intent of the AA requirement by providing a
similar level of security:
1. Enhance smartphone policy to enable possession of the smartphone to be considered a
factor of authentication (i.e. something you have). Require authorized users to treat the
smartphone as a controlled device and protect it as they would a personal credit card or an
issued firearm to ensure only they will be in possession of the device
2. Move the email client used to authenticate with the local agency inside an encrypted,
password-protected secure container on the smartphone ensuring only the authorized user can
access the email application to authenticate.
The agency submits an AA compensating controls request to the CSO outlining the technical
constraint identified by the risk assessment, what compensating controls will be employed,
and the desired duration of the compensating controls.
The CSO approves the agency’s request and provides documentation of the approval to the
agency to maintain for audit purposes. The agency enacts the compensating controls and
informs agency personnel they are permitted to access CJI via the agency-issued smartphone.

Figure 9 – Authentication Decision for Known Location
Incoming CJI
Access Request

#1
Can request’s physical
originating location be
determined?

No

See Figure 10

Yes

#2
Does request originate from
within a physically secure
location?

No

Yes

#3
Are all required technical
controls implemented at this
location or at controlling
agency?

Advanced Authentication
Required

No

Yes

Advanced Authentication
Not Required

Figure 10 – Authentication Decision for Unknown Location
Incoming CJI
Access Request

#1
Can request’s physical
originating location be
determined?

Yes

See Figure 9

No

#4
Does request originate
from an agency-controlled
user device?

No or Unknown

Yes

#5
Is the agency managed
user device associated with
and located within a
Criminal Justice
Conveyance?

No

#6
Is the user device an
agency-issued and
controlled smartphone or
tablet?

No

Advanced Authentication
Required

Yes

Yes

#7
Does the agency-issued
smartphone or tablet have
CSO-approved compensating
controls implemented?

No

Go To Figure 9
Step #3
Yes

Advanced Authentication
Not Required

Figure 10
5.7 Policy Area 7: Configuration Management
5.7.1 Access Restrictions for Changes
Planned or unplanned changes to the hardware, software, and/or firmware components of the
information system can have significant effects on the overall security of the system. The goal is
to allow only qualified and authorized individuals access to information system components for
purposes of initiating changes, including upgrades, and modifications. Section 5.5, Access
Control, describes agency requirements for control of privileges and restrictions.
5.7.1.1 Least Functionality

The agency shall configure the application, service, or information system to provide only essential
capabilities and shall specifically prohibit and/or restrict the use of specified functions, ports,
protocols, and/or services.
5.7.1.2 Network Diagram

The agency shall ensure that a complete topological drawing depicting the interconnectivity of the
agency network, to criminal justice information, systems and services is maintained in a current
status. See Appendix C for sample network diagrams.
The network topological drawing shall include the following:
1. All communications paths, circuits, and other components used for the interconnection,
beginning with the agency-owned system(s) and traversing through all interconnected
systems to the agency end-point.
2. The logical location of all components (e.g., firewalls, routers, switches, hubs, servers,
encryption devices, and computer workstations). Individual workstations (clients) do not
have to be shown; the number of clients is sufficient.
3. “For Official Use Only” (FOUO) markings.
4. The agency name and date (day, month, and year) drawing was created or updated.
5.7.2 Security of Configuration Documentation
The system configuration documentation often contains sensitive details (e.g. descriptions of
applications, processes, procedures, data structures, authorization processes, data flow, etc.)
Agencies shall protect the system documentation from unauthorized access consistent with the
provisions described in Section 5.5 Access Control.
5.7.3 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.

Figure 11 – A Local Police Department’s Configuration Management Controls
A local police department decided to update their CAD system, and in doing so tracked all
changes made to their infrastructure in a configuration management journal, updated their
network topology documents to include all new components in their architecture, then marked
all documentation as FOUO and stored them securely.

5.8

Policy Area 8: Media Protection

Media protection policy and procedures shall be documented and implemented to ensure that
access to digital and physical media in all forms is restricted to authorized individuals. Procedures
shall be defined for securely handling, transporting and storing media.
5.8.1 Media Storage and Access
The agency shall securely store digital and physical media within physically secure locations or
controlled areas. The agency shall restrict access to digital and physical media to authorized
individuals. If physical and personnel restrictions are not feasible then the data shall be encrypted
per Section 5.10.1.2.
5.8.2 Media Transport
The agency shall protect and control digital and physical media during transport outside of
controlled areas and restrict the activities associated with transport of such media to authorized
personnel.
5.8.2.1 Digital Media during Transport

Controls shall be in place to protect digital media containing CJI while in transport (physically
moved from one location to another) to help prevent compromise of the data. Encryption, as
defined in Section 5.10.1.2 of this Policy, is the optimal control during transport; however, if
encryption of the data isn’t possible then each agency shall institute physical controls to ensure the
security of the data.
5.8.2.2 Physical Media in Transit

The controls and security measures in this document also apply to CJI in physical (printed
documents, printed imagery, etc.) form. Physical media shall be protected at the same level as the
information would be protected in electronic form.
5.8.3 Digital Media Sanitization and Disposal
The agency shall sanitize, that is, overwrite at least three times or degauss digital media prior to
disposal or release for reuse by unauthorized individuals. Inoperable digital media shall be
destroyed (cut up, shredded, etc.). The agency shall maintain written documentation of the steps
taken to sanitize or destroy electronic media. Agencies shall ensure the sanitization or destruction
is witnessed or carried out by authorized personnel.
5.8.4 Disposal of Physical Media
Physical media shall be securely disposed of when no longer required, using formal procedures.
Formal procedures for the secure disposal or destruction of physical media shall minimize the risk
of sensitive information compromise by unauthorized individuals. Physical media shall be
destroyed by shredding or incineration. Agencies shall ensure the disposal or destruction is
witnessed or carried out by authorized personnel.

5.8.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 12 – A Local Police Department’s Media Management Policies
A local police department implemented a replacement CAD system that integrated to their
state’s CSA and was authorized to process CJI. The police department contracted with an offsite media manager to store backups of their data in the contractor’s vaults, but the contractor
was not authorized to process or store CJI. To ensure the confidentially of the police
department’s data while outside its perimeter, they encrypted all data going to the contractor
with an encryption product that is FIPS 140-2 certified. The police department rotated and
reused media through the contractor’s vaults periodically, and when it required destruction, the
police department incinerated the media to irreversibly destroy any data on it.

5.9 Policy Area 9: Physical Protection
Physical protection policy and procedures shall be documented and implemented to ensure CJI
and information system hardware, software, and media are physically protected through access
control measures.
5.9.1 Physically Secure Location
A physically secure location is a facility, a criminal justice conveyance, or an area, a room, or a
group of rooms within a facility with both the physical and personnel security controls sufficient
to protect CJI and associated information systems. The physically secure location is subject to
criminal justice agency management control; SIB control; FBI CJIS Security addendum; or a
combination thereof.
Sections 5.9.1.1 – 5.9.1.8 describe the physical controls required in order to be considered a
physically secure location, while Sections 5.2 and 5.12, respectively, describe the minimum
security awareness training and personnel security controls required for unescorted access to a
physically secure location. Sections 5.5, 5.6.2.2.1, and 5.10 describe the requirements for technical
security controls required to access CJI from within the perimeter of a physically secure location
without AA.
5.9.1.1 Security Perimeter

The perimeter of a physically secure location shall be prominently posted and separated from nonsecure locations by physical controls. Security perimeters shall be defined, controlled and secured
in a manner acceptable to the CSA or SIB.
5.9.1.2 Physical Access Authorizations

The agency shall develop and keep current a list of personnel with authorized access to the
physically secure location (except for those areas within the permanent facility officially
designated as publicly accessible) or shall issue credentials to authorized personnel.
5.9.1.3 Physical Access Control

The agency shall control all physical access points (except for those areas within the facility
officially designated as publicly accessible) and shall verify individual access authorizations
before granting access.
5.9.1.4 Access Control for Transmission Medium

The agency shall control physical access to information system distribution and transmission lines
within the physically secure location.
5.9.1.5 Access Control for Display Medium

The agency shall control physical access to information system devices that display CJI and shall
position information system devices in such a way as to prevent unauthorized individuals from
accessing and viewing CJI.

5.9.1.6 Monitoring Physical Access

The agency shall monitor physical access to the information system to detect and respond to
physical security incidents.
5.9.1.7 Visitor Control

The agency shall control physical access by authenticating visitors before authorizing escorted
access to the physically secure location (except for those areas designated as publicly accessible).
The agency shall escort visitors at all times and monitor visitor activity.
5.9.1.8 Delivery and Removal

The agency shall authorize and control information system-related items entering and exiting the
physically secure location.
5.9.2 Controlled Area
If an agency cannot meet all of the controls required for establishing a physically secure location,
but has an operational need to access or store CJI, the agency shall designate an area, a room, or a
storage container, as a controlled area for the purpose of day-to-day CJI access or storage. The
agency shall, at a minimum:
1. Limit access to the controlled area during CJI processing times to only those personnel
authorized by the agency to access or view CJI.
2. Lock the area, room, or storage container when unattended.
3. Position information system devices and documents containing CJI in such a way as to
prevent unauthorized individuals from access and view.
4. Follow the encryption requirements found in Section 5.10.1.2 for electronic storage (i.e.
data “at rest”) of CJI.
5.9.3 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 13 – A Local Police Department's Physical Protection Measures
A local police department implemented a replacement CAD system that was authorized to
process CJI over an encrypted VPN tunnel to the state’s CSA. The police department established
a physically separated wing within their precinct separated by locked doors, walls, and a
monitored security system within which CJI was processed by criminal justice professionals.
Only those persons with the appropriate authorizations were permitted within this wing unless
accompanied by such a person. Within this secure wing the police department further segregated
the back-office information systems’ infrastructure within a separately controlled area restricted
only to those authorized administrative personnel with a need to enter.

5.10 Policy Area 10: System and Communications Protection and
Information Integrity
Examples of systems and communications safeguards range from boundary and transmission
protection to securing an agency’s virtualized environment. In addition, applications, services, or
information systems must have the capability to ensure system integrity through the detection and
protection against unauthorized changes to software and information. This section details the
policy for protecting systems and communications infrastructures.
Refer to Section 5.13.4 for additional system integrity requirements related to mobile devices used
to access CJI.
5.10.1 Information Flow Enforcement
The network infrastructure shall control the flow of information between interconnected systems.
Information flow control regulates where information is allowed to travel within an information
system and between information systems (as opposed to who is allowed to access the information)
and without explicit regard to subsequent accesses to that information. In other words, controlling
how data moves from one place to the next in a secure manner. Examples of controls that are
better expressed as flow control than access control (see Section 5.5) are:
1. Prevent CJI from being transmitted unencrypted across the public network.
2. Block outside traffic that claims to be from within the agency.
3. Do not pass any web requests to the public network that are not from the internal web
proxy.
Specific examples of flow control enforcement can be found in boundary protection devices (e.g.
proxies, gateways, guards, encrypted tunnels, firewalls, and routers) that employ rule sets or
establish configuration settings that restrict information system services or provide a packet
filtering capability.
5.10.1.1 Boundary Protection

The agency shall:
1. Control access to networks processing CJI.
2. Monitor and control communications at the external boundary of the information system
and at key internal boundaries within the system.
3. Ensure any connections to the Internet, other external networks, or information systems
occur through controlled interfaces (e.g. proxies, gateways, routers, firewalls, encrypted
tunnels). See Section 5.13.4.3 for guidance on personal firewalls.
4. Employ tools and techniques to monitor network events, detect attacks, and provide
identification of unauthorized use.
5. Ensure the operational failure of the boundary protection mechanisms do not result in any
unauthorized release of information outside of the information system boundary (i.e. the
device shall “fail closed” vs. “fail open”).

6. Allocate publicly accessible information system components (e.g. public Web servers) to
separate sub networks with separate, network interfaces. Publicly accessible information
systems residing on a virtual host shall follow the guidance in Section 5.10.3.2 to achieve
separation.
5.10.1.2 Encryption

Commonly available encryption tools often use a key to unlock the cipher to allow data access;
this key is called a passphrase. While similar to a password, a passphrase is not used for user
authentication. Additionally, the passphrase contains stringent character requirements making it
more secure and thus providing a higher level of confidence that the passphrase will not be
compromised.
1. Encryption shall be a minimum of 128 bit.
2. When CJI is transmitted outside the boundary of the physically secure location, the data
shall be immediately protected via cryptographic mechanisms (encryption).
EXCEPTIONS:
a) See Sections 5.13.1.2.2 and 5.10.2.
b) Encryption shall not be required if the transmission medium meets all of the
following requirements:
i.

The agency owns, operates, manages, or protects the medium.

ii.

Medium terminates within physically secure locations at both ends with no
interconnections between.

iii.

Physical access to the medium is controlled by the agency using the
requirements in Sections 5.9.1 and 5.12.

iv.

Protection includes safeguards (e.g., acoustic, electric, electromagnetic, and
physical) and if feasible countermeasures (e.g., alarms, notifications) to
permit its use for the transmission of unencrypted information through an
area of lesser classification or control.

v.

With prior approval of the CSO.

Examples:
A campus is completely owned and controlled by a criminal justice agency (CJA)
– If line-of-sight between buildings exists where a cable is buried, encryption is not
required.
A multi-story building is completely owned and controlled by a CJA – If floors are
physically secure or cable runs through non-secure areas are protected, encryption
is not required.
A multi-story building is occupied by a mix of CJAs and non-CJAs – If floors are
physically secure or cable runs through the non-secure areas are protected,
encryption is not required.
3. When CJI is at rest (i.e. stored digitally) outside the boundary of the physically secure
location, the data shall be protected via cryptographic mechanisms (encryption).
a) When agencies implement encryption on CJI at rest, the passphrase used to
unlock the cipher shall meet the following requirements:
i.

Be at least 10 characters

ii.

Not be a dictionary word.

iii.

Include at least one (1) upper case letter, one (1) lower case letter, one
(1) number, and one (1) special character.

iv.

Be changed when previously authorized personnel no longer require
access.

b) Multiple files maintained in the same unencrypted folder shall have separate
and distinct passphrases. A single passphrase may be used to encrypt an entire
folder or disk containing multiple files. All audit requirements found in Section
5.4.1 Auditable Events and Content (Information Systems) shall be applied.
4. When encryption is employed, the cryptographic module used shall be certified to meet
FIPS 140-2 standards.
Note 1: Subsequent versions of approved cryptographic modules that are under current
review for FIPS 140-2 compliancy can be used in the interim until certification is complete.
Note 2: While FIPS 197 (Advanced Encryption Standard) certification is desirable, a FIPS
197 certification alone is insufficient as the certification is for the algorithm only vs. the
FIPS 140-2 standard which certifies the packaging of an implementation.
EXCEPTION: When encryption is used for CJI at rest, agencies may use encryption
methods that are FIPS 197 certified, 256 bit as described on the National Security Agency
(NSA) Suite B Cryptography list of approved algorithms.
5. For agencies using public key infrastructure technology, the agency shall develop and
implement a certificate policy and certification practice statement for the issuance of public
key certificates used in the information system. Registration to receive a public key
certificate shall:
a) Include authorization by a supervisor or a responsible official.
b) Be accomplished by a secure process that verifies the identity of the certificate
holder.
c) Ensure the certificate is issued to the intended party.
5.10.1.3 Intrusion Detection Tools and Techniques

The agency shall implement network-based and/or host-based intrusion detection tools.
The CSA/SIB shall, in addition:
1. Monitor inbound and outbound communications for unusual or unauthorized activities.
2. Send individual intrusion detection logs to a central logging facility where correlation and
analysis will be accomplished as a system wide intrusion detection effort.
3. Employ automated tools to support near-real-time analysis of events in support of detecting
system-level attacks.
5.10.1.4 Voice over Internet Protocol

Voice over Internet Protocol (VoIP) has been embraced by organizations globally as an addition
to, or replacement for, public switched telephone network (PSTN) and private branch exchange
(PBX) telephone systems. The immediate benefits are lower costs than traditional telephone
services and VoIP can be installed in-line with an organization’s existing Internet Protocol (IP)
services. Among VoIP’s risks that have to be considered carefully are: myriad security concerns,
cost issues associated with new networking hardware requirements, and overarching quality of
service (QoS) factors.
In addition to the security controls described in this document, the following additional controls
shall be implemented when an agency deploys VoIP within a network that contains unencrypted
CJI:
1. Establish usage restrictions and implementation guidance for VoIP technologies.
2. Change the default administrative password on the IP phones and VoIP switches.
3. Utilize Virtual Local Area Network (VLAN) technology to segment VoIP traffic from data
traffic.
Appendix G.2 outlines threats, vulnerabilities, mitigations, and NIST best practices for VoIP.
5.10.1.5 Cloud Computing

Organizations transitioning to a cloud environment are presented unique opportunities and
challenges (e.g., purported cost savings and increased efficiencies versus a loss of control over the
data). Reviewing the cloud computing white paper (Appendix G.3), the cloud assessment located
within the security policy resource center on FBI.gov, NIST Special Publications (800-144, 800145, and 800-146), as well as the cloud provider’s policies and capabilities will enable
organizations to make informed decisions on whether or not the cloud provider can offer service
that maintains compliance with the requirements of the CJIS Security Policy.
The metadata derived from CJI shall not be used by any cloud service provider for any purposes.
The cloud service provider shall be prohibited from scanning any email or data files for the purpose
of building analytics, data mining, advertising, or improving the services provided.
5.10.2 Facsimile Transmission of CJI
CJI transmitted via a single or multi-function device over a standard telephone line is exempt from
encryption requirements. CJI transmitted external to a physically secure location using a facsimile
server, application or service which implements email-like technology, shall meet the encryption
requirements for CJI in transit as defined in Section 5.10.
5.10.3 Partitioning and Virtualization
As resources grow scarce, agencies are increasing the centralization of applications, services, and
system administration. Advanced software now provides the ability to create virtual machines that
allows agencies to reduce the amount of hardware needed. Although the concepts of partitioning
and virtualization have existed for a while, the need for securing the partitions and virtualized
machines has evolved due to the increasing amount of distributed processing and federated
information sources now available across the Internet.

5.10.3.1 Partitioning

The application, service, or information system shall separate user functionality (including user
interface services) from information system management functionality.
The application, service, or information system shall physically or logically separate user interface
services (e.g. public web pages) from information storage and management services (e.g. database
management). Separation may be accomplished through the use of one or more of the following:
1. Different computers.
2. Different central processing units.
3. Different instances of the operating system.
4. Different network addresses.
5. Other methods approved by the FBI CJIS ISO.
5.10.3.2 Virtualization

Virtualization refers to a methodology of dividing the resources of a computer (hardware and
software) into multiple execution environments. Virtualized environments are authorized for
criminal justice and noncriminal justice activities. In addition to the security controls described in
this Policy, the following additional controls shall be implemented in a virtual environment:
1. Isolate the host from the virtual machine. In other words, virtual machine users cannot
access host files, firmware, etc.
2. Maintain audit logs for all virtual machines and hosts and store the logs outside the hosts’
virtual environment.
3. Virtual Machines that are Internet facing (web servers, portal servers, etc.) shall be
physically separate from Virtual Machines (VMs) that process CJI internally or be
separated by a virtual firewall.
4. Drivers that serve critical functions shall be stored within the specific VM they service. In
other words, do not store these drivers within the hypervisor, or host operating system, for
sharing. Each VM is to be treated as an independent system – secured as independently as
possible.
The following additional technical security controls shall be applied in virtual environments where
CJI is comingled with non-CJI:
1. Encrypt CJI when stored in a virtualized environment where CJI is comingled with nonCJI or segregate and store unencrypted CJI within its own secure VM.
2. Encrypt network traffic within the virtual environment.
The following are additional technical security control best practices and should be implemented
wherever feasible:
1. Implement IDS and/or IPS monitoring within the virtual environment.
2. Virtually or physically firewall each VM within the virtual environment to ensure that only
allowed protocols will transact.
3. Segregate the administrative duties for the host.
Appendix G-1 provides some reference and additional background information on virtualization.
5.10.4 System and Information Integrity Policy and Procedures
5.10.4.1 Patch Management

The agency shall identify applications, services, and information systems containing software or
components affected by recently announced software flaws and potential vulnerabilities resulting
from those flaws.
The agency (or the software developer/vendor in the case of software developed and maintained
by a vendor/contractor) shall develop and implement a local policy that ensures prompt installation
of newly released security relevant patches, service packs and hot fixes. Local policies should
include such items as:
1. Testing of appropriate patches before installation.
2. Rollback capabilities when installing patches, updates, etc.
3. Automatic updates without individual user intervention.
4. Centralized patch management.
Patch requirements discovered during security assessments, continuous monitoring or incident
response activities shall also be addressed expeditiously.
5.10.4.2 Malicious Code Protection

The agency shall implement malicious code protection that includes automatic updates for all
systems with Internet access. Agencies with systems not connected to the Internet shall implement
local procedures to ensure malicious code protection is kept current (i.e. most recent update
available).
The agency shall employ virus protection mechanisms to detect and eradicate malicious code (e.g.,
viruses, worms, Trojan horses) at critical points throughout the network and on all workstations,
servers and mobile computing devices on the network. The agency shall ensure malicious code
protection is enabled on all of the aforementioned critical points and information systems and
resident scanning is employed.
5.10.4.3 Spam and Spyware Protection

The agency shall implement spam and spyware protection.
The agency shall:
1. Employ spam protection mechanisms at critical information system entry points (e.g.
firewalls, electronic mail servers, remote-access servers).
2. Employ spyware protection at workstations, servers and mobile computing devices on the
network.
3. Use the spam and spyware protection mechanisms to detect and take appropriate action on
unsolicited messages and spyware/adware, respectively, transported by electronic mail,
electronic mail attachments, Internet accesses, removable media (e.g. diskettes or compact
disks) or other removable media as defined in this Policy.
5.10.4.4 Security Alerts and Advisories

The agency shall:
1. Receive information system security alerts/advisories on a regular basis.
2. Issue alerts/advisories to appropriate personnel.
3. Document the types of actions to be taken in response to security alerts/advisories.
4. Take appropriate actions in response.
5. Employ automated mechanisms to make security alert and advisory information available
throughout the agency as appropriate.
5.10.4.5 Information Input Restrictions

The agency shall restrict the information input to any connection to FBI CJIS services to authorized
personnel only.
Restrictions on personnel authorized to input information to the information system may extend
beyond the typical access controls employed by the system and include limitations based on
specific operational/project responsibilities.
5.10.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.

Figure 14 – System and Communications Protection and Information Integrity Use Cases
A Local Police Department’s Information Systems & Communications Protections
A local police department implemented a replacement CAD system within a physically secure
location that was authorized to process CJI using a FIPS 140-2 encrypted VPN tunnel over the
Internet to the state’s CSA. In addition to the policies, physical and personnel controls already
in place, the police department employed firewalls both at their border and at key points within
their network, intrusion detection systems, a patch-management strategy that included automatic
patch updates where possible, virus scanners, spam and spyware detection mechanisms that
update signatures automatically, and subscribed to various security alert mailing lists and
addressed vulnerabilities raised through the alerts as needed.

Faxing from a Single/Multi-function Device over a Traditional Telephone Line
A dispatcher from county A runs a NCIC query on an individual. The results are printed and then
sent to an adjoining county using a single/multi-function device with facsimile capability. For
faxing, the device is only connected to a traditional telephone line as is the device at the receiving
county. Encryption of a document containing CJI is not required because the document travels
over a traditional telephone line.

Faxing from a Multi-function Device over a Network
A dispatcher from city A runs a NCIC query on an individual. The results are printed and the
dispatcher uses a multi-function copier to fax the file to a city in another state. The dispatcher
enters the fax number of the receiver and sends the document. The document containing CJI is
automatically converted to a digital file and routed to the receiver over the agency network and
the Internet. Because the device uses a network and the Internet for transmitting documents
containing CJI, encryption in transit using FIPS 140-2 certified 128 bit symmetric encryption is
required.

5.11 Policy Area 11: Formal Audits
Formal audits are conducted to ensure compliance with applicable statutes, regulations and
policies.
5.11.1 Audits by the FBI CJIS Division
5.11.1.1 Triennial Compliance Audits by the FBI CJIS Division

The FBI CJIS Division is authorized to conduct audits, once every three (3) years as a minimum,
to assess agency compliance with applicable statutes, regulations and policies. The CJIS Audit
Unit (CAU) shall conduct a triennial audit of each CSA in order to verify compliance with
applicable statutes, regulations and policies. This audit shall include a sample of CJAs and, in
coordination with the SIB, the NCJAs. Audits may be conducted on a more frequent basis if the
audit reveals that an agency has not complied with applicable statutes, regulations and policies.
The FBI CJIS Division shall also have the authority to conduct unannounced security inspections
and scheduled audits of Contractor facilities.
5.11.1.2 Triennial Security Audits by the FBI CJIS Division

The FBI CJIS Division is authorized to conduct security audits of the CSA and SIB networks and
systems, once every three (3) years as a minimum, to assess agency compliance with the CJIS
Security Policy. This audit shall include a sample of CJAs and NCJAs. Audits may be conducted
on a more frequent basis if the audit reveals that an agency has not complied with the CJIS Security
Policy.
5.11.2 Audits by the CSA
Each CSA shall:
1. At a minimum, triennially audit all CJAs and NCJAs which have direct access to the state
system in order to ensure compliance with applicable statutes, regulations and policies.
2. In coordination with the SIB, establish a process to periodically audit all NCJAs, with
access to CJI, in order to ensure compliance with applicable statutes, regulations and
policies.
3. Have the authority to conduct unannounced security inspections and scheduled audits of
Contractor facilities.
4. Have the authority, on behalf of another CSA, to conduct a CSP compliance audit of
contractor facilities and provide the results to the requesting CSA. If a subsequent CSA
requests an audit of the same contractor facility, the CSA may provide the results of the
previous audit unless otherwise notified by the requesting CSA that a new audit be
performed.
Note: This authority does not apply to the audit requirement outlined in the Security and
Management Control Outsourcing Standard for Non-Channeler and Channelers related to
outsourcing noncriminal justice administrative functions.

5.11.3 Special Security Inquiries and Audits
All agencies having access to CJI shall permit an inspection team to conduct an appropriate inquiry
and audit of any alleged security violations. The inspection team shall be appointed by the APB
and shall include at least one representative of the CJIS Division. All results of the inquiry and
audit shall be reported to the APB with appropriate recommendations.
5.11.4 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 15 – The Audit of a Local Police Department
A local police department implemented a replacement CAD system that integrated to their
state’s CSA and was authorized to process CJI. Shortly after the implementation, their state’s
CSA conducted an audit of their policies, procedures, and systems that process CJI. The police
department supplied all architectural and policy documentation, including detailed network
diagrams, to the auditors in order to assist them in the evaluation. The auditors discovered a
deficiency in the police department’s systems and marked them “out” in this aspect of the FBI
CJIS Security Policy. The police department quickly addressed the deficiency and took
corrective action, notifying the auditors of their actions.

5.12 Policy Area 12: Personnel Security
Having proper security measures against the insider threat is a critical component for the CJIS
Security Policy. This section’s security terms and requirements apply to all personnel who have
access to unencrypted CJI including those individuals with only physical or logical access to
devices that store, process or transmit unencrypted CJI.
5.12.1 Personnel Security Policy and Procedures
5.12.1.1 Minimum Screening Requirements for Individuals Requiring Access to CJI:

1. To verify identification, a state of residency and national fingerprint-based record checks
shall be conducted within 30 days of assignment for all personnel who have direct access
to CJI and those who have direct responsibility to configure and maintain computer systems
and networks with direct access to CJI. However, if the person resides in a different state
than that of the assigned agency, the agency shall conduct state (of the agency) and national
fingerprint-based record checks and execute a NLETS CHRI IQ/FQ/AQ query using
purpose code C, E, or J depending on the circumstances. When appropriate, the screening
shall be consistent with:
(i) 5 CFR 731.106; and/or
(ii) Office of Personnel Management policy, regulations, and guidance; and/or
(iii) agency policy, regulations, and guidance.
(See Appendix J for applicable guidance regarding noncriminal justice agencies
performing adjudication of civil fingerprint submissions.) Federal entities bypassing state
repositories in compliance with federal law may not be required to conduct a state
fingerprint-based record check.
2. All requests for access shall be made as specified by the CSO. The CSO, or their designee,
is authorized to approve access to CJI. All CSO designees shall be from an authorized
criminal justice agency.
3. If a felony conviction of any kind exists, the hiring authority in the Interface Agency shall
deny access to CJI. However, the hiring authority may ask for a review by the CSO in
extenuating circumstances where the severity of the offense and the time that has passed
would support a possible variance.
4. If a record of any other kind exists, access to CJI shall not be granted until the CSO or
his/her designee reviews the matter to determine if access is appropriate.
5. If the person appears to be a fugitive or has an arrest history without conviction, the CSO
or his/her designee shall review the matter to determine if access to CJI is appropriate.
6. If the person is employed by a NCJA, the CSO or his/her designee, and, if applicable, the
appropriate board maintaining management control, shall review the matter to determine
if CJI access is appropriate. This same procedure applies if this person is found to be a
fugitive or has an arrest history without conviction.
7. If the person already has access to CJI and is subsequently arrested and or convicted,
continued access to CJI shall be determined by the CSO. This does not implicitly grant
hiring/firing authority with the CSA, only the authority to grant access to CJI. For offenses
other than felonies, the CSO has the latitude to delegate continued access determinations
to his or her designee.
8. If the CSO or his/her designee determines that access to CJI by the person would not be in
the public interest, access shall be denied and the person's appointing authority shall be
notified in writing of the access denial.
9. Support personnel, contractors, and custodial workers with access to physically secure
locations or controlled areas (during CJI processing) shall be subject to a state and national
fingerprint-based record check unless these individuals are escorted by authorized
personnel at all times.
It is recommended individual background re-investigations be conducted every five years unless
Rap Back is implemented.
5.12.1.2 Personnel Screening for Contractors and Vendors

In addition to meeting the requirements in paragraph 5.12.1.1, contractors and vendors shall meet
the following requirements:
1. Prior to granting access to CJI, the CGA on whose behalf the Contractor is retained shall
verify identification via a state of residency and national fingerprint-based record check.
However, if the person resides in a different state than that of the assigned agency, the
agency shall conduct state (of the agency) and national fingerprint-based record checks and
execute a NLETS CHRI IQ/FQ/AQ query using purpose code C, E, or J depending on the
circumstances.
2. If a record of any kind is found, the CGA shall be formally notified and system access shall
be delayed pending review of the criminal history record information. The CGA shall in
turn notify the Contractor-appointed Security Officer.
3. When identification of the applicant with a criminal history has been established by
fingerprint comparison, the CGA or the CJA (if the CGA does not have the authority to
view CHRI) shall review the matter.
4. A Contractor employee found to have a criminal record consisting of felony conviction(s)
shall be disqualified.
5. Applicants shall also be disqualified on the basis of confirmations that arrest warrants are
outstanding for such applicants.
6. The CGA shall maintain a list of personnel who have been authorized access to CJI and
shall, upon request, provide a current copy of the access list to the CSO.
Applicants with a record of misdemeanor offense(s) may be granted access if the CSO determines
the nature or severity of the misdemeanor offense(s) do not warrant disqualification. The CGA
may request the CSO to review a denial of access determination.
5.12.2 Personnel Termination
The agency, upon termination of individual employment, shall immediately terminate access to
CJI.

5.12.3 Personnel Transfer
The agency shall review CJI access authorizations when personnel are reassigned or transferred to
other positions within the agency and initiate appropriate actions such as closing and establishing
accounts and changing system access authorizations.
5.12.4 Personnel Sanctions
The agency shall employ a formal sanctions process for personnel failing to comply with
established information security policies and procedures.
5.12.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 16 – A Local Police Department's Personnel Security Controls
A local police department implemented a replacement CAD system that integrated to their
state’s CSA and was authorized to process CJI. In addition to the physical and technical controls
already in place, the police department implemented a variety of personnel security controls to
reduce the insider threat. The police department used background screening consistent with the
FBI CJIS Security Policy to vet those with unescorted access to areas in which CJI is processed,
including the IT administrators employed by a contractor and all janitorial staff. The police
department established sanctions against any vetted person found to be in violation of stated
policies. The police department re-evaluated each person’s suitability for access to CJI every
five years.

5.13 Policy Area 13: Mobile Devices
This policy area describes considerations and requirements for mobile devices including
smartphones and tablets. Mobile devices are not limited to a single form factor or communications
medium. The requirements in this section augment those in other areas of the Policy to address
the gaps introduced by using mobile devices.
The agency shall: (i) establish usage restrictions and implementation guidance for mobile devices;
and (ii) authorize, monitor, control wireless access to the information system. Wireless
technologies, in the simplest sense, enable one or more devices to communicate without physical
connections—without requiring network or peripheral cabling.
Appendix G provides reference material and additional information on mobile devices.
5.13.1 Wireless Communications Technologies
Examples of wireless communication technologies include, but are not limited to: 802.11, cellular,
Bluetooth, satellite, microwave, and land mobile radio (LMR). Wireless technologies require at
least the minimum security applied to wired technology and, based upon the specific technology
or implementation, wireless technologies may require additional security controls as described
below.
5.13.1.1 802.11 Wireless Protocols

Wired Equivalent Privacy (WEP) and Wi-Fi Protected Access (WPA) cryptographic algorithms,
used by all pre-80.11i protocols, do not meet the requirements for FIPS 140-2 and shall not be
used.
Agencies shall implement the following controls for all agency-managed wireless access points
with access to an agency’s network that processes unencrypted CJI:
1. Perform validation testing to ensure rogue APs (Access Points) do not exist in the
802.11 Wireless Local Area Network (WLAN) and to fully understand the wireless
network security posture.
2. Maintain a complete inventory of all Access Points (APs) and 802.11 wireless devices.
3. Place APs in secured areas to prevent unauthorized physical access and user
manipulation.
4. Test AP range boundaries to determine the precise extent of the wireless coverage and
design the AP wireless coverage to limit the coverage area to only what is needed for
operational purposes.
5. Enable user authentication and encryption mechanisms for the management interface
of the AP.
6. Ensure that all APs have strong administrative passwords and ensure that all passwords
are changed in accordance with Section 5.6.2.1.
7. Ensure the reset function on APs is used only when needed and is only invoked by
authorized personnel. Restore the APs to the latest security settings, when the reset
functions are used, to ensure the factory default settings are not utilized.

8. Change the default service set identifier (SSID) in the APs. Disable the broadcast SSID
feature so that the client SSID must match that of the AP. Validate that the SSID
character string does not contain any agency identifiable information (division,
department, street, etc.) or services.
9. Enable all security features of the wireless product, including the cryptographic
authentication, firewall, and other available privacy features.
10. Ensure that encryption key sizes are at least 128-bits and the default shared keys are
replaced by unique keys.
11. Ensure that the ad hoc mode has been disabled.
12. Disable all nonessential management protocols on the APs.
13. Ensure all management access and authentication occurs via FIPS compliant secure
protocols (e.g. SFTP, HTTPS, SNMP over TLS, etc.). Disable non-FIPS compliant
secure access to the management interface.
14. Enable logging (if supported) and review the logs on a recurring basis per local policy.
At a minimum logs shall be reviewed monthly.
15. Insulate, virtually (e.g. virtual local area network (VLAN) and ACLs) or physically
(e.g. firewalls), the wireless network from the operational wired infrastructure. Limit
access between wireless networks and the wired network to only operational needs.
16. When disposing of access points that will no longer be used by the agency, clear access
point configuration to prevent disclosure of network configuration, keys, passwords,
etc.
5.13.1.2 Cellular Devices

Cellular telephones, smartphones (i.e. Blackberry, iPhones, etc.), tablets, personal digital assistants
(PDA), and “aircards” are examples of cellular handheld devices or devices that are capable of
employing cellular technology. Additionally, cellular handheld devices typically include
Bluetooth, infrared, and other wireless protocols capable of joining infrastructure networks or
creating dynamic ad hoc networks.
Threats to cellular handheld devices stem mainly from their size, portability, and available wireless
interfaces and associated services. Examples of threats to cellular handheld devices include:
1. Loss, theft, or disposal.
2. Unauthorized access.
3. Malware.
4. Spam.
5. Electronic eavesdropping.
6. Electronic tracking (threat to security of data and safety of the criminal justice
professional).
7. Cloning (not as prevalent with later generation cellular technologies).
8. Server-resident data.
5.13.1.2.1 Cellular Service Abroad

Certain internal functions on cellular devices may be modified or compromised by the cellular
carrier during international use as the devices are intended to have certain parameters configured
by the cellular provider which is considered a “trusted” entity by the device.
When devices are authorized to access CJI outside the U.S., agencies shall perform an inspection
to ensure that all controls are in place and functioning properly in accordance with the agency’s
policies prior to and after deployment outside of the U.S.
5.13.1.2.2 Voice Transmissions Over Cellular Devices

Any cellular device used to transmit CJI via voice is exempt from the encryption and authentication
requirements.
5.13.1.3 Bluetooth

Bluetooth is an open standard for short-range radio frequency (RF) communication. Bluetooth is
used primarily to establish wireless personal area networks (WPAN). Bluetooth technology has
been integrated into many types of business and consumer devices, including cell phones, laptops,
automobiles, medical devices, printers, keyboards, mice, headsets, and biometric capture devices.
Bluetooth technology and associated devices are susceptible to general wireless networking threats
(e.g. denial of service [DoS] attacks, eavesdropping, man-in-the-middle [MITM] attacks, message
modification, and resource misappropriation) as well as specific Bluetooth-related attacks that
target known vulnerabilities in Bluetooth implementations and specifications. Organizational
security policy shall be used to dictate the use of Bluetooth and its associated devices based on the
agency’s operational and business processes.
5.13.1.4 Mobile Hotspots

Many mobile devices include the capability to function as a WiFi hotspot that allows other devices
to connect through the device to the internet over the devices cellular network.
When an agency allows mobile devices that are approved to access or store CJI to function as a
Wi-Fi hotspot connecting to the Internet, they shall be configured:
1. Enable encryption on the hotspot
2. Change the hotspot’s default SSID
a. Ensure the hotspot SSID does not identify the device make/model or agency
ownership
3. Create a wireless network password (Pre-shared key)
4. Enable the hotspot’s port filtering/blocking features if present
5. Only allow connections from agency controlled devices
Note: Refer to the requirements in Section 5.10.1.2 encryption for item #1. Refer to the
requirements in Section 5.6.2.2.1 Password for item #3. Only password attributes #1, #2 and #3
are required.
OR

1. Have a MDM solution to provide the same security as identified in items 1 – 5 above.

5.13.2 Mobile Device Management (MDM)
Mobile Device Management (MDM) facilitates the implementation of sound security controls for
mobile devices and allows for centralized oversight of configuration control, application usage,
and device protection and recovery, if so desired by the agency.
Due to the potential for inconsistent network access or monitoring capability on mobile devices,
methods used to monitor and manage the configuration of full featured operating systems may not
function properly on devices with limited feature operating systems. MDM systems and
applications coupled with device specific technical policy can provide a robust method for device
configuration management if properly implemented.
Devices that have had any unauthorized changes made to them (including but not limited to being
rooted or jailbroken) shall not be used to process, store, or transmit CJI data at any time. Agencies
shall implement the following controls when allowing CJI access from devices running a limitedfeature operating system:
1. Ensure that CJI is only transferred between CJI authorized applications and storage areas
of the device.
2. MDM with centralized administration configured and implemented to perform at least
the:
i.
Remote locking of device
ii.
Remote wiping of device
iii. Setting and locking device configuration
iv.
Detection of “rooted” and “jailbroken” devices
v.
Enforcement of folder or disk level encryption
vi.
Application of mandatory policy settings on the device
vii.
Detection of unauthorized configurations
viii. Detection of unauthorized software or applications
ix. Ability to determine the location of agency controlled devices
x. Prevention of unpatched devices from accessing CJI or CJI systems
xi. Automatic device wiping after a specified number of failed access attempts
5.13.3 Wireless Device Risk Mitigations
Organizations shall, at a minimum, ensure that wireless devices:
1. Apply available critical patches and upgrades to the operating system as soon as they
become available for the device and after necessary testing as described in Section
5.10.4.1.
2. Are configured for local device authentication (see Section 5.13.7.1).
3. Use advanced authentication or CSO approved compensating controls as per Section
5.13.7.2.1.
4. Encrypt all CJI resident on the device.
5. Erase cached information, to include authenticators (see Section 5.6.2.1) in
applications, when session is terminated.
6. Employ personal firewalls or run a Mobile Device Management (MDM) system that
facilitates the ability to provide firewall services from the agency level.
7. Employ malicious code protection or run a MDM system that facilitates the ability to
provide anti-malware services from the agency level.
5.13.4 System Integrity
Managing system integrity on limited function mobile operating systems may require methods
and technologies significantly different from traditional full featured operating systems. In many
cases, the requirements of Section 5.10 of the CJIS Security Policy cannot be met with a mobile
device without the installation of a third party MDM, application, or supporting service
infrastructure.
5.13.4.1 Patching/Updates

Based on the varying connection methods for mobile devices, an always on connection cannot be
guaranteed for patching and updating. Devices without always-on cellular connections may not
be reachable for extended periods of time by the MDM or solution either to report status or
initiate patching.
Agencies shall monitor mobile devices to ensure their patch and update state is current.
5.13.4.2 Malicious Code Protection

Appropriately configured MDM software is capable of checking the installed applications on the
device and reporting the software inventory to a central management console in a manner
analogous to traditional virus scan detection of unauthorized software and can provide a high
degree of confidence that only known software or applications are installed on the device.
Agencies that allow smartphones and tablets to access CJI shall have a process to approve the
use of specific software or applications on the devices. Any device natively capable of
performing these functions without a MDM solution is acceptable under this section.
5.13.4.3 Personal Firewall

For the purpose of this policy, a personal firewall is an application that controls network traffic to
and from a user device, permitting or denying communications based on policy. A personal
firewall shall be employed on all mobile devices that have a full-feature operating system (i.e.
laptops or tablets with Windows or Linux/Unix operating systems). At a minimum, the personal
firewall shall perform the following activities:
1. Manage program access to the Internet.
2. Block unsolicited requests to connect to the user device.
3. Filter incoming traffic by IP address or protocol.
4. Filter incoming traffic by destination ports.
5. Maintain an IP traffic log.
Mobile devices with limited feature operating systems (i.e. tablets, smartphones) may not support
a personal firewall. However, these operating systems have a limited number of system services
installed, carefully controlled network access, and to a certain extent, perform functions similar to
a personal firewall on a device with a full feature operating system. Appropriately configured
MDM software is capable of controlling which applications are allowed on the device.
5.13.5 Incident Response
In addition to the requirements in Section 5.3 Incident Response, agencies shall develop additional
or enhanced incident reporting and handling procedures to address mobile device operating
scenarios. Rapid response to mobile device related incidents can significantly mitigate the risks
associated with illicit data access either on the device itself or within online data resources
associated with the device through an application or specialized interface.
Special reporting procedures for mobile devices shall apply in any of the following situations:
1. Loss of device control. For example:
a. Device known to be locked, minimal duration of loss
b. Device lock state unknown, minimal duration of loss
c. Device lock state unknown, extended duration of loss
d. Device known to be unlocked, more than momentary duration of loss
2. Total loss of device
3. Device compromise
4. Device loss or compromise outside the United States
5.13.6 Access Control
Multiple user accounts are not generally supported on limited feature mobile operating systems.
Access control (Section 5.5 Access Control) shall be accomplished by the application that accesses
CJI.
5.13.7 Identification and Authentication
Due to the technical methods used for identification and authentication on many limited feature
mobile operating systems, achieving compliance may require many different components.
5.13.7.1 Local Device Authentication

When mobile devices are authorized for use in accessing CJI, local device authentication shall be
used to unlock the device for use. The authenticator used shall meet the requirements in section
5.6.2.1 Standard Authenticators.
5.13.7.2 Advanced Authentication

When accessing CJI from an authorized mobile device, advanced authentication shall be used by
the authorized user.

5.13.7.2.1 Compensating Controls

CSO approved compensating controls to meet the AA requirement on agency-issued smartphones
and tablets with limited feature operating systems are permitted. Compensating controls are
temporary control measures that are implemented in lieu of the required AA control measures
when an agency cannot meet a requirement due to legitimate technical or business constraints.
Before CSOs consider approval of compensating controls, Mobile Device Management (MDM)
shall be implemented per Section 5.13.2. The compensating controls shall:
1. Meet the intent of the CJIS Security Policy AA requirement
2. Provide a similar level of protection or security as the original AA requirement
3. Not rely upon the existing requirements for AA as compensating controls
Additionally, compensating controls may rely upon other, non-AA, existing requirements as
compensating controls and/or be combined with new controls to create compensating controls.
The proposed compensating controls for AA are a combination of controls that provide acceptable
assurance only the authorized user is authenticating and not an impersonator or (in the case of
agency-issued device used by multiple users) controls that reduce the risk of exposure if
information is accessed by an unauthorized party.
At least two of the following examples of AA compensating controls for agency-issued
smartphones and tablets with limited feature operating systems shall be implemented to qualify
for compensating control consideration:
-

Possession of the agency issued smartphone or tablet as an indication it is the authorized
user
Implemented password protection on the Mobile Device Management application and/or
secure container where the authentication application is stored
Enable remote device locking
Enable remote data deletion
Enable automatic data wipe after predetermined number of failed authentication attempts
Remote device location (GPS) tracking
Require CJIS Security Policy compliant password to access the device
Use of device certificates as per Section 5.13.7.3 Device Certificates

5.13.7.3 Device Certificates

Device certificates are often used to uniquely identify mobile devices using part of a public key
pair on the device in the form of a public key certificate. While there is value to ensuring the device
itself can authenticate to a system supplying CJI, and may provide a critical layer of device
identification or authentication in a larger scheme, a device certificate alone placed on the device
shall not be considered valid proof that the device is being operated by an authorized user.
When certificates or cryptographic keys used to authenticate a mobile device are used in lieu of
compensating controls for advanced authentication, they shall be:
1. Protected against being extracted from the device
2. Configured for remote wipe on demand or self-deletion based on a number of
unsuccessful login or access attempts
3. Configured to use a secure authenticator (i.e. password, PIN) to unlock the key for use

APPENDICES
APPENDIX A TERMS AND DEFINITIONS
Access to Criminal Justice Information — The physical or logical (electronic) ability, right or
privilege to view, modify or make use of Criminal Justice Information.
Administration of Criminal Justice — The detection, apprehension, detention, pretrial release,
post-trial release, prosecution, adjudication, correctional supervision, or rehabilitation of accused
persons or criminal offenders. It also includes criminal identification activities; the collection,
storage, and dissemination of criminal history record information; and criminal justice
employment. In addition, administration of criminal justice includes “crime prevention programs”
to the extent access to criminal history record information is limited to law enforcement agencies
for law enforcement programs (e.g. record checks of individuals who participate in Neighborhood
Watch or “safe house” programs) and the result of such checks will not be disseminated outside
the law enforcement agency.
Agency Controlled Mobile Device — A mobile device that is centrally managed by an agency
for the purpose of securing the device for potential access to CJI. The device can be agency issued
or BYOD (personally owned).
Agency Coordinator (AC) — A staff member of the Contracting Government Agency who
manages the agreement between the Contractor and agency.
Agency Issued Mobile Device — A mobile device that is owned by an agency and issued to an
individual for use. It is centrally managed by the agency for the purpose of securing the device
for potential access to CJI. The device is not BYOD (personally owned).
Agency Liaison (AL) — Coordinator of activities between the criminal justice agency and the
noncriminal justice agency when responsibility for a criminal justice system has been delegated
by a criminal justice agency to a noncriminal justice agency, which has in turn entered into an
agreement with a contractor. The agency liaison shall, inter alia, monitor compliance with system
security requirements. In instances in which the noncriminal justice agency's authority is directly
from the CJIS systems agency, there is no requirement for the appointment of an agency liaison.
Authorized User/Personnel — An individual, or group of individuals, who have been
appropriately vetted through a national fingerprint-based record check and have been granted
access to CJI.
Authorized Recipient — (1) A criminal justice agency or federal agency authorized to receive
CHRI pursuant to federal statute or executive order; (2) A nongovernmental entity authorized by
federal statute or executive order to receive CHRI for noncriminal justice purposes; or (3) A
government agency authorized by federal statute or executive order, or state statute which has been
approved by the United States Attorney General to receive CHRI for noncriminal justice purposes.
Availability — The degree to which information, a system, subsystem, or equipment is operable
and in a useable state; frequently represented as a proportion of time the element is in a functioning
condition.

Biographic Data — Information collected about individuals associated with a unique case, and
not necessarily connected to identity data. Biographic Data does not provide a history of an
individual, only information related to a unique case.
Biometric Data — When applied to CJI, it is used to identify individuals, and includes the
following types: fingerprints, palm prints, DNA, iris, and facial recognition.
Case / Incident History — All relevant information gathered about an individual, organization,
incident, or combination thereof, arranged so as to serve as an organized record to provide analytic
value for a criminal justice organization. In regards to CJI, it is the information about the history
of criminal incidents.
Certificate Authority (CA) Certificate – Digital certificates required for certificate-based
authentication that are issued to tell the client computers and servers that it can trust other
certificates that are issued by this CA.
Channeler — A FBI approved contractor, who has entered into an agreement with an Authorized
Recipient(s), to receive noncriminal justice applicant fingerprint submissions and collect the
associated fees. The Channeler ensures fingerprint submissions are properly and adequately
completed, electronically forwards fingerprint submissions to the FBI's CJIS Division for national
noncriminal justice criminal history record check, and receives electronic record check results for
dissemination to Authorized Recipients. A Channeler is essentially an "expediter" rather than a
user of criminal history record check results.
Cloud Client – A machine or software application that accesses cloud services over a network
connection, perhaps on behalf of a subscriber.
Cloud Computing – A distributed computing model that permits on-demand network access to a
shared pool of configurable computing resources (i.e., networks, servers, storage, applications, and
services), software, and information.
Cloud Provider – An organization that provides cloud computing services.
Cloud Subscriber – A person or organization that is a customer of a cloud computing service
provider.
CJIS Advisory Policy Board (APB) — The governing organization within the FBI CJIS
Advisory Process composed of representatives from criminal justice and national security agencies
within the United States. The APB reviews policy, technical, and operational issues relative to
CJIS Division programs and makes subsequent recommendations to the Director of the FBI.
CJIS Audit Unit (CAU) — The organization within the FBI CJIS Division responsible to perform
audits of CSAs to verify compliance with the CJIS Security Policy.
CJIS Security Policy — The FBI CJIS Security Policy document as published by the FBI CJIS
ISO; the document containing this glossary.
CJIS Systems Agency (CSA) — A duly authorized state, federal, international, tribal, or territorial
criminal justice agency on the CJIS network providing statewide (or equivalent) service to its
criminal justice users with respect to the CJI from various systems managed by the FBI CJIS
Division. There shall be only one CSA per state or territory. In federal agencies, the CSA may be
the interface or switch to other federal agencies connecting to the FBI CJIS systems.

CJIS Systems Agency Information Security Officer (CSA ISO) — The appointed FBI CJIS
Division personnel responsible to coordinate information security efforts at all CJIS interface
agencies.
CJIS Systems Officer (CSO) — The individual located within the CJIS Systems Agency
responsible for the administration of the CJIS network on behalf of the CJIS Systems Agency.
Compact Council — The entity created by the National Crime Prevention and Privacy Compact
of 1998 that has the authority to promulgate rules and procedures governing the use of the III
system for noncriminal justice purposes.
Compact Officers — The leadership of the Compact Council, oversees the infrastructure
established by the National Crime Prevention and Privacy Compact Act of 1998, which is used by
ratifying states to exchange criminal records for noncriminal justice purposes. Their primary
responsibilities are to promulgate rules and procedures for the effective and appropriate use of the
III system.
Compensating Controls — Compensating controls are temporary control measures implemented
in lieu of the required control measures when an agency cannot meet the AA requirement due to
legitimate technical or business constraints. The compensating controls must:
1. Meet the intent of the CJIS Security Policy AA requirement
2. Provide a similar level of protection or security as the original AA requirement
3. Not rely upon the existing requirements for AA as compensating controls
Additionally, compensating controls may rely upon other, non-AA, existing requirements as
compensating controls and/or be combined with new controls to create compensating controls.
Computer Security Incident Response Capability (CSIRC) — A collection of personnel,
systems, and processes that are used to efficiently and quickly manage a centralized response to
any sort of computer security incident which may occur.
Confidentiality — The concept of ensuring that information is observable only to those who have
been granted authorization to do so.
Contractor — A private business, agency or individual which has entered into an agreement for
the administration of criminal justice or noncriminal justice functions with a Criminal Justice
Agency or a Noncriminal Justice Agency. Also, a private business approved by the FBI CJIS
Division to contract with Noncriminal Justice Agencies to perform noncriminal justice functions
associated with civil fingerprint submission for hiring purposes.
Contracting Government Agency (CGA) — The government agency, whether a Criminal
Justice Agency or a Noncriminal Justice Agency, which enters into an agreement with a private
contractor.
Crime Reports Data — The data collected through the Uniform Crime Reporting program and
reported upon annually by the FBI CJIS division used to analyze the crime statistics for the United
States.

Criminal History Record Information (CHRI) — A subset of CJI. Any notations or other
written or electronic evidence of an arrest, detention, complaint, indictment, information or other
formal criminal charge relating to an identifiable person that includes identifying information
regarding the individual as well as the disposition of any charges.
Criminal Justice Agency (CJA) — The courts, a governmental agency, or any subunit of a
governmental agency which performs the administration of criminal justice pursuant to a statute
or executive order and which allocates a substantial part of its annual budget to the administration
of criminal justice. State and federal Inspectors General Offices are included.
Criminal Justice Agency User Agreement — A terms-of-service agreement that must be signed
prior to accessing CJI. This agreement is required by each CJA and spells out user’s
responsibilities, the forms and methods of acceptable use, penalties for their violation, disclaimers,
and so on.
Criminal Justice Conveyance — A criminal justice conveyance is any enclosed mobile vehicle
used for the purposes of criminal justice activities with the capability to comply, during operational
periods, with the requirements of Section 5.9.1.3.
Criminal Justice Information (CJI) — Criminal Justice Information is the abstract term used to
refer to all of the FBI CJIS provided data necessary for law enforcement agencies to perform their
mission and enforce the laws, including but not limited to: biometric, identity history, person,
organization, property (when accompanied by any personally identifiable information), and
case/incident history data. In addition, CJI refers to the FBI CJIS-provided data necessary for civil
agencies to perform their mission; including, but not limited to data used to make hiring decisions.
The following type of data are exempt from the protection levels required for CJI: transaction
control type numbers (e.g. ORI, NIC, FNU, etc.) when not accompanied by information that
reveals CJI or PII.
Criminal Justice Information Services Division (FBI CJIS or CJIS) — The FBI division
responsible for the collection, warehousing, and timely dissemination of relevant CJI to the FBI
and to qualified law enforcement, criminal justice, civilian, academic, employment, and licensing
agencies.
Data — See Information and CJI.
Degauss — Neutralize a magnetic field to erase information from a magnetic disk or other storage
device. In the field of information technology, degauss has become synonymous with erasing
information whether or not the medium is magnetic. In the event the device to be degaussed is not
magnetic (e.g. solid state drive, USB storage device), steps other than magnetic degaussing may
be required to render the information irretrievable from the device.
Department of Justice (DoJ) — The Department within the U.S. Government responsible to
enforce the law and defend the interests of the United States according to the law, to ensure public
safety against threats foreign and domestic, to provide federal leadership in preventing and
controlling crime, to seek just punishment for those guilty of unlawful behavior, and to ensure fair
and impartial administration of justice for all Americans.
Digital Media – Any form of electronic media designed to store data in a digital format. This
includes, but is not limited to: memory device in laptops, computers, and mobile devices; and any
removable, transportable electronic media, such as magnetic tape or disk, optical disk, flash drives,
external hard drives, or digital memory card.
Digital Signature – A digital signature consists of three algorithms: (1) A key generation
algorithm that selects a private key uniformly at random from a set of possible private keys. The
algorithm outputs the private key and a corresponding public key. (2) A signing algorithm that,
given a message and a private key, produces a signature. (3) A signature verifying algorithm that,
given a message, public key, and a signature, either accepts or rejects the message’s claim to
authenticity. Two main properties are required. First, a signature generated from a fixed message
and fixed private key should verify the authenticity of that message by using the corresponding
public key. Secondly, it should be computationally infeasible to generate a valid signature for a
party who does not possess the private key.
Direct Access — (1) Having the authority to access systems managed by the FBI CJIS Division,
whether by manual or automated methods, not requiring the assistance of, or intervention by, any
other party or agency (28 CFR, Chapter 1, Part 20). (2) Having the authority to query or update
national databases maintained by the FBI CJIS Division including national queries and updates
automatically or manually generated by the CSA.
Dissemination — The transmission/distribution of CJI to Authorized Recipients within an agency.
Escort – Authorized personnel who accompany a visitor at all times while within a physically
secure location to ensure the protection and integrity of the physically secure location and any
Criminal Justice Information therein. The use of cameras or other electronic means used to
monitor a physically secure location does not constitute an escort.
Facsimile (Fax) – Facsimile is: (a) a document received and printed on a single or multi-function
stand-alone device, (b) a single or multi-function stand-alone device for the express purpose of
transmitting and receiving documents from a like device over a standard telephone line, or (c) a
facsimile server, application, service which implements email-like technology and transfers
documents over a network.
Federal Bureau of Investigation (FBI) — The agency within the DOJ responsible to protect and
defend the United States against terrorist and foreign intelligence threats, to uphold and enforce
the criminal laws of the United States, and to provide leadership and criminal justice services to
federal, state, municipal, and international agencies and partners.
FBI CJIS Information Security Officer (FBI CJIS ISO) — The FBI personnel responsible for
the maintenance and dissemination of the FBI CJIS Security Policy; the liaison between the FBI
and the CSA’s ISOs and other relevant security points-of-contact (POCs); the provider of technical
guidance as to the intent and implementation of technical policy issues; the POC for computer
incident notification which also disseminates security alerts to the CSOs and ISOs.
Federal Information Security Management Act (FISMA) — The Federal Information Security
Management Act of 2002, a US Federal law that established information security standards for the
protection of economic and national security interests of the United States. It requires each federal
agency to develop, document, and implement an agency-wide program to provide information
security for the information and information systems that support the operations and assets of the
agency, including those provided or managed by another agency, contractor, or other source.
For Official Use Only (FOUO) — A caveat applied to unclassified sensitive information that
may be exempt from mandatory release to the public under the Freedom of Information Act
(FOIA), 5 U.S.C 522. In general, information marked FOUO shall not be disclosed to anybody
except Government (Federal, State, tribal, or local) employees or contractors with a need to know.
Full-feature Operating System — Full-feature operating systems are traditional operating
systems used by a standard desktop computer (e.g. Microsoft Windows, Apple OS X,
LINUX/UNIX, etc.). These operating systems are generally open to user control and configuration
and therefore require configuration management to properly secure, or “harden”, these devices
from malicious network based technical attacks (e.g. malware, spyware, hackers, etc.). These
operating systems require traditional protection applications such as antivirus programs and
personal firewalls.
Guest Operating System — An operating system that has emulated hardware presented to it by
a host operating system. Also referred to as the virtual machine (VM).
Host Operating System — In the context of virtualization, the operating system that interfaces
with the actual physical hardware and arbitrates between it and the guest operating systems. It is
also referred to as a hypervisor.
Hypervisor — See Host Operating System.
Identity History Data — Textual data that corresponds with an individual’s biometric data,
providing a history of criminal and/or civil events for the identified individual.
In-Band – The communication service channel (network connection, email, SMS text, phone call,
etc.) used to obtain an authenticator is the same as the one used for login.
Indirect Access – Having the authority to access systems containing CJI without providing the
user the ability to conduct transactional activities (the capability to query or update) on state and
national systems (e.g. CJIS Systems Agency (CSA), State Identification Bureau (SIB), or national
repositories).
Information — See data and CJI.
Information Exchange Agreement — An agreement that codifies the rules by which two parties
engage in the sharing of information. These agreements typically include language which
establishes some general duty-of-care over the other party’s information, whether and how it can
be further disseminated, penalties for violations, the laws governing the agreement (which
establishes venue), procedures for the handling of shared information at the termination of the
agreement, and so on. This document will ensure consistency with applicable federal laws,
directives, policies, regulations, standards and guidance.
Information Security Officer (ISO) — Typically a member of an organization who has the
responsibility to establish and maintain information security policy, assesses threats and
vulnerabilities, performs risk and control assessments, oversees the governance of security
operations, and establishes information security training and awareness programs. The ISO also
usually interfaces with security operations to manage implementation details and with auditors to
verify compliance to established policies.
Information System — A system of people, data, and processes, whether manual or automated,
established for the purpose of managing information.
Integrated Automated Fingerprint Identification System (IAFIS) — The national fingerprint
and criminal history system maintained by the FBI CJIS Division that provides the law
enforcement community with automated fingerprint search capabilities, latent searching
capability, electronic image storage, and electronic exchange of fingerprints and responses.

Integrity — The perceived consistency of expected outcomes, actions, values, and methods of an
individual or organization. As it relates to data, it is the concept that data is preserved in a
consistent and correct state for its intended use.
Interconnection Security Agreement (ISA) — An agreement much like an Information
Exchange Agreement as mentioned above, but concentrating more on formalizing the technical
and security requirements pertaining to some sort of interface between the parties’ information
systems.
Interface Agency — A legacy term used to describe agencies with direct connections to the
CSA. This term is now used predominantly in a common way to describe any sub-agency of a
CSA or SIB that leverages the CSA or SIB as a conduit to FBI CJIS information.
Internet Protocol (IP) — A protocol used for communicating data across a packet-switched
internetwork using the Internet Protocol Suite, also referred to as TCP/IP. IP is the primary
protocol in the Internet Layer of the Internet Protocol Suite and has the task of delivering
distinguished protocol datagrams (packets) from the source host to the destination host solely
based on their addresses.
Interstate Identification Index (III) — The CJIS service that manages automated submission
and requests for CHRI that is warehoused subsequent to the submission of fingerprint information.
Subsequent requests are directed to the originating State as needed.
Jailbreak (Jailbroken) — The process of attaining privileged control (known as “root access”)
of a device running the Apple iOS operating system that ultimately allows a user the ability to alter
or replace system applications and settings, run specialized applications that require administratorlevel permissions, or perform other operations that are otherwise not allowed.
Laptop Devices – Laptop devices are mobile devices with a full-featured operating system (e.g.
Microsoft Windows, Apple OS X, LINUX/UNIX, etc.). Laptops are typically intended for
transport via vehicle mount or portfolio-sized carry case, but not on the body. This definition does
not include pocket/handheld devices (e.g. smartphones), or mobile devices that feature a limited
feature operating system (e.g. tablets).
Law Enforcement Enterprise Portal (LEEP) — A secure, Internet-based communications
portal provided by the FBI CJIS Division for use by law enforcement, first responders, criminal
justice professionals, and anti-terrorism and intelligence agencies around the globe. Its primary
purpose is to provide a platform on which various law enforcement agencies can collaborate on
FOUO matters.
Limited-feature Operating System — Limited-feature operating systems are designed
specifically for the mobile environment where battery life and power efficiency are primary design
drivers (e.g. Apple iOS, Android, Windows RT/Phone, Blackberry OS, etc.). There operating
systems permit limited user control, but are inherently more resistant than a full-feature operating
system to certain types of network based technical attacks due to the limited feature sets. Devices
using these operating systems are required to be managed by a mobile device management
solution.
Logical Access – The technical means (e.g., read, create, modify, delete a file, execute a program,
or use an external connection) for an individual or other computer system to utilize CJI or CJIS
applications.

Logical Partitioning – When the host operating system, or hypervisor, allows multiple guest
operating systems to share the same physical resources.
Local Agency Security Officer (LASO) — The primary Information Security contact between a
local law enforcement agency and the CSA under which this agency interfaces with the FBI CJIS
Division. The LASO actively represents their agency in all matters pertaining to Information
Security, disseminates Information Security alerts and other material to their constituents,
maintains Information Security documentation (including system configuration data), assists with
Information Security audits of hardware and procedures, and keeps the CSA informed as to any
Information Security needs and problems.
Management Control Agreement (MCA) — An agreement between parties that wish to share
or pool resources that codifies precisely who has administrative control over, versus overall
management and legal responsibility for, assets covered under the agreement. An MCA must
ensure the CJA’s authority remains with regard to all aspects of Section 3.2.2. The MCA usually
results in the CJA having ultimate authority over the CJI supporting infrastructure administered
by the NCJA.
Mobile Device — Any portable device used to access CJI via a wireless connection (e.g. cellular,
WiFi, Bluetooth, etc.).
Mobile Device Management (MDM) — Centralized administration and control of mobile
devices specifically including, but not limited to, cellular phones, smart phones, and tablets.
Management typically includes the ability to configure device settings and prevent a user from
changing them, remotely locating a device in the event of theft or loss, and remotely locking or
wiping a device. Management can also include over-the-air distribution of applications and
updating installed applications.
Mobile (WiFi) Hotspot — A mobile (WiFi) hotspot is a zone or area associated with a mobile
device (e.g. smartphone, air card) allowing wireless connectivity to the Internet typically through
a cellular connection.
National Crime Information Center (NCIC) — An information system which stores CJI which
can be queried by appropriate Federal, state, and local law enforcement and other criminal justice
agencies.
National Instant Criminal Background Check System (NICS) — A system mandated by the
Brady Handgun Violence Prevention Act of 1993 that is used by Federal Firearms Licensees
(FFLs) to instantly determine via telephone or other electronic means whether the transfer of a
firearm would be in violation of Section 922 (g) or (n) of Title 18, United States Code, or state
law, by evaluating the prospective buyer’s criminal history.
National Institute of Standards and Technology (NIST) — Founded in 1901, NIST is a nonregulatory federal agency within the U.S. Department of Commerce whose mission is to promote
U.S. innovation and industrial competitiveness by advancing measurement science, standards, and
technology in ways that enhance economic and national security.
Noncriminal Justice Agency (NCJA) — A governmental agency, or any subunit thereof, that
provides services primarily for purposes other than the administration of criminal justice.
Examples of services include, but not limited to, employment suitability, licensing determinations,
immigration and naturalization matters, and national security clearances.

NCJA (Government) — A Federal, state, local, or tribal governmental agency or any subunit
thereof whose charter does not include the responsibility to administer criminal justice, but may
have a need to process CJI. An example would be the central IT organization within a state
government that administers equipment on behalf of a state law-enforcement agency.
NCJA (Private) — A private agency or subunit thereof whose charter does not include the
responsibility to administer criminal justice, but may have a need to process CJI. An example
would include a local bank.
NCJA (Public) — A public agency or sub-unit thereof whose charter does not include the
responsibility to administer criminal justice, but may have a need to process CJI. An example
would include a county school board which uses CHRI to assist in employee hiring decisions.
Noncriminal Justice Purpose — The uses of criminal history records for purposes authorized by
federal or state law other than purposes relating to the administration of criminal justice, including
employment suitability, licensing determinations, immigration and naturalization matters, and
national security clearances.
Office of Management and Budget (OMB) — The agency within the Executive Branch of the
Federal government responsible to oversee the preparation of the federal budget, to assist in the
supervision of other Executive Branch agencies, and to oversee and coordinate the Presidential
Administration’s procurement, financial management, information, and regulatory policies.
Out-of-Band — The communication service channel (network connection, email, SMS text,
phone call, etc.) used to obtain an authenticator is separate from that used for login.
Outsourcing — The process of delegating in-house operations to a third-party. For instance, when
the administration of criminal justice functions (network operations, dispatch functions, system
administration operations, etc.) are performed for the criminal justice agency by a city or county
information technology department or are contracted to be performed by a vendor.
Outsourcing Standard — National Crime Prevention and Privacy Compact Council’s
Outsourcing Standard. The Compact Council’s uniform standards and processes for the interstate
and Federal-State exchange of criminal history records for noncriminal justice purposes.
Partitioning – Managing guest operating system, or virtual machine, access to hardware so that
each guest OS can access its own resources but cannot encroach on the other guest operating
systems resources or any resources not allocated for virtualization use.
Personal Firewall — An application which controls network traffic to and from a computer,
permitting or denying communications based on a security policy.
Personally Identifiable Information (PII) — PII is information which can be used to distinguish
or trace an individual’s identity, such as name, social security number, or biometric records, alone
or when combined with other personal or identifying information which is linked or linkable to a
specific individual, such as date and place of birth, or mother’s maiden name.
Physical Access – The physical ability, right or privilege to view, modify or make use of Criminal
Justice Information (CJI) by means of physical presence within the proximity of computers and
network devices (e.g. the ability to insert a boot disk or other device into the system, make a
physical connection with electronic equipment, etc.).

Physical Media – Physical media refers to media in printed form. This definition includes, but is
not limited to, printed documents, printed imagery, printed facsimile.
Physical Partitioning – When the host operating system, or hypervisor, assigns separate physical
resources to each guest operating systems, or virtual machine.
Physically Secure Location — A facility, a criminal justice conveyance, or an area, a room, or a
group of rooms, within a facility with both the physical and personnel security controls sufficient
to protect CJI and associated information systems.
Pocket/Handheld Mobile Device – Pocket/Handheld mobile devices (e.g. smartphones) are
intended to be carried in a pocket or holster attached to the body and feature an operating system
with limited functionality (e.g., iOS, Android, BlackBerry, etc.). This definition does not include
tablet and laptop devices.
Property Data — Information about vehicles and property associated with a crime.
Rap Back — A NGI service that allows authorized agencies to receive notification of subsequent
criminal activity reported to the FBI committed by persons of interest.
Receive-Only Terminal (ROT) – A device that is configured to accept a limited type of data but
is technically prohibited from forming or transmitting data, browsing or navigating internal or
external networks, or otherwise performing outside the scope of receive only (e.g., a printer, dumb
terminal, etc.).
Repository Manager, or Chief Administrator — The designated manager of the agency having
oversight responsibility for a CSA’s fingerprint identification services. If both state fingerprint
identification services and CJIS systems control are managed within the same state agency, the
repository manager and CSO may be the same person.
Root (Rooting, Rooted) — The process of attaining privileged control (known as “root access”)
of a device running the Android operating system that ultimately allows a user the ability to alter
or replace system applications and settings, run specialized applications that require administratorlevel permissions, or perform other operations that are otherwise not allowed.
Secondary Dissemination — The promulgation of CJI from a releasing agency to an authorized
recipient agency when the recipient agency has not been previously identified in a formal
information exchange agreement.
Security Addendum (SA) — A uniform addendum to an agreement between the government
agency and a private contractor, approved by the Attorney General of the United States, which
specifically authorizes access to criminal history record information, limits the use of the
information to the purposes for which it is provided, ensures the security and confidentiality of the
information consistent with existing regulations and the CJIS Security Policy, provides for
sanctions, and contains such other provisions as the Attorney General may require.
Sensitive But Unclassified (SBU) — Designation of information in the United States federal
government that, though unclassified, often requires strict controls over its distribution. SBU is a
broad category of information that includes material covered by such designations as For Official
Use Only (FOUO), Law Enforcement Sensitive (LES), Sensitive Homeland Security Information,
Security Sensitive Information (SSI), Critical Infrastructure Information (CII), etc. Some
categories of SBU information have authority in statute or regulation (e.g. SSI, CII) while others,

including FOUO, do not. As of May 9, 2008, the more appropriate terminology to use is
Controlled Unclassified Information (CUI).
Server/Client Computer Certificate (device-based) – Digital certificates that are issued to
servers or client computers or devices by a CA and used to prove device identity between server
and/or client computer devices during the authentication process.
Service — The organized system of apparatus, appliances, personnel, etc, that supply some
tangible benefit to the consumers of this service. In the context of CJI, this usually refers to one
of the applications that can be used to process CJI.
Shredder — A device used for shredding documents, often as a security measure to prevent
unapproved persons from reading them. Strip-cut shredders, also known as straight-cut or
spaghetti-cut, slice the paper into long, thin strips but are not considered secure. Cross-cut
shredders provide more security by cutting paper vertically and horizontally into confetti-like
pieces.
Smartphone – See pocket/handheld mobile devices.
Social Engineering — The act of manipulating people into performing actions or divulging
confidential information. While similar to a confidence trick or simple fraud, the term typically
applies to trickery or deception for the purpose of information gathering, fraud, or computer system
access; in most cases the attacker never comes face-to-face with the victim.
Software Patch — A piece of software designed to fix problems with, or update, a computer
program or its supporting data. This includes fixing security vulnerabilities and other bugs and
improving the usability or performance. Though meant to fix problems, poorly designed patches
can sometimes introduce new problems. As such, patches should be installed in a test environment
prior to being installed in a live, operational system. Patches often can be found in multiple
locations but should be retrieved only from sources agreed upon through organizational policy.
State and Federal Agency User Agreement — A written agreement that each CSA or SIB Chief
shall execute with the FBI CJIS Division stating their willingness to demonstrate conformance
with the FBI CJIS Security Policy prior to the establishment of connectivity between
organizations. This agreement includes the standards and sanctions governing use of CJIS
systems, as well as verbiage to allow the FBI to periodically audit the CSA as well as to allow the
FBI to penetration test its own network from the CSA’s interfaces to it.
State Compact Officer — The representative of a state that is party to the National Crime
Prevention and Privacy Compact, and is the chief administrator of the state's criminal history
record repository or a designee of the chief administrator who is a regular full-time employee of
the repository.
State Identification Bureau (SIB) — The state agency with the responsibility for the state’s
fingerprint identification services.
State Identification Bureau (SIB) Chief — The SIB Chief is the designated manager of state’s
SIB. If both state fingerprint identification services and CJIS systems control are managed within
the same state agency, the SIB Chief and CSO may be the same person.
State of Residency – A state of residency is the state in which an individual claims and can provide
documented evidence as proof of being his/her permanent living domicile. CJIS Systems Officers
have the latitude to determine what documentation constitutes acceptable proof of residency.
System — Refer to connections to the FBI’s criminal justice information repositories and the
equipment used to establish said connections. In the context of CJI, this usually refers to
applications and all interconnecting infrastructure required to use those applications that process
CJI.
Tablet Devices – Tablet devices are mobile devices with a limited feature operating system (e.g.
iOS, Android, Windows RT, etc.). Tablets typically consist of a touch screen without a
permanently attached keyboard intended for transport via vehicle mount or portfolio-sized carry
case but not on the body. This definition does not include pocket/handheld devices (e.g.
smartphones) or mobile devices with full-featured operating systems (e.g. laptops).
Terminal Agency Coordinator (TAC) — Serves as the point-of-contact at the local agency for
matters relating to CJIS information access. A TAC administers CJIS systems programs within
the local agency and oversees the agency’s compliance with CJIS systems policies.
Wireless Access Point – A wireless access point is a device that logically connects a wireless
client device to an organization’s enterprise network which processes unencrypted CJI.
Wireless (WiFi) Hotspot – A wireless (WiFi) hotspot is a zone or area within a fixed location
allowing wireless connectivity to the Internet typically through a wired connection. Hotspots are
typically available in public areas such as airports, hotels and restaurants.
User Certificate (user-based) – Digital certificates that are unique and issued to individuals by a
CA. Though not always required to do so, these specific certificates are often embedded on smart
cards or other external devices as a means of distribution to specified users. This certificate is used
when individuals need to prove their identity during the authentication process.
Virtual Escort – Authorized personnel who actively monitor a remote maintenance session on
Criminal Justice Information (CJI)-processing systems. The escort must have the ability to end the
session at any time deemed necessary to ensure the protection and integrity of CJI at all times.
Virtual Machine (VM) – See Guest Operating System
Virtualization — Refers to a methodology of dividing the resources of a computer (hardware and
software) into multiple execution environments, by applying one or more concepts or technologies
such as hardware and software partitioning, time-sharing, partial or complete machine simulation
or emulation allowing multiple operating systems, or images, to run concurrently on the same
hardware.
Voice over Internet Protocol (VoIP) — A set of software, hardware, and standards designed to
make it possible to transmit voice over packet switched networks, either an internal Local Area
Network, or across the Internet.

APPENDIX B ACRONYMS
Acronym

Term

AA

Advanced Authentication

AC

Agency Coordinator

ACL

Access Control List

AES

Advanced Encryption Standard

AP

Access Point

APB

Advisory Policy Board

BD-ADDR

Bluetooth-Enabled Wireless Devices and Addresses

BYOD

Bring Your Own Device

CAD

Computer-Assisted Dispatch

CAU

CJIS Audit Unit

CFR

Code of Federal Regulations

CGA

Contracting Government Agency

CHRI

Criminal History Record Information

CJA

Criminal Justice Agency

CJI

Criminal Justice Information

CJIS

Criminal Justice Information Services

ConOps

Concept of Operations

CSA

CJIS Systems Agency

CSIRC

Computer Security Incident Response Capability

CSO

CJIS Systems Officer

DAA

Designated Approving Authority

DoJ

Department of Justice

DoJCERT

DoJ Computer Emergency Response Team

FBI

Federal Bureau of Investigation

FIPS

Federal Information Processing Standards

FISMA

Federal Information Security Management Act

FOIA

Freedom of Information Act

FOUO

For Official Use Only

HTTP

Hypertext Transfer Protocol

IAFIS

Integrated Automated Fingerprint Identification System

IDS

Intrusion Detection System

III

Interstate Identification Index

IP

Internet Protocol

IPS

Intrusion Prevention System

IPSEC

Internet Protocol Security

ISA

Interconnection Security Agreement

ISO

Information Security Officer

IT

Information Technology

LASO

Local Agency Security Officer

LEEP

Law Enforcement Enterprise Portal

LMR

Land Mobile Radio

MAC

Media Access Control

MCA

Management Control Agreement

MDM

Mobile Device Management

MITM

Man-in-the-Middle

MOU

Memorandum of Understanding

NCIC

National Crime Information Center

NCJA

Noncriminal Justice Agency

NICS

National Instant Criminal Background Check System

NIST

National Institute of Standards and Technology

OMB

Office of Management and Budget

ORI

Originating Agency Identifier

PBX

Private Branch Exchange

PDA

Personal Digital Assistant

PII

Personally Identifiable Information

PIN

Personal Identification Number

PKI

Public Key Infrastructure

POC

Point-of-Contact

PSTN

Public Switched Telephone Network

QA

Quality Assurance

QoS

Quality of Service

RF

Radio Frequency

SA

Security Addendum

SCO

State Compact Officer

SIB

State Identification Bureau

SIG

Special Interest Group

SP

Special Publication

SPRC

Security Policy Resource Center

SSID

Service Set Identifier

TAC

Terminal Agency Coordinator

TLS

Transport Layer Security

VLAN

Virtual Local Area Network

VM

Virtual Machine

VoIP

Voice Over Internet Protocol

VPN

Virtual Private Network

WEP

Wired Equivalent Privacy

WLAN

Wireless Local Area Network

WPA

Wi-Fi Protected Access

APPENDIX C NETWORK TOPOLOGY DIAGRAMS
Network diagrams, i.e. topological drawings, are an essential part of solid network security.
Through graphical illustration, a comprehensive network diagram provides the “big picture” –
enabling network managers to quickly ascertain the interconnecting nodes of a network for a
multitude of purposes, including troubleshooting and optimization. Network diagrams are integral
to demonstrating the manner in which each agency ensures criminal justice data is afforded
appropriate technical security protections and is protected during transit and at rest.
The following diagrams, labeled Appendix C.1-A through C.1-D, are examples for agencies to
utilize during the development, maintenance, and update stages of their own network diagrams.
By using these example drawings as a guideline, agencies can form the foundation for ensuring
compliance with Section 5.7.1.2 of the CJIS Security Policy.
The purpose for including the following diagrams in this Policy is to aid agencies in their
understanding of diagram expectations and should not be construed as a mandated method for
network topologies. It should also be noted that agencies are not required to use the identical icons
depicted in the example diagrams and should not construe any depiction of a particular vendor
product as an endorsement of that product by the FBI CJIS Division.
Appendix C.1-A is a conceptual overview of the various types of agencies that can be involved in
handling of CJI, and illustrates several ways in which these interconnections might occur. This
diagram is not intended to demonstrate the level of detail required for any given agency’s
documentation, but it provides the reader with some additional context through which to digest the
following diagrams. Take particular note of the types of network interfaces in use between
agencies, in some cases dedicated circuits with encryption mechanisms, and in other cases VPNs
over the Internet. This diagram attempts to show the level of diversity possible within the law
enforcement community. These diagrams in no way constitute a standard for network engineering,
but rather, for the expected quality of documentation.
The next three topology diagrams, C.1-B through C.1-D, depict conceptual agencies. For C.1-B
through C.1-D, the details identifying specific “moving parts” in the diagrams by manufacturer
and model are omitted, but it is expected that any agencies producing such documentation will
provide diagrams with full manufacturer and model detail for each element of the diagram. Note
that the quantities of clients should be documented in order to assist the auditor in understanding
the scale of assets and information being protected.
Appendix C.1-B depicts a conceptual state law enforcement agency’s network topology and
demonstrates a number of common technologies that are in use throughout the law enforcement
community (some of which are compulsory per CJIS policy, and some of which are optional)
including Mobile Broadband cards, VPNs, Firewalls, Intrusion Detection Devices, VLANs, and
so forth. Note that although most state agencies will likely have highly-available configurations,
the example diagram shown omits these complexities and only shows the “major moving parts”
for clarity but please note the Policy requires the logical location of all components be shown. The
level of detail depicted should provide the reader with a pattern to model future documentation
from, but should not be taken as network engineering guidance.
Appendix C.1-C depicts a conceptual county law enforcement agency. A number of common
technologies are presented merely to reflect the diversity in the community, including proprietary
Packet-over-RF infrastructures and advanced authentication techniques, and to demonstrate the
fact that agencies can act as proxies for other agencies.
Appendix C.1-D depicts a conceptual municipal law enforcement agency, presumably a small one
that lacks any precinct-to-patrol data communications. This represents one of the smallest designs
that could be assembled that, assuming all other details are properly considered, would meet the
criteria for Section 5.7.1.2. This diagram helps to demonstrate the diversity in size that agencies
handling criminal justice data exhibit.

Figure C-1-A Overview: Conceptual Connections Between Various Agencies

Overview: Conceptual Connections Between Various Agencies
State Law Enforcement (L.E.) Agency
State L.E.
Workstation

Web Server
w/ TLS

Firewall

CAD
CAD Client
Client

Encryption
Mechanism

Municipal
Core
Network

CAD
System

Extranet
Router

Internet
Router

Encryption
Mechanism

Large Municipal L.E. Agency 1

Small Municipal L.E. Agency 1

Internet

CAD Client w/
TLS Connector
Web App Hosted By
State Via VPN

Dedicated Circuit

Firewall
+ VPN

Internet
Router

Dedicated Circuit
Extranet
Router

Municipal L.E.
Workstation

Web
Web Browser
Browser

CAD Client w/
TLS Connector

Authentication
Server
State Core
Network

Web App Hosted By
State Via Private Circuit

CAD
CAD Client
Client

Municipal L.E.
Workstation
Municipal
Core
Network

Web
Web Browser
Browser

Internet
Router

Dedicated Circuit
Private
DialUp Pool

Firewall
+ VPN

Encryption
Mechanism

Border
Router

TLS Web App Hosted
By State Via Dial-Up
Encryption
Mechanism

Firewall
+ VPN
FBI / CJIS
Core Network
Extranet
Router

Cabinet Number

HKP

48V

GSP

Extranet
Router

HKP

48V

GSP

Remote
Attention

An CJIS
Information
System

CAD
System

FBI CJIS Division
FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION
TLS CONNECTION

Figure C-1-B Conceptual Topology Diagram for a State Law Enforcement Agency

Conceptual Topology Diagram For A State Law Enforcement Agency
Internet

Dedicated
Circuit To FBI

State WAN

Mobile
BroadBand
Card + Service

Squad Car
Laptop w/
Advanced
Authentication
(A.A.) (275)

Intrusion
Detection
Device

Intranet
Router

CAD
CAD Client
Client

VPN Tunnels Via
Internet To Counties /
Municipalities

Encryption
Mechanism

Router / Firewall / VPN,
FIPS 140-2 Compliant

Ethernet Switch
1

SYST
RPS
MASTR
STAT
DUPLX
SPEED

2

3

4

5

6

7

8

9

10

11

13

12

14

15

16

17

18

19

20

21

22

23

Catalyst 2960 SERIES

24

1X

11X

13X

23X

2X

12X

14X

24X

1

MODE

Web
Servers
VLAN

2

Law
Enforcement
Workstation
VLAN

State L.E.
Workstation
(125)
Other
Department
VLAN

General
Infrastructure
VLAN
A.A.
Authentication
Server

CAD System
with CJIS
Interface +128Bit TLS

Web
Web Browser
Browser

TLS Web
Server

CAD Client
w/ A.A.

Dedicated
Circuits To
Municipalities

Extranet
Router

VLAN
Membership
Through
VPN Via
Internet

FIPS 140-2
VPN Client

Dedicated
Circuits To
Counties

TLS Web
App.

Web
Web Browser
Browser

CAD
CAD Client
Client

Other
Department
Workstation (60)

Police Cruiser VLAN

TLS Web App.

CAD Client
State Law Enforcement Agency

FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION

Figure C-1-C Conceptual Topology Diagram for a County Law Enforcement Agency

Conceptual Topology Diagram For A County Law Enforcement Agency

Internet
Router

Dedicated
Circuits To
Municipalities

Dedicated
Circuit To
State

Internet

Intrusion
Detection
Device

Extranet
Router

VPN Tunnels To
Municipalities Via
Internet

Encryption
Mechanism
Router / Firewall / VPN,
FIPS 140-2 Compliant

Proprietary
Packet / RF
Card + Built-in
FIPS 140-2
Encryption

Packet / RF
Transcievers +
FIPS 140-2
Encryption

Ethernet Switch
1

SYST
RPS
MASTR
STAT
DUPLX
SPEED

2

3

4

5

6

7

8

9

10

11

13

12

14

15

16

17

18

19

20

23

Catalyst 2960 SERIES

24

13X

23X

14X

24X

1

2

Other
Department
VLAN

Police Cruiser VLAN
Web
Web Browser
Browser
Web
Web Browser
Browser

CAD Client
w/ A.A.

22

11X

12X

County L.E.
Workstation
(6)

Squad Car
Laptop w/
A.A. (4)

CAD
CAD Client
Client

21

1X

2X

MODE

Law
Enforcement
Workstation
VLAN

TLS Web App.
Hosted By State
+A.A.

TLS Web App.
Hosted By State

CAD
CAD Client
Client

General
Infrastructure
VLAN
A.A.
Authentication
Server

CAD System
with CJIS
Interface +128Bit TLS

Other
Department
Workstation (10)

CAD Client
County Law Enforcement Agency

FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION

Figure C-1-D Conceptual Topology Diagram for a Municipal Law Enforcement Agency

Conceptual Topology Diagram For A Municipal Law Enforcement Agency
Dedicated
Circuit To
State

Internet

Internet
Router

Extranet
Router

VPN Tunnels Via
Internet To County

Encryption
Mechanism
Router / Firewall / VPN,
FIPS 140-2 Compliant

Intrusion
Detection
Device

Ethernet Switch
1

Law
Enforcement
Workstation
VLAN

SYST
RPS
MASTR
STAT
DUPLX
SPEED

2

3

4

5

6

7

8

9

10

11

TLS Web App.
Hosted By State
+ A.A.

14

15

16

17

18

19

20

21

22

23

Catalyst 2960 SERIES

24

11X

13X

23X

12X

14X

24X

1

2

Other
Department
VLAN

Municipal L.E.
Workstation (3)

Web
Web Browser
Browser

13

12

1X

2X

MODE

Other
Department
Workstation (11)

CAD
CAD Client
Client

CAD Client to
County CAD
System + 128-bit
TLS +A.A.
Municipal Law Enforcement Agency

FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION

APPENDIX D SAMPLE INFORMATION EXCHANGE
AGREEMENTS
D.1 CJIS User Agreement
CRIMINAL JUSTICE INFORMATION SERVICES (CJIS)
SYSTEMS USER AGREEMENT
The FBI CJIS Division provides state-of-the-art identification and information services
to the local, state, tribal, federal, and international criminal justice communities, as well as the
noncriminal justice community, for licensing and employment purposes. These services are
administered and maintained by the FBI CJIS Division and managed in cooperation with the CJIS
Systems Agency (CSA) and its administrator for CJIS data, the CJIS Systems Officer (CSO). The
CJIS Systems include, but are not limited to: the Interstate Identification Index (III); National
Crime Information Center (NCIC); Uniform Crime Reporting (UCR), whether summary or
incident-based reporting to the National Incident-Based Reporting System; Fingerprint
Identification Record System; Law Enforcement National Data Exchange (N-DEx); Law
Enforcement Enterprise Portal; and the National Instant Criminal Background Check System
(NICS).
The FBI CJIS Division provides the following services to its users, as applicable:
1. Operational, technical, and investigative assistance.
2. Telecommunication lines to state, federal, and regulatory interfaces.
3. Legal and legislative review of matters pertaining to all CJIS Systems.
4. Timely information on all aspects of all CJIS Systems and other related programs by
means of operating manuals, code manuals, technical and operational updates, various
newsletters, information letters, frequently asked questions, and other relevant
documents.
5. Training assistance and up-to-date materials provided to each CSO, NICS Point of
Contact (POC), state Compact Officer, State Administrator, Information Security Officer
(ISO), and other appropriate personnel.
6. Ongoing assistance to Systems’ users through meetings and briefings with the CSOs,
State Administrators, Compact Officers, ISOs, and NICS State POCs to discuss
operational and policy issues.
7. Advisory Process through which authorized users have input as to the policies and
procedures governing the operation of CJIS programs.
8. National Crime Prevention and Privacy Compact Administrative Office through which
states and other authorized users may submit issues concerning the noncriminal justice
use of the III System.
9. Annual NICS Users Conference.
10. Audit.
11. Staff research assistance.
PART 1
The purpose behind a designated CSO is to unify responsibility for Systems user
discipline and to ensure adherence to established procedures and policies within each signatory
state/territory/tribal agency and by each federal user. This agreement outlines the responsibilities
of each CSO as they relate to all CJIS Systems and other related CJIS administered programs.
These individuals are ultimately responsible for planning necessary hardware, software, funding,
and training for access to all CJIS Systems.
To ensure continued access as set forth above, the CSA agrees to adhere to all
applicable CJIS policies including, but not limited to, the following:
1. The signatory state/tribal agency will provide fingerprints that meet submission criteria for
all qualifying arrests. In addition, states/tribal agencies will make their records available
for interstate exchange for criminal justice and other authorized purposes unless restricted
by state/tribal law, and, where applicable, continue to move toward participation in the III
and, upon ratification of the National Crime Prevention and Privacy Compact, the National
Fingerprint File.
2. Appropriate and reasonable quality assurance procedures; e.g., hit confirmation, audits for
record timeliness, and validation, must be in place to ensure that only complete, accurate,
and valid information is maintained in the CJIS Systems.
3. Biannual file synchronization of information entered into the III by participating states.
4. Security - Each agency is responsible for appropriate security measures as applicable to
physical security of terminals and telecommunication lines; personnel security to include
background screening requirements; technical security to protect against unauthorized use;
data security to include III use, dissemination, and logging; and security of criminal history
records. Additionally, each CSO must ensure that all agencies establish an information
security structure that provides for an ISO and complies with the CJIS Security Policy.
5. Audit - Each agency shall be responsible for complying with all audit requirements for use
of CJIS Systems. Each CSO is responsible for completing a triennial audit of all agencies
with access to CJIS Systems through the CSO’s lines.
6. Training - Each agency shall be responsible for training requirements, including
compliance with operator training mandates.
7. Integrity of the Systems - Each agency shall be responsible for maintaining the integrity of
the system in accordance with FBI CJIS Division/state/federal/tribal policies to ensure only
authorized terminal access; only authorized transaction submission; and proper handling
and dissemination of CJI. Each agency shall also be responsible for computer security
incident reporting as required by the CJIS Security Policy.
The following documents are incorporated by reference and made part of this
agreement for CSA users:
1. Bylaws for the CJIS Advisory Policy Board and Working Groups.
2. CJIS Security Policy.
3. Interstate Identification Index Operational and Technical Manual, National Fingerprint
File Operations Plan, NCIC 2000 Operating Manual, UCR Handbook-NIBRS Edition,
and National Incident-Based Reporting System Volumes 1, 2, and 4.
4. National Crime Prevention and Privacy Compact, 42 United States Code (U.S.C.)
§14616.
5. NCIC Standards and UCR Standards, as recommended by the CJIS Advisory Policy
Board.
6. The National Fingerprint File Qualification Requirements.
7. Title 28, Code of Federal Regulations, Parts 20 and 25, §50.12, and Chapter IX.
8. Electronic Fingerprint Transmission Specifications.

9. Other relevant documents, to include: NCIC Technical and Operational Updates, CJIS
Information Letters, NICS User Manual, NICS Interface Control Document.
10. Applicable federal, state, and tribal laws and regulations.
PART 2
Additionally, there are authorized federal regulatory recipients and other authorized
users that provide electronic fingerprint submissions through a CJIS Wide Area Network (WAN)
connection (or other approved form of electronic connection) to the CJIS Division that are required
to comply with the following CJIS policies:
1. The authorized user will provide fingerprints that meet submission criteria and apply
appropriate and reasonable quality assurance procedures.
2. Security - Each agency is responsible for appropriate security measures as applicable to
physical security of communication equipment; personnel security to include background
screening requirements; technical security to protect against unauthorized use; and security
of criminal history records.
3. Audit - Each authorized user shall be responsible for complying with all audit requirements
for CJIS Systems. Additionally, each authorized user is subject to a triennial audit by the
CJIS Division Audit staff.
4. Training - Each authorized user receiving criminal history record information shall be
responsible for training requirements, including compliance with proper handling of
criminal history records.
The following documents are incorporated by reference and made part of this
agreement for non-CSA authorized users:
1. CJIS Security Policy.
2. National Crime Prevention and Privacy Compact, 42 U.S.C. §14616.
3. Title 28, Code of Federal Regulations, Parts 20 and 25, § 50.12, and Chapter IX.
4. Other relevant documents, to include CJIS Information Letters.
5. Applicable federal, state, and tribal laws and regulations.
GENERAL PROVISIONS
Funding:
Unless otherwise agreed in writing, each party shall bear its own costs in relation to
this agreement. Expenditures will be subject to federal and state budgetary processes
and availability of funds pursuant to applicable laws and regulations. The parties
expressly acknowledge that this in no way implies that Congress will appropriate funds
for such expenditures.
Termination:
1. All activities of the parties under this agreement will be carried out in accordance to the
above-described provisions.
2. This agreement may be amended or terminated by the mutual written consent of the parties
authorized representatives.
3. Either party may terminate this agreement upon 30-days written notification to the other
party. Such notice will be the subject of immediate consultation by the parties to decide
upon the appropriate course of action. In the event of such termination, the following rules
apply:
a. The parties will continue participation, financial or otherwise, up to the effective
date of termination.
b. Each party will pay the costs it incurs as a result of termination.
c. All information and rights therein received under the provisions of this agreement
prior to the termination will be retained by the parties, subject to the provisions of
this agreement.

ACKNOWLEDGMENT AND CERTIFICATION
As a CSO or CJIS WAN Official (or other CJIS authorized official), I hereby
acknowledge the duties and responsibilities as set out in this agreement. I acknowledge that these
duties and responsibilities have been developed and approved by CJIS Systems users to ensure the
reliability, confidentiality, completeness, and accuracy of all information contained in, or obtained
by means of, the CJIS Systems. I further acknowledge that failure to comply with these duties and
responsibilities may result in the imposition of sanctions against the offending state/agency; other
federal, tribal, state, and local criminal justice users; and approved noncriminal justice users with
System access, whether direct or indirect. The Director of the FBI (or the National Crime
Prevention and Privacy Compact Council), may approve sanctions to include the termination of
CJIS services.
I hereby certify that I am familiar with all applicable documents that are made part of
this agreement and to all applicable federal and state laws and regulations relevant to the receipt
and dissemination of documents provided through the CJIS Systems.
This agreement is a formal expression of the purpose and intent of both parties and is
effective when signed. It may be amended by the deletion or modification of any provision
contained therein, or by the addition of new provisions, after written concurrence of both parties.
The “Acknowledgment and Certification” is being executed by the CSO or CJIS WAN Official
(or other CJIS authorized official) in both an individual and representative capacity.
Accordingly, this agreement will remain in effect after the CSO or CJIS WAN Official (or other
CJIS authorized official) vacates his/her position or until it is affirmatively amended or rescinded
in writing. This agreement does not confer, grant, or authorize any rights, privileges, or
obligations to any third party.

SYSTEMS USER AGREEMENT
Please execute either Part 1 or Part 2
PART 1
____________________________________

Date: ____________

CJIS Systems Officer
______________________________________________________________________________
Printed Name/Title
CONCURRENCE OF CSA HEAD:
____________________________________

Date: ____________

CSA Head
______________________________________________________________________________
Printed Name/Title
PART 2
____________________________________

Date: ____________

CJIS WAN Official (or other CJIS Authorized Official)
______________________________________________________________________________
Printed Name/Title
CONCURRENCE OF CJIS WAN AGENCY HEAD:
____________________________________

Date: ____________

CJIS WAN Agency Head
______________________________________________________________________________
Printed Name/Title

FBI CJIS DIVISION:
____________________________________

Date: ____________

[Name]
Assistant Director
FBI CJIS Division
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt strip-pages The FBI Designated Federal Officer should be notified when a CSO or other CJIS
WAN/authorized Official vacates his/her position. The name and telephone number of the
Acting CSO or other CJIS WAN/authorized Official, and when known, the name and telephone
number of the new CSO or other CJIS WAN/authorized Official, should be provided. Revised:
D.2 Management Control Agreement

Management Control Agreement
Pursuant to the CJIS Security Policy, it is agreed that with respect to administration of that
portion of computer systems and network infrastructure interfacing directly or indirectly with the
state network (Network Name) for the interstate exchange of criminal history/criminal justice
information, the (Criminal Justice Agency) shall have the authority, via managed control, to set,
maintain, and enforce:
(1) Priorities.
(2) Standards for the selection, supervision, and termination of personnel access to Criminal
Justice Information (CJI).
(3) Policy governing operation of justice systems, computers, access devices, circuits, hubs,
routers, firewalls, and any other components, including encryption, that comprise and
support a telecommunications network and related criminal justice systems to include but
not limited to criminal history record/criminal justice information, insofar as the
equipment is used to process or transmit criminal justice systems information
guaranteeing the priority, integrity, and availability of service needed by the criminal
justice community.
(4) Restriction of unauthorized personnel from access or use of equipment accessing the
State network.
(5) Compliance with all rules and regulations of the (Criminal Justice Agency) Policies and
CJIS Security Policy in the operation of all information received.
“…management control of the criminal justice function remains solely with the Criminal Justice
Agency.” Section 5.1.1.4
This agreement covers the overall supervision of all (Criminal Justice Agency) systems,
applications, equipment, systems design, programming, and operational procedures associated
with the development, implementation, and maintenance of any (Criminal Justice Agency) system
to include NCIC Programs that may be subsequently designed and/or implemented within the
(Criminal Justice Agency).

__________________
John Smith, CIO
Any State Department of Administration

_____________
Date

__________________
Joan Brown, CIO
(Criminal Justice Agency)

_____________
Date

D.3 Noncriminal Justice Agency Agreement & Memorandum of
Understanding
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE FEDERAL BUREAU OF INVESTIGATION
AND
(Insert Name of Requesting Organization)
FOR
THE ESTABLISHMENT AND ACCOMMODATION OF
THIRD-PARTY CONNECTIVITY TO THE
CRIMINAL JUSTICE INFORMATION SERVICES DIVISION'S WIDE AREA NETWORK

1. PURPOSE: This Memorandum of Understanding (MOU) between the Federal Bureau of
Investigation (FBI) and (insert requesting organization’s name), hereinafter referred to as the
"parties," memorializes each party's responsibilities with regard to establishing connectivity to
records services accessible via the Wide Area Network (WAN) of the FBI's Criminal Justice
Information Services (CJIS) Division.
2. BACKGROUND: The requesting organization, (insert requesting organization’s name),
being approved for access to systems of records accessible via the CJIS WAN, desires connectivity
to the CJIS WAN or via a secure Virtual Private Network (VPN) Connection (Internet) to the CJIS
WAN. The CJIS Division has created a framework for accommodating such requests based on the
type of connection.
In preparing for such non-CJIS-funded connectivity to the CJIS WAN, the parties plan to
acquire, configure, and place needed communications equipment at suitable sites and to make
electronic connections to the appropriate systems of records via the CJIS WAN.
To ensure that there is a clear understanding between the parties regarding their respective
roles in this process, this MOU memorializes each party's responsibilities regarding the
development, operation, and maintenance of third-party connectivity to the CJIS WAN. Unless
otherwise contained in an associated contract, the enclosed terms apply. If there is a conflict
between terms and provisions contained in both the contract and this MOU, the contract will
prevail.
3. AUTHORITY: The FBI is entering into this MOU under the authority provided by Title 28,
United States Code (U.S.C.), Section 534; 42 U.S.C. § 14616; and/or Title 28, Code of Federal
Regulations, Part 906.
4. SCOPE:
a. The CJIS Division agrees to:
i. Provide the requesting organization with a "CJIS WAN Third-Party Connectivity
Package" that will detail connectivity requirements and options compatible with the
CJIS Division's WAN architecture upon receipt of a signed nondisclosure
statement.
ii. Configure the requesting organization’s connection termination equipment suite
at Clarksburg, West Virginia, and prepare it for deployment or shipment under the
CJIS WAN option. In the Secure VPN arrangement only, the third party will
develop, configure, manage, and maintain its network connectivity to its preferred
service provider.
iii. Work with the requesting organization to install the connection termination
equipment suite and verify connectivity.
iv. Perform installation and/or routine maintenance on the requesting organization’s
third-party dedicated CJIS WAN connection termination equipment after
coordinating with the requesting organization’s designated point of contact (POC)
and during a time when the CJIS Division's technical personnel are near the
requesting organization’s site.
v. Perform periodic monitoring and troubleshooting of the requesting
organization’s CJIS WAN connection termination equipment. Software patches
will be maintained on the dedicated CJIS WAN connected network equipment only.
Under the Secure VPN option, no availability or data thru-put rates will be
guaranteed.
vi. Provide 24 hours a day, 7 days a week uninterrupted monitoring from the CJIS
Division’s Network Operations Center.
vii. Provide information regarding potential hardware end-of-life replacement
cycles to the requesting organization for its budgeting purposes.
viii. Maintain third-party dedicated CJIS WAN connection termination equipment
as if in the CJIS Division's operational environment.
ix. Update the appropriate software on the requesting organization’s dedicated
connection termination equipment connected to the CJIS WAN (i.e., Cisco
Internetwork Operating System, SafeNet frame relay encryptor firmware, etc.)
pursuant to the requesting organization's authorized maintenance contracts.
x. Provide a POC and telephone number for MOU-related issues.
b. The (insert requesting organization’s name) agrees to:
i. Coordinate requests for third-party connectivity to the CJIS WAN or the Secure
VPN with the CJIS Division's POC.
ii. Purchase hardware and software that are compatible with the CJIS WAN.
iii. Pay for the telecommunications infrastructure that supports its connection to the
CJIS WAN or Secure VPN.
iv. Maintain telecommunication infrastructure in support of Secure VPN
connectivity.
v. Provide any/all hardware and software replacements and upgrades as mutually
agreed to by the parties.
vi. Pay for all telecommunication requirements related to its connectivity.

vii. Provide required information for dedicated service relating to Data Link
Connection Identifiers, Circuit Identifier, Permanent Virtual Circuit Identifiers,
Local Exchange Carrier Identifier, POC, location, etc., as determined by the parties.
viii. Transport the CJIS WAN connection termination equipment suite to the CJIS
Division for configuration and preparation for deployment under the dedicated
service option.
ix. Provide registered Internet Protocol information to be used by the requesting
organization’s system to the CJIS Division.
x. Provide the CJIS Division with six months advance notice or stated amount of
time for testing activities (i.e., disaster recovery exercises).
xi. Provide the CJIS Division with applicable equipment maintenance contract
numbers and level of service verifications needed to perform software upgrades on
connection termination equipment.
xii. Provide the CJIS Division with applicable software upgrade and patch images
(or information allowing the CJIS Division to access such images).
xiii. Transport only official, authorized traffic over the Secure VPN.
xiv. Provide a POC and telephone number for MOU-related issues.
5. FUNDING: There are no reimbursable expenses associated with this level of support. Each
party will fund its own activities unless otherwise agreed to in writing. This MOU is not an
obligation or commitment of funds, nor a basis for transfer of funds, but rather is a basic statement
of understanding between the parties hereto of the nature of the relationship for the connectivity
efforts. Unless otherwise agreed to in writing, each party shall bear its own costs in relation to this
MOU. Expenditures by each party will be subject to its budgetary processes and to the availability
of funds and resources pursuant to applicable laws, regulations, and policies. The parties expressly
acknowledge that the above language in no way implies that Congress will appropriate funds for
such expenditures.
6. SETTLEMENT OF DISPUTES: Disagreements between the parties arising under or relating
to this MOU will be resolved only by consultation between the parties and will not be referred to
any other person or entity for settlement.
7. SECURITY: It is the intent of the parties that the actions carried out under this MOU will be
conducted at the unclassified level. No classified information will be provided or generated under
this MOU.
8. AMENDMENT, TERMINATION, ENTRY INTO FORCE, AND DURATION:
a. All activities of the parties under this MOU will be carried out in accordance with the
above - described provisions.
b. This MOU may be amended or terminated by the mutual written consent of the parties'
authorized representatives.
c. Either party may terminate this MOU upon 30-days written notification to the other
party. Such notice will be the subject of immediate consultation by the parties to decide
upon the appropriate course of action. In the event of such termination, the following rules
apply:
i. The parties will continue participation, financial or otherwise, up to the effective
date of the termination.
ii. Each party will pay the costs it incurs as a result of the termination.
iii. All information and rights therein received under the provisions of this MOU
prior to the termination will be retained by the parties, subject to the provisions of
this MOU.
9. FORCE AND EFFECT: This MOU, which consists of nine numbered sections, will enter into
effect upon signature of the parties and will remain in effect until terminated. The parties should
review the contents of this MOU annually to determine whether there is a need for the deletion,
addition, or amendment of any provision. This MOU is not intended, and should not be construed,
to create any right or benefit, substantive or procedural, enforceable at law or otherwise by any
third party against the parties, their parent agencies, the United States, or the officers, employees,
agents, or other associated personnel thereof.
The foregoing represents the understandings reached between the parties.

FOR THE FEDERAL BUREAU OF INVESTIGATION

________________________________

___________

[Name]

Date

Assistant Director
Criminal Justice Information Services Division

FOR THE (insert requesting organization name)

________________________________

___________

Date

D.4 Interagency Connection Agreement
CRIMINAL JUSTICE INFORMATION SERVICES (CJIS)
Wide Area Network (WAN) USER AGREEMENT
BY INTERIM REMOTE LATENT USERS
The responsibility of the FBI CJIS Division is to provide state-of-the-art
identification and information services to the local, state, federal, and international criminal justice
communities, as well as the civil community for licensing and employment purposes. The data
provided by the information systems administered and maintained by the FBI CJIS Division are
routed to and managed in cooperation with the designated interface agency official. This
information includes, but is not limited to, the Interstate Identification Index (III), National Crime
Information Center (NCIC), Uniform Crime Reporting (UCR)/National Incident-Based Reporting
System (NIBRS), and the Integrated Automated Fingerprint Identification System (IAFIS)
programs.
In order to fulfill this responsibility, the FBI CJIS Division provides the following
services to its users:
Operational, technical, and investigative assistance;
Telecommunications lines to local, state, federal and authorized interfaces;
Legal and legislative review of matters pertaining to IAFIS, CJIS WAN
and other related services;
Timely information on all aspects of IAFIS, CJIS WAN, and other related
programs by means of technical and operational updates, various
newsletters, and other relative documents;
Shared management through the CJIS Advisory Process and the Compact
Council;
Training assistance and up-to-date materials provided to each designated
agency official, and;
Audit.
The concept behind a designated interface agency official is to unify responsibility
for system user discipline and ensure adherence to system procedures and policies within each
interface agency. These individuals are ultimately responsible for planning necessary hardware,
software, funding, training, and the administration of policy and procedures including security and
integrity for complete access to CJIS related systems and CJIS WAN related data services by
authorized agencies.
The following documents and procedures are incorporated by reference and made
part of this agreement:
CJIS Security Policy;
Title 28, Code of Federal Regulations, Part 20;
Computer Incident Response Capability (CIRC);
Applicable federal and state laws and regulations.
To ensure continued access as set forth above, the designated interface agency agrees to adhere to
all CJIS policies, including, but not limited to, the following:
1. The signatory criminal agency will provide fingerprints for all qualifying arrests
either via electronic submission or fingerprint card that meet submission
criteria. In addition, the agency will make their records available for interstate
exchange for criminal justice and other authorized purposes.
2. The signatory civil agency with legislative authority will provide all qualifying
fingerprints via electronic submission or fingerprint card that meet submission
criteria.
3. Appropriate and reasonable quality assurance procedures must be in place to
ensure that only complete, accurate, and valid information is maintained in the
system.
4. Security - Each agency is responsible for appropriate security measures as
applicable to physical security of terminals and telecommunications lines;
Interim Distributed Imaging System (IDIS) equipment shall remain stand-alone
devices and be used only for authorized purposes; personnel security to meet
background screening requirements; technical security to protect against
unauthorized use; data security, dissemination, and logging for audit purposes;
and actual security of criminal history records. Additionally, each agency must
establish an information security structure that provides for an Information
Security Officer (ISO) or a security point of contact.
5. Audit - Each agency shall be responsible for complying with the appropriate audit
requirements.
6. Training - Each agency shall be responsible for training requirements, including
compliance with training mandates.
7. Integrity of the system shall be in accordance with FBI CJIS Division and
interface agency policies. Computer incident reporting shall be implemented.
Until states are able to provide remote latent connectivity to their respective latent
communities via a state WAN connection, the CJIS Division may provide direct connectivity to
IAFIS via a dial-up connection or through the Combined DNA Index System (CODIS) and/or
National Integrated Ballistics Information Network (NIBIN) connections. When a state
implements a latent management system and is able to provide intrastate connectivity and
subsequent forwarding to IAFIS, this agreement may be terminated. Such termination notice will
be provided in writing by either the FBI or the state CJIS Systems Agency.
It is the responsibility of the local remote latent user to develop or acquire an IAFIS
compatible workstation. These workstations may use the software provided by the FBI or develop
their own software, provided it is IAFIS compliant.
The CJIS Division will provide the approved modem and encryptors required for
each dial-up connection to IAFIS. The CJIS Communication Technologies Unit will configure
and test the encryptors before they are provided to the user. Users requesting remote latent
connectivity through an existing CODIS and/or NIBIN connection must receive verification from
the FBI that there are a sufficient number of Ethernet ports on the router to accommodate the
request.
If at any time search limits are imposed by the CJIS Division, these individual
agency connections will be counted toward the total state allotment.

ACKNOWLEDGMENT AND CERTIFICATION
As a CJIS WAN interface agency official serving in the CJIS system, I hereby
acknowledge the duties and responsibilities as set out in this agreement. I acknowledge that these
duties and responsibilities have been developed and approved by CJIS system users in order to
ensure the reliability, confidentiality, completeness, and accuracy of all information contained in
or obtained by means of the CJIS system. I further acknowledge that a failure to comply with
these duties and responsibilities may subject our agency to various sanctions adopted by the CJIS
Advisory Policy Board and approved by the Director of the FBI. These sanctions may include the
termination of CJIS service.
As the designated CJIS WAN interface agency official serving in the CJIS system,
I hereby certify that I am familiar with the contents of the Title 28, Code of Federal Regulations,
Part 20; CJIS Security Policy; Computer Incident Response Capability; and applicable federal or
state laws and regulations applied to IAFIS and CJIS WAN Programs for the dissemination of
criminal history records for criminal and noncriminal justice purposes.
*___________________________________ ______________________________
Signature

CJIS WAN Agency Official

Print or Type

Date

CONCURRENCE OF FEDERAL/REGULATORY AGENCY HEAD OR STATE
CJIS SYSTEMS OFFICER (CSO):
*____________________________________
Signature
*____________________________________
Title

______________________________
Print or Type
__________
Date

State CSO

FBI CJIS DIVISION:
____________________________________
Signature – [Name]
Assistant Director

__________

Title

Date

CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt strip-pages If there is a change in the CJIS WAN interface agency official, the FBI Designated Federal
Employee must be notified in writing 30 days prior to the change.
5/27/2004 UA modification reflects change in CTO title to CSO.

APPENDIX E SECURITY FORUMS AND ORGANIZATIONAL
ENTITIES
Online Security Forums / Organizational Entities
AntiOnline
Black Hat
CIO.com
CSO Online
CyberSpeak Podcast
FBI Criminal Justice Information Services Division (CJIS)
Forrester Security Forum
Forum of Incident Response and Security Teams (FIRST)
Information Security Forum (ISF)
Information Systems Audit and Control Association (ISACA)
Information Systems Security Association (ISSA)
Infosyssec
International Organization for Standardization (ISO)
International Information Systems Security Certification Consortium, Inc. (ISC) 2
Metasploit
Microsoft Developer Network (MSDN) Information Security
National Institute of Standards and Technology (NIST)
Open Web Application Security Project (OWASP)
SANS (SysAdmin, Audit, Network, Security) Institute
SC Magazine
Schneier.com
Security Focus
The Register
US Computer Emergency Response Team (CERT)
US DoJ Computer Crime and Intellectual Property Section (CCIPS)

APPENDIX F

SAMPLE FORMS

This appendix contains sample forms.

F.1 Security Incident Response Form
FBI CJIS DIVISION
INFORMATION SECURITY OFFICER (ISO)
SECURITY INCIDENT REPORTING FORM
NAME OF PERSON REPORTING THE INCIDENT: ______________________________
DATE OF REPORT: ____________________________ (mm/dd/yyyy)
DATE OF INCIDENT: __________________________ (mm/dd/yyyy)
POINT(S) OF CONTACT (Include Phone/Extension/Email): _________________________
___________________________________________________________________________
LOCATION(S) OF INCIDENT: ________________________________________________
INCIDENT DESCRIPTION: ___________________________________________________
___________________________________________________________________________
SYSTEM(S) AFFECTED: _____________________________________________________
___________________________________________________________________________
SYSTEM(S) AFFECTED (e.g. CAD, RMS, file server, etc.): ____________
___________________________________________________________________________
METHOD OF DETECTION: ___________________________________________________
ACTIONS TAKEN/RESOLUTION: _____________________________________________
___________________________________________________________________________
___________________________________________________________________________
Copies To:
George White

John C. Weatherly

(FBI CJIS Division ISO)

(FBI CJIS CSIRC POC)

1000 Custer Hollow Road

1000 Custer Hollow Road/Module D-2

Clarksburg, WV 26306-0102

Clarksburg, WV 26306-0102

(304) 625-5849

(304) 625-3660

[email protected]

[email protected]

APPENDIX G BEST PRACTICES
G.1 Virtualization
Virtualization
This appendix documents security considerations for implementing and operating virtual
environments that process, store, and/or transmit Criminal Justice Information.
The FBI CJIS ISO has fielded several inquiries from various states requesting guidance on
implementing virtual environments within their data centers. With the proliferation of virtual
environments across industry in general there is a realistic expectation that FBI CJIS Auditors will
encounter virtual environments during the upcoming year. Criminal Justice Agencies (CJAs) and
Noncriminal Justice Agencies (NCJAs) alike need to understand and appreciate the foundation of
security protection measures required for virtual environments.
From Microsoft’s Introduction to Windows Server 2008
http://www.microsoft.com/windowsserver2008/en/us/hyperv.aspx:
“Server virtualization, also known as hardware virtualization, is a hot topic in the
IT world because of the potential for serious economic benefits. Server
virtualization enables multiple operating systems to run on a single physical
machine as virtual machines (VMs). With server virtualization, you can consolidate
workloads across multiple underutilized server machines onto a smaller number of
machines. Fewer physical machines can lead to reduced costs through lower
hardware, energy, and management overhead, plus the creation of a more dynamic
IT infrastructure.”
From a trade publication, kernelthread.com
http://www.kernelthread.com/publications/virtualization/:
“Virtualization is a framework or methodology of dividing the resources of a
computer into multiple execution environments, by applying one or more concepts
or technologies such as hardware and software partitioning, time-sharing, partial
or complete machine simulation, emulation, quality of service, and many others.”
From an Open Source Software developer
http://www.kallasoft.com/pc-hardware-virtualization-basics/:
“Virtualization refers to virtualizing hardware in software, allowing multiple
operating systems, or images, to run concurrently on the same hardware. There are
two main types of virtualization software:
“Type-1 Hypervisor, which runs ‘bare-metal’ (on top of the hardware)
“Type-2 Hypervisor which requires a separate application to run within an
operating system

“Type1 hypervisors usually offer the best in efficiency, while Type-2 hypervisors
allow for greater support of hardware that can be provided by the operating system.
For the developer, power user, and small business IT professionals, virtualization
offers the same basic idea of collapsing multiple physical boxes into one. For
instance, a small business can run a web server and an Exchange server without
the need for two boxes. Developers and power users can use the ability to contain
different development environments without the need to modify their main
operating system. Big businesses can also benefit from virtualization by allowing
software maintenance to be run and tested on a separate image on hardware
without having to take down the main production system.”
Industry leaders and niche developers are bringing more products to market every day. The
following article excerpts, all posted during September 2008, on www.virtualization.com are
examples of industry offerings.
“Microsoft and Novell partnered together for joint virtualization solution.
Microsoft and Novell are announcing the availability of a joint virtualization
solution optimized for customers running mixed-source environments. The joint
offering includes SUSE Linux Enterprise Server configured and tested as an
optimized guest operating system running on Windows Sever 2008 Hyper-V, and is
fully support by both companies’ channel partners. The offering provides
customers with the first complete, fully supported and optimized virtualization
solution to span Windows and Linux environments.”
“Sun Microsystems today account the availability of Sun xVM Server software and
Sun xVM Ops Center 2.0, key components in its strategy. Sun also announced the
addition of comprehensive services and support for Sun xVM Server software and
xVM Ops Center 2.0 to its virtualization suite of services. Additionally, Sun
launched xVMserver.org, a new open source community, where developers can
download the first source code bundle for SunxVM Server software and contribute
to the direction and development of the product.”
“NetEx, specialist in high-speed data transport over TCP, today announced Vistual
HyperIP bandwidth optimization solutions for VMware environments that deliver
a threefold to tenfold increase in data replication performance. Virtual HyperIP is
a software-based Data Transport Optimizer that operates on the VMware ESX
server and boosts the performance of storage replication applications from vendors
such as EMC, NetApp, Symantec, IBM, Data Domain, and FalconStor. Virtual
HyperIP mitigates TCP performance issues that are common when moving data
over wide –area network (WAN) connections because of bandwidth restrictions,
latency due to distance and/or router hop counts, packet loss and network errors.
Like the company’s award-winning appliance-based HyperIP, Virtual HyperIP
eliminates these issues with an innovative software design developed specifically
to accelerate traffic over an IP based network.”
From several sources, particularly:
http://www.windowsecurity.com/articles/security-virutalization.html
http://csrc.nist.gov/publications/drafts/6--=64rev2/draft-sp800-64-Revision2.pdf
Virtualization provides several benefits:
Make better use of under-utilized servers by consolidating to fewer machines saving on
hardware, environmental costs, management, and administration of the server
infrastructure.
Legacy applications unable to run on newer hardware and/or operating systems can be
loaded into a virtual environment – replicating the legacy environment.
Provides for isolated portions of a server where trusted and untrusted applications can be
ran simultaneously – enabling hot standbys for failover.
Enables existing operating systems to run on shared memory multiprocessors.
System migration, backup, and recovery are easier and more manageable.
Virtualization also introduces several vulnerabilities:
Host Dependent.
If the host machine has a problem then all the VMs could potentially terminate.
Compromise of the host makes it possible to take down the client servers hosted on the
primary host machine.
If the virtual network is compromised then the client is also compromised.
Client share and host share can be exploited on both instances. Potentially this can lead to
files being copied to the share that fill up the drive.
These vulnerabilities can be mitigated by the following factors:
Apply “least privilege” technique to reduce the attack surface area of the virtual
environment and access to the physical environment.
Configuration and patch management of the virtual machine and host, i.e. Keep operating
systems and application patches up to date on both virtual machines and hosts.
Install the minimum applications needed on host machines.
Practice isolation from host and virtual machine.
Install and keep updated antivirus on virtual machines and the host.
Segregation of administrative duties for host and versions.
Audit logging as well as exporting and storing the logs outside the virtual environment.
Encrypting network traffic between the virtual machine and host IDS and IPS monitoring.
Firewall each virtual machine from each other and ensure that only allowed protocols will
transact.

G.2 Voice over Internet Protocol

Voice over Internet Protocol (VoIP)

Attribution:
The following information has been extracted from NIST Special Publication 800-58, Security
Considerations for Voice over IP Systems.
Definitions:
Voice over Internet Protocol (VoIP) – A set of software, hardware, and standards designed to make
it possible to transmit voice over packet switched networks, either an internal Local Area Network,
or across the Internet.
Internet Protocol (IP) - A protocol used for communicating data across a packet-switched
internetwork using the Internet Protocol Suite, also referred to as TCP/IP. IP is the primary
protocol in the Internet Layer of the Internet Protocol Suite and has the task of delivering
distinguished protocol datagrams (packets) from the source host to the destination host solely
based on their addresses.
Summary:
Voice over Internet Protocol (VoIP) has been embraced by organizations globally as an
addition to, or replacement for, public switched telephone network (PSTN) and private branch
exchange (PBX) telephone systems. The immediate benefits are alluring since the typical cost
to operate VoIP is less than traditional telephone services and VoIP can be installed in-line
with an organization’s existing Internet Protocol services. Unfortunately, installing a VoIP
network is not a simple “plug-and-play” procedure. There are myriad security concerns, cost
issues with new networking hardware requirements, and overarching quality of service (QoS)
factors that have to be considered carefully.
What are some of the advantages of VoIP?
a. Cost – a VoIP system is usually cheaper to operate than an equivalent office telephone
system with a Private Branch Exchange and conventional telephone service.
b. Integration with other services – innovative services are emerging that allow customers
to combine web access with telephone features through a single PC or terminal. For
example, a sales representative could discuss products with a customer using the
company’s web site. In addition, the VoIP system may be integrated with video across
the Internet, providing a teleconferencing facility.
What are some of the disadvantages of VoIP?
a. Startup cost – although VoIP can be expected to save money in the long run, the
initial installation can be complex and expensive. In addition, a single standard has
not yet emerged for many aspects of VoIP, so an organization must plan to support
more than one standard, or expect to make relatively frequent changes as the VoIP
field develops.
b. Security – the flexibility of VoIP comes at a price: added complexity in securing
voice and data. Because VoIP systems are connected to the data network, and share
many of the same hardware and software components, there are more ways for
intruders to attack a VoIP system than a conventional voice telephone system or
PBX.
VoIP Risks, Threats, and Vulnerabilities
This section details some of the potential threats and vulnerabilities in a VoIP environment,
including vulnerabilities of both VoIP phones and switches. Threat discussion is included
because the varieties of threats faced by an organization determine the priorities in securing
its communications equipment. Not all threats are present in all organizations. A
commercial firm may be concerned primarily with toll fraud, while a government agency
may need to prevent disclosure of sensitive information because of privacy or national
security concerns. Information security risks can be broadly categorized into the following
three types: confidentiality, integrity, and availability, (which can be remembered with the
mnemonic “CIA”). Additional risks relevant to switches are fraud and risk of physical
damage to the switch, physical network, or telephone extensions.
Packet networks depend for their successful operation on a large number of configurable
parameters: IP and MAC (physical) addresses of voice terminals, addresses of routers and
firewalls, and VoIP specific software such as Call Managers and other programs used to
place and route calls. Many of these network parameters are established dynamically every
time a network component is restarted, or when a VoIP telephone is restarted or added to
the network. Because there are so many places in a network with dynamically configurable
parameters, intruders have a wide array of potentially vulnerable points to attack.
Vulnerabilities described in this section are generic and may not apply to all systems, but
investigations by NIST and other organizations have found these vulnerabilities in a
number of VoIP systems. In addition, this list is not exhaustive; systems may have security
weaknesses that are not included in the list. For each potential vulnerability, a
recommendation is included to eliminate or reduce the risk of compromise.
Confidentiality and Privacy

Confidentiality refers to the need to keep information secure and private. For home
computer users, this category includes confidential memoranda, financial information, and
security information such as passwords. In a telecommunications switch, eavesdropping
on conversations is an obvious concern, but the confidentiality of other information on the
switch must be protected to defend against toll fraud, voice and data interception, and
denial of service attacks. Network IP addresses, operating system type, telephone extension
to IP address mappings, and communication protocols are all examples of information that,
while not critical as individual pieces of data, can make an attacker’s job easier
With conventional telephones, eavesdropping usually requires either physical access to tap
a line, or penetration of a switch. Attempting physical access increases the intruder’s risk
of being discovered, and conventional PBXs have fewer points of access than VoIP
systems. With VoIP, opportunities for eavesdroppers increase dramatically, because of the
many nodes in a packet network.
Switch Default Password Vulnerability
It is common for switches to have a default login/password set, e.g., admin/admin, or root
/root. This vulnerability also allows for wiretapping conversations on the network with port
mirroring or bridging. An attacker with access to the switch administrative interface can
mirror all packets on one port to another, allowing the indirect and unnoticeable
interception of all communications. Failing to change default passwords is one of the most
common errors made by inexperienced users.
REMEDIATION: If possible, remote access to the graphical user interface should be
disabled to prevent the interception of plaintext administration sessions. Some devices
provide the option of a direct USB connection in addition to remote access through a web
browser interface. Disabling port mirroring on the switch should also be considered.
Classical Wiretap Vulnerability
Attaching a packet capture tool or protocol analyzer to the VoIP network segment makes
it easy to intercept voice traffic.
REMEDIATION: A good physical security policy for the deployment environment is a
general first step to maintaining confidentiality. Disabling the hubs on IP Phones as well
as developing an alarm system for notifying the administrator when an IP Phone has been
disconnected will allow for the possible detection of this kind of attack.
ARP Cache Poisoning and ARP Floods
Because many systems have little authentication, an intruder may be able to log onto a
computer on the VoIP network segment, and then send ARP commands corrupting ARP
caches on sender(s) of desired traffic, then activate IP. An ARP flood attack on the switch
could render the network vulnerable to conversation eavesdropping. Broadcasting ARP
replies blind is sufficient to corrupt many ARP caches. Corrupting the ARP cache makes
it possible to re-route traffic to intercept voice and data traffic.
REMEDIATION: Use authentication mechanisms wherever possible and limit physical
access to the VoIP network segment.
Web Server interfaces
Both VoIP switches and voice terminals are likely to have a web server interface for remote
or local administration. An attacker may be able to sniff plaintext HTTP packets to gain
confidential information. This would require access to the local network on which the
server resides.

REMEDIATION: If possible, do not use an HTTP server. If it is necessary to use a web
server for remote administration, use the more secure HTTPS (HTTP over SSL or TLS)
protocol.
IP Phone Netmask Vulnerability
A similar effect of the ARP Cache Vulnerability can be achieved by assigning a subnet
mask and router address to the phone crafted to cause most or all of the packets it transmits
to be sent to an attacker’s MAC address. Again, standard IP forwarding makes the intrusion
all but undetectable.
REMEDIATION: A firewall filtering mechanism can reduce the probability of this attack.
Remote access to IP phones is a severe risk.
Extension to IP Address Mapping Vulnerability
Discovering the IP address corresponding to any extension requires only calling that
extension and getting an answer. A protocol analyzer or packet capture tool attached to
the hub on the dialing instrument will see packets directly from the target instrument once
the call is answered. Knowing the IP address of a particular extension is not a
compromise in itself, but makes it easier to accomplish other attacks. For example, if the
attacker is able to sniff packets on the local network used by the switch, it will be easy to
pick out packets sent and received by a target phone. Without knowledge of the IP
address of the target phone, the attacker’s job may be much more difficult to accomplish
and require much longer, possibly resulting in the attack being discovered.
REMEDIATION: Disabling the hub on the IP Phone will prevent this kind of attack.
However, it is a rather simple task to turn the hub back on.
Integrity Issues
Integrity of information means that information remains unaltered by unauthorized users.
For example, most users want to ensure that bank account numbers cannot be changed by
anyone else, or that passwords are changed only by the user or an authorized security
administrator. Telecommunication switches must protect the integrity of their system data
and configuration. Because of the richness of feature sets available on switches, an attacker
who can compromise the system configuration can accomplish nearly any other goal. For
example, an ordinary extension could be re-assigned into a pool of phones that supervisors
can listen in on or record conversations for quality control purposes. Damaging or deleting
information about the IP network used by a VoIP switch results in an immediate denial of
service.
The security system itself provides the capabilities for system abuse and misuse. That is,
compromise of the security system not only allows system abuse but also allows the
elimination of all traceability and the insertion of trapdoors for intruders to use on their
next visit. For this reason, the security system must be carefully protected. Integrity threats
include any in which system functions or data may be corrupted, either accidentally or as
a result of malicious actions. Misuse may involve legitimate users (i.e. insiders performing
unauthorized operations) or intruders.
A legitimate user may perform an incorrect, or unauthorized, operations function (e.g., by
mistake or out of malice) and may cause deleterious modification, destruction, deletion, or
disclosure of switch software and data. This threat may be caused by several factors
including the possibility that the level of access permission granted to the user is higher
than what the user needs to remain functional.
Intrusion - An intruder may masquerade as a legitimate user and access an operations port of
the switch. There are a number of serious intrusion threats. For example, the intruder may use
the permission level of the legitimate user and perform damaging operations functions such as:

Disclosing confidential data
Causing service deterioration by modifying the switch software
Crashing the switch
Removing all traces of the intrusion (e.g., modifying the security log) so that it
may not be readily detected
Insecure state - At certain times the switch may be vulnerable due to the fact that it is not
in a secure state. For example:
After a system restart, the old security features may have been reset to insecure
settings, and new features may not yet be activated. (For example, all old
passwords may have reverted to the default system-password, even though new
passwords are not yet assigned.) The same may happen at the time of a disaster
recovery.
At the time of installation the switch may be vulnerable until the default security
features have been replaced.
DHCP Server Insertion Attack
It is often possible to change the configuration of a target phone by exploiting the DHCP
response race when the IP phone boots. As soon as the IP phone requests a DHCP response,
a rogue DHCP server can initiate a response with data fields containing false information.
This attack allows for possible man in the middle attacks on the IP-media gateway, and IP
Phones. Many methods exist with the potential to reboot the phone remotely, e.g. “social
engineering”, ping flood, MAC spoofing (probably SNMP hooks, etc.).
REMEDIATION: If possible, use static IP addresses for the IP Phones. This will remove
the necessity of using a DHCP server. Further, using a state based intrusion detection
system can filter out DHCP server packets from IP Phone ports, allowing this traffic only
from the legitimate server.
TFTP Server Insertion Attack
It is possible to change the configuration of a target phone by exploiting the TFTP
response race when the IP phone is resetting. A rogue TFTP server can supply spurious
information before the legitimate server is able to respond to a request. This attack allows
an attacker to change the configuration of an IP Phone.
REMEDIATION: Using a state based intrusion detection system can filter out DHCP
server packets from IP Phone ports, allowing such traffic only from the legitimate server.
Organizations looking to deploy VoIP systems should look for IP Phone instruments that
can download signed binary files.
Availability and Denial of Service
Availability refers to the notion that information and services be available for use when
needed. Availability is the most obvious risk for a switch. Attacks exploiting vulnerabilities
in the switch software or protocols may lead to deterioration or even denial of service or
functionality of the switch. For example: if unauthorized access can be established to any
branch of the communication channel (such as a CCS link or a TCP/IP link), it may be
possible to flood the link with bogus messages causing severe deterioration (possibly
denial) of service. A voice over IP system may have additional vulnerabilities with Internet
connections. Because intrusion detection systems fail to intercept a significant percentage
of Internet based attacks, attackers may be able to bring down VoIP systems by exploiting
weaknesses in Internet protocols and services.
Any network may be vulnerable to denial of service attacks, simply by overloading the
capacity of the system. With VoIP the problem may be especially severe, because of its
sensitivity to packet loss or delay.
CPU Resource Consumption Attack without any account information.
An attacker with remote terminal access to the server may be able to force a system
restart (shutdown all/restart all) by providing the maximum number of characters for the
login and password buffers multiple times in succession. Additionally, IP Phones may
reboot as a result of this attack.
In addition to producing a system outage, the restart may not restore uncommitted
changes or, in some cases, may restore default passwords, which would introduce
intrusion vulnerabilities.
REMEDIATION: The deployment of a firewall disallowing connections from
unnecessary or unknown network entities is the first step to overcoming this problem.
However, there is still the opportunity for an attacker to spoof his MAC and IP address,
circumventing the firewall protection.
Default Password Vulnerability
It is common for switches to have a default login/password set, e.g., admin/admin, or root
/root. Similarly, VoIP telephones often have default keypad sequences that can be used to
unlock and modify network information

This vulnerability would allow an attacker to control the topology of the network remotely,
allowing for not only complete denial of service to the network, but also a port mirroring
attack to the attacker’s location, giving the ability to intercept any other conversations
taking place over the same switch. Further, the switch may have a web server interface,
providing an attacker with the ability to disrupt the network without advance knowledge
of switch operations and commands. In most systems, telephones download their
configuration data on startup using TFTP or similar protocols. The configuration specifies
the IP addresses for Call Manager nodes, so an attacker could substitute another IP address
pointing to a call manager that would allow eavesdropping or traffic analysis.
REMEDIATION: Changing the default password is crucial. Moreover, the graphical user
interface should be disabled to prevent the interception of plaintext administration sessions.
Exploitable software flaws
Like other types of software, VoIP systems have been found to have vulnerabilities due
to buffer overflows and improper packet header handling. These flaws typically occur
because the software is not validating critical information properly. For example, a short
integer may be used as a table index without checking whether the parameter passed to
the function exceeds 32,767, resulting in invalid memory accesses or crashing of the
system.
Exploitable software flaws typically result in two types of vulnerabilities: denial of
service or revelation of critical system parameters. Denial of service can often be
implemented remotely, by passing packets with specially constructed headers that cause
the software to fail. In some cases the system can be crashed, producing a memory dump
in which an intruder can find IP addresses of critical system nodes, passwords, or other
security-relevant information. In addition, buffer overflows that allow the introduction of
malicious code have been found in VoIP software, as in other applications.
REMEDIATION: These problems require action from the software vendor, and
distribution of patches to administrators. Intruders monitor announcements of
vulnerabilities, knowing that many organizations require days or weeks to update their
software. Regular checking for software updates and patches is essential to reducing these
vulnerabilities. Automated patch handling can assist in reducing the window of
opportunity for intruders to exploit known software vulnerabilities.
Account Lockout Vulnerability
An attacker will be able to provide several incorrect login attempts at the telnet prompt
until the account becomes locked out. (This problem is common to most passwordprotected systems, because it prevents attackers from repeating login attempts until the
correct password is found by trying all possible combinations.)
The account is unable to connect to the machine for the set lockout time.
REMEDIATION: If remote access is not available, this problem can be solved with
physical access control.
NIST Recommendations.

Because of the integration of voice and data in a single network, establishing a secure VoIP
and data network is a complex process that requires greater effort than that required for
data-only networks. In particular, start with these general guidelines, recognizing that
practical considerations, such as cost or legal requirements, may require adjustments for
the organization:
1. Develop appropriate network architecture.
Separate voice and data on logically different networks if feasible. Different
subnets with separate RFC 1918 address blocks should be used for voice and data
traffic, with separate DHCP servers for each, to ease the incorporation of intrusion
detection and VoIP firewall protection at the voice gateway, which interfaces with
the PSTN, disallow H.323, SIP, or other VoIP protocols from the data network.
Use strong authentication and access control on the voice gateway system, as with
any other critical network component. Strong authentication of clients towards a
gateway often presents difficulties, particularly in key management. Here, access
control mechanisms and policy enforcement may help.
A mechanism to allow VoIP traffic through firewalls is required. There are a
variety of protocol dependent and independent solutions, including application
level gateways (ALGs) for VoIP protocols, Session Border Controllers, or other
standards-based solutions when they mature.
Stateful packet filters can track the state of connections, denying packets that are
not part of a properly originated call. (This may not be practical when multimedia
protocol inherent security or lower layer security is applied, e.g., H.235 Annex D
for integrity provision or TLS to protect SIP signaling.)
Use IPsec or Secure Shell (SSH) for all remote management and auditing access.
If practical, avoid using remote management at all and do IP PBX access from a
physically secure system.
If performance is a problem, use encryption at the router or other gateway, not the
individual endpoints, to provide for IPsec tunneling. Since some VoIP endpoints
are not computationally powerful enough to perform encryption, placing this
burden at a central point ensures all VoIP traffic emanating from the enterprise
network has been encrypted. Newer IP phones are able to provide Advanced
Encryption System (AES) encryption at reasonable cost. Note that Federal
Information Processing Standard (FIPS) 140-2, Security Requirements for
Cryptographic Modules, is applicable to all Federal agencies that use
cryptographic-based security systems to protect sensitive information in computer
and telecommunication systems (including voice systems) as defined in Section
5131 of the Information Technology Management Reform Act of 1996, Public
Law 104-106.
2. Ensure that the organization has examined and can acceptably manage and mitigate the risks to
their information, system operations, and continuity of essential operations when deploying VoIP
systems.
VoIP can provide more flexible service at lower cost, but there are significant tradeoffs
that must be considered. VoIP systems can be expected to be more vulnerable than
conventional telephone systems, in part because they are tied in to the data network,
resulting in additional security weaknesses and avenues of attack (see VoIP Risks, Threats,
and Vulnerabilities section for more detailed discussion of vulnerabilities of VoIP and their
relation to data network vulnerabilities).
Confidentiality and privacy may be at greater risk in VoIP systems unless strong controls
are implemented and maintained. An additional concern is the relative instability of VoIP
technology compared with established telephony systems. Today, VoIP systems are still
maturing and dominant standards have not emerged. This instability is compounded by
VoIP’s reliance on packet networks as a transport medium. The public switched telephone
network is ultra-reliable. Internet service is generally much less reliable, and VoIP cannot
function without Internet connections, except in the case of large corporate or other users
who may operate a private network. Essential telephone services, unless carefully planned,
deployed, and maintained, will be at greater risk if based on VoIP.
3. Special consideration should be given to E-911 emergency services communications, because
E-911 automatic location service is not available with VoIP in some cases.
Unlike traditional telephone connections, which are tied to a physical location, VoIP’s
packet switched technology allows a particular number to be anywhere. This is convenient
for users, because calls can be automatically forwarded to their locations. But the tradeoff
is that this flexibility severely complicates the provision of E-911 service, which normally
provides the caller’s location to the 911 dispatch office. Although most VoIP vendors have
workable solutions for E-911 service, government regulators and vendors are still working
out standards and procedures for 911 services in a VoIP environment. Agencies must
carefully evaluate E-911 issues in planning for VoIP deployment.
4. Agencies should be aware that physical controls are especially important in a VoIP environment
and deploy them accordingly.
Unless the VoIP network is encrypted, anyone with physical access to the office LAN could
potentially connect network monitoring tools and tap into telephone conversations.
Although conventional telephone lines can also be monitored when physical access is
obtained, in most offices there are many more points to connect with a LAN without
arousing suspicion. Even if encryption is used, physical access to VoIP servers and
gateways may allow an attacker to do traffic analysis (i.e., determine which parties are
communicating). Agencies therefore should ensure that adequate physical security is in
place to restrict access to VoIP network components. Physical securities measures,
including barriers, locks, access control systems, and guards, are the first line of defense.
Agencies must make sure that the proper physical countermeasures are in place to mitigate
some of the biggest risks such as insertion of sniffers or other network monitoring devices.
Otherwise, practically speaking this means that installation of a sniffer could result in not
just data but all voice communications being intercepted.
5. VoIP-ready firewalls and other appropriate protection mechanisms should be employed.
Agencies must enable, use, and routinely test the security features that are included in VoIP
systems.
Because of the inherent vulnerabilities (e.g. susceptibility to packet sniffing) when
operating telephony across a packet network, VoIP systems incorporate an array of security
features and protocols. Organization security policy should ensure that these features are
used. In particular, firewalls designed for VoIP protocols are an essential component of a
secure VoIP system.
6. If practical, “softphone” systems, which implement VoIP using an ordinary PC with a headset
and special software, should not be used where security or privacy are a concern.
Worms, viruses, and other malicious software are extraordinarily common on PCs
connected to the internet, and very difficult to defend against. Well-known vulnerabilities
in web browsers make it possible for attackers to download malicious software without a
user’s knowledge, even if the user does nothing more than visit a compromised web site.
Malicious software attached to email messages can also be installed without the user’s
knowledge, in some cases even if the user does not open the attachment. These
vulnerabilities result in unacceptably high risks in the use of “softphones”, for most
applications. In addition, because PCs are necessarily on the data network, using a
softphone system conflicts with the need to separate voice and data networks to the greatest
extent practical.
7. If mobile units are to be integrated with the VoIP system, use products implementing WiFi
Protected Access (WPA), rather than 802.11 Wired Equivalent Privacy (WEP).
The security features of 802.11 WEP provide little or no protection because WEP can be
cracked with publicly available software. The more recent WiFi Protected Access (WPA),
a snapshot of the ongoing 802.11i standard, offers significant improvements in security,
and can aid the integration of wireless technology with VoIP. NIST strongly recommends
that the WPA (or WEP if WPA is unavailable) security features be used as part of an overall
defense-in-depth strategy. Despite their weaknesses, the 802.11 security mechanisms can
provide a degree of protection against unauthorized disclosure, unauthorized network
access, or other active probing attacks. However, the Federal Information Processing
Standard (FIPS) 140-2, Security Requirements for Cryptographic Modules, is mandatory
and binding for Federal agencies that have determined that certain information must be
protected via cryptographic means. As currently defined, neither WEP nor WPA meets the
FIPS 140-2 standard. In these cases, it will be necessary to employ higher level
cryptographic protocols and applications such as secure shell (SSH), Transport Level
Security (TLS) or Internet Protocol Security (IPsec) with FIPS 140-2 validated
cryptographic modules and associated algorithms to protect information, regardless of
whether the nonvalidated data link security protocols are used.
8. Carefully review statutory requirements regarding privacy and record retention with competent
legal advisors.
Although legal issues regarding VoIP are beyond the scope of this document, readers
should be aware that laws and rulings governing interception or monitoring of VoIP lines,
and retention of call records, may be different from those for conventional telephone
systems. Agencies should review these issues with their legal advisors. See Section 2.5 for
more on these issues.

G.3 Cloud Computing
Cloud Computing
Purpose:
This paper is provided to define and describe cloud computing, discuss CJIS Security Policy
(CSP) compliance, detail security and privacy, and provide general recommendations.
Attribution:
NIST SP 800-144, Guidelines on Security and Privacy in Public Cloud Computing (Dec.
2011)
NIST SP 800-145, the NIST Definition of Cloud Computing (Sept. 2011)
NIST SP 800-146, Cloud Computing Synopsis and Recommendations (May 2011)
CJIS Security Policy, Version 5.0
Definitions and Terms:
Cloud computing – A distributed computing model that permits on-demand network access to a
shared pool of configurable computing resources (e.g., networks, servers, storage, applications,
and services), software, and information.
Cloud subscriber – A person or organization that is a customer of a cloud
Cloud client – A machine or software application that accesses a cloud over a network connection,
perhaps on behalf of a subscriber
Cloud provider – An organization that provides cloud services
Summary:
With many law enforcement agencies looking for ways to attain greater efficiency while grappling
with reduced budgets, the idea of cloud computing to maintain data and applications is a viable
business solution. But the unique security and legal characteristics of law enforcement agencies
means any migration to cloud services may be challenging. Anytime the security of information
and transactions must be maintained, as it must be with access to the FBI’s CJIS systems and the
protection of Criminal Justice Information (CJI), security and policy compliance concerns are
bound to arise.
Cloud computing has become a popular and sometimes contentious topic of discussion for both
the private and public sectors. This is in part because of the difficulty in describing cloud
computing in general terms, because it is not a single kind of system. The “cloud” spans a spectrum
of underlying technologies, configuration possibilities, service and deployment models. Cloud
computing offers the ability to conveniently rent access to fully featured applications, software
development and deployment environments, and computing infrastructure assets - such as
network-accessible data storage and processing from a cloud service provider.
Ultimately, the move to cloud computing is a business decision in which the following relevant
factors are giving proper consideration:
readiness of existing applications for cloud deployment
transition costs
life-cycle costs
maturity of service orientation in existing infrastructure
security and privacy requirements – federal, state, and local
Achieving CJIS Security Policy Compliance:
The question that is often asked is, “Can an Agency be compliant with the CSP and also cloud
compute?”
Because the CSP is device and architecture independent (per CSP Section 2.2), the answer is yes,
and this can be accomplished— assuming the vendor of the cloud technology is able to meet the
existing requirements of the CSP.
There are security challenges that must be addressed if CJI is to be sent into or through, stored
within, or accessed from the cloud.
Admittedly, the existing CSP requirements may be difficult for some cloud-computing vendors
due to the sheer numbers and the geographic disbursement of their personnel; however, the
requirements aren’t new to vendors serving the criminal justice community and many vendors
have been successfully meeting the CSP requirements for years. Even so, they are the minimum
security requirements which will provide an acceptable level of assurance that law enforcement
and personally identifiable information (PII) will be protected when shared with other law
enforcement agencies across the nation.

Before tackling these challenges, the cloud subscriber should first be aware of what security and
legal requirements they are subject to prior to entering into any agreement with a cloud provider.
The following questions can help frame the process of determining compliance with the existing
requirements of the CSP.
Will access to Criminal Justice Information (CJI) within a cloud environment fall within
the category of remote access? (5.5.6 Remote Access)
Will advanced authentication (AA) be required for access to CJI within a cloud
environment? (5.6.2.2 Advanced Authentication, 5.6.2.2.1 Advanced Authentication
Policy and Rationale)
Does/do any cloud service provider’s datacenter(s) used in the transmission or storage of
CJI meet all the requirements of a physically secure location? (5.9.1 Physically Secure
Location)
Are the encryption requirements being met? (5.10.1.2 Encryption)
o Who will be providing the encryption as required in the CJIS Security Policy?
(client or cloud service provider)
o Is the data encrypted while at rest and in transit?
What are the cloud service provider’s incident response procedures? (5.3 Policy Area 3:
Incident Response)
o Will the cloud subscriber be notified of any incident?
o If CJI is compromised, what are the notification and response procedures?
Is the cloud service provider a private contractor/vendor?
o If so, they are subject to the same screening and agreement requirements as any
other private contractors hired to handle CJI? (5.1.1.5 Private Contractor User
Agreements and CJIS Security Addendum; 5.12.1.2 Personnel Screening for
Contractors and Vendors)
Will the cloud service provider allow the CSA and FBI to conduct compliance and
security audits? (5.11.1 Audits by the FBI CJIS Division; 5.11.2 Audits by the CSA)
How will event and content logging be handled? (5.4 Policy Area 4, Auditing and
Accountability)
o Will the cloud service provider handle logging and provide that upon request?
Ultimately, the goal is to remain committed to using technology in its information sharing
processes, but not at the sacrifice of the security of the information with which it has been
entrusted. As stated in the CSP, device and architecture independence can permit the use of cloud
computing, but the security requirements do not change.
The Cloud Model Explained:
Cloud computing is a model for enabling ubiquitous, convenient, on-demand network access to a
shared pool of configurable computing resources (e.g., networks, servers, storage, applications,
and services) that can be rapidly provisioned and released with minimal management effort or
service provider interaction.
The cloud model as defined by NIST consists of five essential characteristics, offers the option of
three service models, and may be deployed via any of four deployment models as shown in
Figure 1 below:

Figure 1 - Visual Depiction of the NIST Cloud Computing Definition

Essential Characteristics:
On-demand self-service
A consumer can unilaterally provision computing capabilities, such as server time and
network storage, as needed automatically without requiring human interaction with each
service provider.
Broad network access
Capabilities are available over the network and accessed through standard mechanisms
that promote use by heterogeneous thin or thick client platforms (e.g., mobile phones,
tablets, laptops, and workstations).
Resource pooling
The provider’s computing resources are pooled to serve multiple consumers using a
multi-tenant model, with different physical and virtual resources dynamically assigned
and reassigned according to consumer demand. There is a sense of location independence
in that the customer generally has no control or knowledge over the exact location of the
provided resources but may be able to specify location at a higher level of abstraction
(e.g., country, state, or datacenter). Examples of resources include storage, processing,
memory, and network bandwidth.
Rapid elasticity
Capabilities can be elastically provisioned and released, in some cases automatically, to
scale rapidly outward and inward commensurate with demand. To the consumer, the
capabilities available for provisioning often appear to be unlimited and can be
appropriated in any quantity at any time.
Measured service
Cloud systems automatically control and optimize resource use by leveraging a metering
capability* at some level of abstraction appropriate to the type of service (e.g., storage,
processing, bandwidth, and active user accounts). Resource usage can be monitored,
controlled, and reported, providing transparency for both the provider and consumer of
the utilized service.
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt strip-pages Typically this is done on a pay-per-use or charge-per-use basis.
Deployment Models:
Private cloud
The cloud infrastructure is provisioned for exclusive use by a single organization
comprising multiple consumers (e.g., business units). It may be owned, managed, and
operated by the organization, a third party, or some combination of them, and it may exist
on or off premises.
Community cloud
The cloud infrastructure is provisioned for exclusive use by a specific community of
consumers from organizations that have shared concerns (e.g., mission, security
requirements, policy, and compliance considerations). It may be owned, managed, and
operated by one or more of the organizations in the community, a third party, or some
combination of them, and it may exist on or off premises.
Public cloud
The cloud infrastructure is provisioned for open use by the general public. It may be
owned, managed, and operated by a business, academic, or government organization, or
some combination of them. It exists on the premises of the cloud provider.
Hybrid cloud
The cloud infrastructure is a composition of two or more distinct cloud infrastructures
(private, community, or public) that remain unique entities, but are bound together by
standardized or proprietary technology that enables data and application portability (e.g.,
cloud bursting for load balancing between clouds).
Service Models:
Software as a Service (SaaS)
This model provides the consumer the capability to use the provider’s applications
running on a cloud infrastructure*.
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt strip-pages A cloud infrastructure is the collection of hardware and software that enables
the five essential characteristics of cloud computing. The cloud infrastructure can
be viewed as containing both a physical layer and an abstraction layer. The
physical layer consists of the hardware resources that are necessary to support
the cloud services being provided, and typically includes server, storage and
network components. The abstraction layer consists of the software deployed
across the physical layer, which manifests the essential cloud characteristics.
Conceptually the abstraction layer sits above the physical layer.
The SaaS service model is often referred to as “Software deployed as a hosted service
and accessed over the Internet.”
The applications are accessible from various client devices through either a thin client
interface, such as a web browser (e.g., web-based email), or a program interface.
When using the SaaS service model it should be understood that the consumer does not
manage or control the underlying cloud infrastructure including network, servers,
operating systems, storage, or even individual application capabilities, with the possible
exception of limited user-specific application configuration settings.
Platform as a Service (PaaS)
This model provides the consumer the capability to deploy consumer-created or acquired
applications* created using programming languages, libraries, services, and tools
supported by the provider onto the cloud infrastructure.
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt strip-pages This capability does not necessarily preclude the use of compatible
programming languages, libraries, services, and tools from other sources.

When using the PaaS service model the consumer may have control over the deployed
applications and possibly configuration settings for the application-hosting environment,
but does not manage or control the underlying cloud infrastructure including network,
servers, operating systems, or storage.
Infrastructure as a Service (IaaS)
This model provides the consumer the capability to provision processing, storage,
networks, and other fundamental computing resources where the consumer is able to
deploy and run arbitrary software, which can include operating systems and applications.
When using the IaaS service model the consumer may have control over operating
systems, storage, and deployed applications; and possibly limited control of select
networking components (e.g., host firewalls), but does not manage or control the
underlying cloud infrastructure.
Key Security and Privacy Issues:
Although the emergence of cloud computing is a recent development, insights into critical aspects
of security can be gleaned from reported experiences of early adopters and also from researchers
analyzing and experimenting with available cloud provider platforms and associated technologies.
The sections below highlight privacy and security-related issues that are believed to have longterm significance for public cloud computing and, in many cases, for other cloud computing
service models.
Because cloud computing has grown out of an amalgamation of technologies, including service
oriented architecture, virtualization, Web 2.0, and utility computing, many of the privacy and
security issues involved can be viewed as known problems cast in a new setting. The importance
of their combined effect in this setting, however, should not be discounted. Public cloud computing
does represent a thought-provoking paradigm shift from conventional norms to an open
organizational infrastructure—at the extreme, displacing applications from one organization’s
infrastructure to the infrastructure of another organization, where the applications of potential
adversaries may also operate.
Governance
Governance implies control and oversight by the organization over policies, procedures, and
standards for application development and information technology service acquisition, as well as
the design, implementation, testing, use, and monitoring of deployed or engaged services. With
the wide availability of cloud computing services, lack of organizational controls over employees
engaging such services arbitrarily can be a source of problems. While cloud computing simplifies
platform acquisition, it doesn't alleviate the need for governance; instead, it has the opposite effect,
amplifying that need.
Dealing with cloud services requires attention to the roles and responsibilities involved between
the organization and cloud provider, particularly with respect to managing risks and ensuring
organizational requirements are met. Ensuring systems are secure and risk is managed is
challenging in any environment and even more daunting with cloud computing. Audit mechanisms
and tools should be in place to determine how data is stored, protected, and used, to validate
services, and to verify policy enforcement. A risk management program should also be in place
that is flexible enough to deal with the continuously evolving and shifting risk landscape.
Compliance
Compliance refers to an organization’s responsibility to operate in agreement with established
laws, regulations, standards, and specifications. Various types of security and privacy laws and
regulations exist within different countries at the national, state, and local levels, making
compliance a potentially complicated issue for cloud computing.
Law and Regulations
Cloud providers are becoming more sensitive to legal and regulatory concerns, and may be
willing to commit to store and process data in specific jurisdictions and apply required
safeguards for security and privacy. However, the degree to which they will accept liability
in their service agreements, for exposure of content under their control, remains to be seen.
Even so, organizations are ultimately accountable for the security and privacy of data held
by a cloud provider on their behalf.
Data Location
One of the most common compliance issues facing an organization is data location. A
characteristic of many cloud computing services is that data is stored redundantly in
multiple physical locations and detailed information about the location of an organization’s
data is unavailable or not disclosed to the service consumer. This situation makes it difficult
to ascertain whether sufficient safeguards are in place and whether legal and regulatory
compliance requirements are being met. External audits and security certifications can
alleviate this issue to some extent, but they are not a panacea.
When information crosses borders, the governing legal, privacy, and regulatory regimes
can be ambiguous and raise a variety of concerns. Consequently, constraints on the transborder flow of sensitive data, as well as the requirements on the protection afforded the
data, have become the subject of national and regional privacy and security laws and
regulations.
Electronic Discovery
The capabilities and processes of a cloud provider, such as the form in which data is
maintained and the electronic discovery-related tools available, affect the ability of the
organization to meet its obligations in a cost effective, timely, and compliant manner. A
cloud provider’s archival capabilities may not preserve the original metadata as expected,
causing spoliation (i.e., the intentional, reckless, or negligent destruction, loss, material
alteration, or obstruction of evidence that is relevant to litigation), which could negatively
impact litigation.
Trust
Under the cloud computing paradigm, an organization relinquishes direct control over many
aspects of security and privacy, and in doing so, confers a high level of trust onto the cloud
provider. At the same time, federal agencies have a responsibility to protect information and
information systems commensurate with the risk and magnitude of the harm resulting from
unauthorized access, use, disclosure, disruption, modification, or destruction, regardless of
whether the information is collected or maintained by or on behalf of the agency; or whether the
information systems are used or operated by an agency or by a contractor of an agency or other
organization on behalf of an agency
Insider Access
Data processed or stored outside the physical confines of an organization, its firewall, and
other security controls bring with it an inherent level of risk. The insider security threat is
a well-known issue for most organizations. Incidents may involve various types of fraud,
sabotage of information resources, and theft of sensitive information.
Data Ownership
The organization’s ownership rights over the data must be firmly established in the service
contract to enable a basis for trust and privacy of data. The continuing controversy over
privacy and data ownership rights for social networking users illustrates the impact that
ambiguous terms can have on the parties involved.
Ideally, the contract should state clearly that the organization retains exclusive ownership
over all its data; that the cloud provider acquires no rights or licenses through the
agreement, including intellectual property rights or licenses, to use the organization’s data
for its own purposes; and that the cloud provider does not acquire and may not claim any
interest in the data due to security. For these provisions to work as intended, the terms of
data ownership must not be subject to unilateral amendment by the cloud provider.
Visibility

Continuous monitoring of information security requires maintaining ongoing awareness of
security controls, vulnerabilities, and threats to support risk management decisions.
Transition to public cloud services entails a transfer of responsibility to the cloud provider
for securing portions of the system on which the organization’s data and applications
operate.
Ancillary Data
While the focus of attention in cloud computing is mainly on protecting application data,
cloud providers also hold significant details about the accounts of cloud consumers that
could be compromised and used in subsequent attacks.
Risk Management
Assessing and managing risk in systems that use cloud services can be a challenge. With
cloud-based services, some subsystems or subsystem components fall outside of the direct
control of a client organization. Many organizations are more comfortable with risk when
they have greater control over the processes and equipment involved. Establishing a level
of trust about a cloud service is dependent on the degree of control an organization is able
to exert on the provider to provision the security controls necessary to protect the
organization’s data and applications, and also the evidence provided about the
effectiveness of those controls. Ultimately, if the level of trust in the service falls below
expectations and the organization is unable to employ compensating controls, it must either
reject the service or accept a greater degree of risk.
Architecture
The architecture of the software and hardware used to deliver cloud services can vary significantly
among public cloud providers for any specific service model. It is important to understand the
technologies the cloud provider uses to provision services and the implications the technical
controls involved have on security and privacy of the system throughout its lifecycle. With such
information, the underlying system architecture of a cloud can be decomposed and mapped to a
framework of security and privacy controls that can be used to assess and manage risk.
Identity and Access Management
Data sensitivity and privacy of information have become increasingly an area of concern for
organizations. The identity proofing and authentication aspects of identity management entail the
use, maintenance, and protection of PII collected from users. Preventing unauthorized access to
information resources in the cloud is also a major consideration. One recurring issue is that the
organizational identification and authentication framework may not naturally extend into a public

cloud and extending or changing the existing framework to support cloud services may prove
difficult.
Software Isolation
High degrees of multi-tenancy over large numbers of platforms are needed for cloud computing to
achieve the envisioned flexibility of on-demand provisioning of reliable services and the cost
benefits and efficiencies due to economies of scale. Regardless of the service model and multitenant software architecture used, the computations of different consumers must be able to be
carried out in isolation from one another, mainly through the use of logical separation mechanisms.
Data Protection
Data stored in a public cloud typically resides in a shared environment collocated with data from
other customers. Organizations placing sensitive and regulated data into a public cloud, therefore,
must account for the means by which access to the data is controlled and the data is kept secure.
Similar concerns exist for data migrated within or between clouds.
Value Concentration
Having data collocated with that of an organization with a high threat profile could also
lead to a denial of service, as an unintended casualty from an attack targeted against that
organization. Similarly, side effects from a physical attack against a high profile
organization’s cloud-based resources are also a possibility. For example, over the years,
facilities of the Internal Revenue Service have attracted their share of attention from wouldbe attackers.
Data Isolation
Database environments used in cloud computing can vary significantly. Accordingly,
various types of multi-tenant arrangements exist for databases. Each arrangement pools
resources differently, offering different degrees of isolation and resource efficiency.
Regardless of implementation decision, data must be secured while at rest, in transit, and
in use, and access to the data must be controlled.
Data Sanitization
The data sanitization practices that a cloud provider implements have obvious implications
for security. Sanitization involves the expunging of data from storage media by
overwriting, degaussing, or other means, or the destruction of the media itself, to prevent
unauthorized disclosure of information. Data sanitization also applies to backup copies
made for recovery and restoration of service and residual data remaining upon termination
of service.
In a public cloud computing environment, data from one consumer is physically collocated
(e.g., in an IaaS data store) or commingled (e.g., in a SaaS database) with the data of other
consumers, which can complicate matters. Service agreements should stipulate sufficient
measures that are taken to ensure data sanitization is performed appropriately throughout
the system lifecycle.
Encryption
Client end-to-end encryption (e.g. encryption/decryption occurs on the law enforcement
controlled client prior to data entering the cloud and decryption occurs only on the client
device after encrypted data is removed from the cloud service) with cryptographic keys
managed solely by law enforcement would prevent exposure of sensitive data.
May cause significant cloud service functionality limitations on available service types
made available for sensitive data. This may also increase expenses to cover key items,
such as key management and client software. Additionally, a number of specific SLA or
contract clauses may be necessary for the implementation of client end-to end
encryption.

Use of cloud services without end-to-end encryption implemented by the client is another
option that would require cloud service provider participation in the encryption of data.
This would require at least some cloud provider personnel to undergo personnel
background screening and training.
Specialized Service Level Agreements (SLA) and/or contractual clauses would be
necessary to identify those personnel that may have access to unencrypted, sensitive
data.

Conducting the analysis and gaining approval of particular cloud service
implementations not utilizing end-to-end encryption for sensitive law enforcement data
may be costly and time consuming due to the high degree of technical complexity.

Availability
In simple terms, availability is the extent to which an organization’s full set of computational
resources is accessible and usable. Denial of service attacks, equipment outages, and natural
disasters are all threats to availability. The concern is that most downtime is unplanned and can
impact the mission of the organization. Some examples of unplanned service interruptions that
cause concerns are:
Temporary Outages
Prolonged and Permanent Outages
Denial of Service
Incident Response
The complexity of a cloud service can obscure recognition and analysis of incidents. Revising an
organization’s incident response plan to address differences between the organizational computing
environment and a cloud computing environment is an important, but easy-to-overlook
prerequisite to transitioning applications and data.
Data Availability
The availability of relevant data from event monitoring is essential for timely detection of
security incidents. Cloud consumers are often confronted with extremely limited
capabilities for detection of incidents in public cloud environments. The situation varies
among cloud service models and cloud providers. For example, PaaS providers typically
do not make event logs available to consumers, who are then left mainly with event data
from self-deployed applications (e.g., via application logging). Similarly, SaaS consumers
are completely dependent upon the cloud provider to provide event data such as activity
logging, while IaaS consumers control more of the information stack and have access to
associated event sources.
Incident Analysis and Resolution
An analysis to confirm the occurrence of an incident or determine the method of exploit
needs to be performed quickly and with sufficient detail of documentation and care to
ensure that traceability and integrity is maintained for subsequent use, if needed (e.g., a
forensic copy of incident data for legal proceedings). Issues faced by cloud consumers
when performing incident analysis include lack of detailed information about the
architecture of the cloud relevant to an incident, lack of information about relevant event
and data sources held by the cloud provider, ill-defined or vague incident handling
responsibilities stipulated for the cloud provider, and limited capabilities for gathering and
preserving pertinent data sources as evidence. Understanding and negotiating the
provisions and procedures for incident response should be done before entering into a
service contract, rather than as an afterthought.

General Recommendations:
A number of significant security and privacy issues were covered in the previous subsections.
Table 1 summarizes those issues and related recommendations for organizations to follow when
planning, reviewing, negotiating, or initiating a public cloud service outsourcing arrangement.

Table 1: Security and Privacy Issue Areas and Recommendations
Areas
Recommendations
Extend organizational practices pertaining to the policies, procedures,
and standards used for application development and service provisioning
in the cloud, as well as the design, implementation, testing, use, and
Governance
monitoring of deployed or engaged services.
Put in place audit mechanisms and tools to ensure organizational
practices are followed throughout the system lifecycle.
Understand the various types of laws and regulations that impose
security and privacy obligations on the organization and potentially
impact cloud computing initiatives, particularly those involving data
location, privacy and security controls, records management, and
electronic discovery requirements.
Compliance
Review and assess the cloud provider’s offerings with respect to the
organizational requirements to be met and ensure that the contract terms
adequately meet the requirements.
Ensure that the cloud provider’s electronic discovery capabilities and
processes do not compromise the privacy or security of data and
applications.
Ensure that service arrangements have sufficient means to allow
visibility into the security and privacy controls and processes employed
by the cloud provider, and their performance over time.
Establish clear, exclusive ownership rights over data.
Trust
Institute a risk management program that is flexible enough to adapt to
the constantly evolving and shifting risk landscape for the lifecycle of
the system.
Continuously monitor the security state of the information system to
support on-going risk management decisions.
Understand the underlying technologies that the cloud provider uses to
provision services, including the implications that the technical controls
Architecture
involved have on the security and privacy of the system, over the full
system lifecycle and across all system components.
Ensure that adequate safeguards are in place to secure authentication,
Identity and
authorization, and other identity and access management functions, and
Access
are suitable for the organization.
Management
Software
Isolation

Data
Protection

Availability

Incident
Response

Understand virtualization and other logical isolation techniques that the
cloud provider employs in its multi-tenant software architecture, and
assess the risks involved for the organization.
Evaluate the suitability of the cloud provider’s data management
solutions for the organizational data concerned and the ability to control
access to data, to secure data while at rest, in transit, and in use, and to
sanitize data.
Take into consideration the risk of collating organizational data with that
of other organizations whose threat profiles are high or whose data
collectively represent significant concentrated value.
Fully understand and weigh the risks involved in cryptographic key
management with the facilities available in the cloud environment and
the processes established by the cloud provider.
Understand the contract provisions and procedures for availability, data
backup and recovery, and disaster recovery, and ensure that they meet
the organization’s continuity and contingency planning requirements.
Ensure that during an intermediate or prolonged disruption or a serious
disaster, critical operations can be immediately resumed, and that all
operations can be eventually reinstituted in a timely and organized
manner.
Understand the contract provisions and procedures for incident response
and ensure that they meet the requirements of the organization.
Ensure that the cloud provider has a transparent response process in
place and sufficient mechanisms to share information during and after an
incident.
Ensure that the organization can respond to incidents in a coordinated
fashion with the cloud provider in accordance with their respective roles
and responsibilities for the computing environment.

G.4 Mobile Appendix
Mobile Appendix
Introduction
Mobile devices present a unique security challenge with regard to the correct application of CJIS
Security Policy requirements. This appendix is intended to provide best practices based on industry
standards and on methods to achieve policy compliance in mobile device employment scenarios.
The technical methods used to achieve compliance with CJIS Security Policy will typically be
different within the mobile environment than those used in fixed locations. Many of the security
features and capabilities inherited by endpoint devices from the fixed environment are either not
present or present in a different form in the mobile environment. Additionally, the basic
technologies used in some types of mobile devices may adequately fulfill some of the CJIS
Security Policy requirements which would require additional software or added features in a
traditional fixed computing environment. Due to the complexity and rapid evolvement of the
mobile environment, this Appendix will remain as device and vendor agnostic as practical,
however certain key requirements for specific mobile operating systems will be identified for the
major mobile operating systems (e.g. Apple iOS, Android) as the underlying technologies are
fundamentally different and offer different levels of built-in compliance to CJIS Security Policy.
Sections within this appendix will provide recommendations regarding priorities and level of effort
versus value of applying certain security controls in the mobile environment. These
recommendations do not supersede or modify the requirements listed in the CJIS Security Policy,
and are intended to describe the effect of inherent security functions and inherent device limitations
in many mobile platforms that impact the application of policy elements in the mobile
environment.
Mobile Device Risk Scenarios
There are multiple risk scenarios that may apply to mobile devices depending on the category of
device (e.g. Laptop, Tablet, and ‘Pocket sized’ devices such as smartphones) and the methods of
device connectivity (e.g. cellular service, WiFi + Cellular, WiFi only). Device category and
method of connection define the technology types within the device which inherently affects the
total level of compliance with CJIS Security Policy that can be obtained by the mobile device.
It is advisable for acquiring agencies to review the mobile device guidance in this Appendix prior
to completing selection and acquisition of particular devices. Both the device category and
connectivity methods installed and configured on the device will impact the overall risk scenario
associated with the device and may significantly affect the effective cost to bring use of the device
in compliance with the CJIS Security Policy. For instance, inclusion of cellular radios with the
ability to remotely control a device significantly changes the risk scenario by allowing remote
tracking, file deletion, and device management which could provide a higher level of CJIS Security
Policy compliance than a WiFi only device that does not guarantee the ability to remotely manage
the device. However, inclusion of cellular technology may significantly increase the initial device
costs and incur ongoing subscription costs. Appropriate choices based on the intended use of the
device along with the types and methods of Criminal Justice Information (CJI) data to be accessed
could greatly reduce agency cost and enhance security.
Device Categories
This appendix defines risk levels for three categories of devices. Prior to reading individual
sections of this Appendix, the agency should identify which device categories will apply to their
employment scenario. If multiple categories of devices are employed, individual technical
configurations and local policy will likely need to be defined for each category of device based on
the risk inherent in the technical characteristics associated with each device category.
Laptop devices
The laptop device category includes mobile devices in a larger format that are transported either
in a vehicle mount or a carrying case and include a monitor with attached keyboard. This includes
all traditional laptop computers that utilize a ‘traditional’, full featured operating system (e.g.
Windows or a Linux variant). Also included in this category are ‘tablet’ type full featured
computers running a traditional full featured operating system but without an attached keyboard.
The main defining factor is the use of a full featured operating system and a form factor too large
to be carried in a pocket. In general, devices of this type connect via WiFi only, but may include
an internal cellular access card in some cases.
The risks associated with this device type are similar to a standard desktop computer at the
technical level, but are increased due to the potential to connect directly to the internet without the
benefit of organizational network security layers (e.g. network firewall, IDS/IPS, network
monitoring devices). There is also an increased risk of intentional device theft from vehicles or
unsecure locations as these devices are too large to be carried on the authorized user’s body. There
may be increased risk from the limited technical ability to wipe or track a lost/stolen device
depending on the particular technical means used for remote device connectivity (e.g. cellular or
WiFi).
In general, the technical configurations for compliance with most of the CJIS Security Policy that
is accomplished via the operating system (e.g. auditing, access control, etc) will remain consistent
with normal fixed location computing systems for laptop devices, but some functions may operate
in an unexpected manner due to lack of constant connectivity. Thorough testing of applied security
policy elements within the expected mobile environments will help ensure the applied policy
configurations remain effective and appropriate when applied to mobile laptop devices.
NOTE: Some newer devices running multi-function operating systems (e.g. Windows 8 or similar
multi-mode operating systems) may exhibit technical features associated with both laptop and
tablet device categories based on their current operating mode which may be reconfigured by the
user on demand. If this is the case, it will be necessary to assess and configure multiple operating
modes to be compliant with CJIS Security Policy on the device, or restrict the operating mode to
one category of operation.
Tablet devices
The tablet device category includes larger format devices transported via vehicle mount or
portfolio sized carry case that typically consist of a touch screen without attached keyboard. These
devices utilize a limited feature operating system (e.g. Apple iOS, Google Android, Windows
mobile) that is inherently more resistant than a traditional operating system to certain types of
network based technical attacks due to the limited feature sets. Additionally, limited functionality
operating systems are designed specifically for the mobile environment where battery life and
power efficiency are primary design drivers. This inherently limits the types of services that can
function effectively on the devices (e.g. traditional real-time anti-virus software) as the base
operating system may not be designed to allow installed applications enhanced execution priority
in the background and or the ability to examine the contents or communications associated within
another application. However, this same design methodology significantly limits the vectors
available for malware transmission and the device or application data actually accessible to
malware if a device becomes infected.
Tablet devices will have different risks associated depending on the installed and configured
methods for network access (e.g. ‘always on cellular’ vs. WiFi only). Physical risks associated
with this category are similar to the laptop category for enhanced likelihood of intentional theft or
device hijacking while unattended, while the technical risks are similar to the pocket device
category.
Pocket devices/Handheld devices
The pocket/handheld device category is technically similar or identical to the tablet category and
is primarily differentiated by device form factor. Pocket/handheld devices are characterized as
having a limited functionality operating system and a small form factor intended for carry in a
pocket or ‘holster’ attached to the body. The bulk of this category will be cellular ‘smartphones’
with integrated cellular data connectivity, however devices intended to be worn or carried on the
body (e.g. portable fingerprint devices) may also be included in this category if they operate using
a limited functionality operating system. Custom or specialty devices may meet the form factor
distinction for this category, but operate using a full feature operating system. In rare cases of this
nature the employing agency should apply security guidance and principles in this appendix for
both the laptop and pocket device categories.
Risks associated with this category are a reduced threat of theft to a stored devices (e.g. device left
unattended in a vehicle) since these devices are typically carried continuously by the authorized
user, but include a greater risk of temporary or permanent loss of control due to the device being
misplaced by the authorized user.
Due to the installation of a limited functionality operating system, the technical threat to these
devices via a network based attack is significantly lower than the laptop category, however, the
threat of unauthorized access at the device level may be higher if the device is lost due to technical
limits on multi-factor authentication to the operating system itself and practical limits to device
passwords due to screen/software keyboard limitations.
NOTE: Data accessible on pocket or tablet devices simply through the entry of a single device PIN
or password should not be considered secure due to the likelihood of enhanced password guessing
based on fingerprints/smudges on the device touch screen. Any data stored on devices of these
types should be protected within a separate secure container using Advanced Authentication.
Device Connectivity
There are three main categories of device connectivity that are associated with varying risk levels
and threats to the devices. The Three categories are: Cellular Network Only (always on), WiFi
Only (includes ‘on demand’ cellular), and Cellular (always on) + WiFi network. The risks
associated with connectivity categories are general risks and may apply differently to any
particular device at different points in its usage or lifecycle. Particular device configurations either
through the operating system or a third-party mobile device management (MDM) system may be
able to significantly control and define which particular connectivity risks may be associated with
a particular device.
Cellular Network Only (always on)
Cellular network connectivity is characterized by ‘always on’ network connection through the
device internal radio to a cellular network provider. There is a reasonable assurance that devices
with ‘always on’ cellular can be tracked, managed, or wiped remotely if lost or stolen. This will
significantly reduce risks associated with loss of the device and attempted illicit access to the
device. One important consideration for this risk category is characterization of the device as
‘always on’ or ‘on demand’. In effect the difference is typically a configuration setting, which in
some cases may be changeable by the user. In particular most cellular smart phones contain
‘airplane’ mode settings that disable all internal radios allowing a user authenticated to the device
operating system via password or personal identification number (PIN) to disable the cellular
system. Access to this functionality may be disabled through the use of some MDM systems which
would necessitate a complete power down of the device while carried on aircraft. Additionally,
someone illicitly obtaining a device with properly configured password requirements and screen
lock timeouts would be unlikely to guess the device password before the device was reported stolen
in order for them to disable the cellular connection and prevent tracking or a remote wipe of the
device.
Cellular networks do not allow for the same level of exposure of individual devices to random
access from the internet. This significantly reduces the potential network based attack vectors that
might reach a cellular connected device. The risk scenario in most cases from a network based
attack would be similar to a device protected behind rudimentary network defenses (e.g. standard
firewall but NOT advanced intrusion detection/prevention) Cellular device communications
cannot typically be accessed by other ‘eavesdropping’ devices physically close to them without
significant specialized equipment and can be considered well protected against network attacks
below the nation/state level of technical capability by the hosting technical infrastructure and
technology inherent in the device. However, network based attacks that utilize connections
initiated by the user device may still succeed over the cellular infrastructure. For this reason, the
technical protections inherent in the cellular infrastructure provide limited protection against
user/device initiated actions (e.g. web surfing on a cellular connected web browser). Therefore,
the protections provided by always on cellular connections are primarily in the ability to remotely
access the mobile device for tracking or data deletion in case of device loss or compromise, which
combined with a limited functionality device operating system, the protections are generally
equivalent to a ‘personal firewall’ if properly configured and supported by a well-designed
organizational infrastructure. However, that equivalency does not apply to full featured operating
systems connected through cellular infrastructure.
NOTE: It should be noted that a technically capable, intentional, thief knowingly obtaining an
‘always on’ cellular device for the purpose of data theft can physically disable the radio by utilizing
a Faraday cage or similar external electromagnetic shield device while attempting to guess the
device password. While technically possible these methods require specialized equipment and high
technical expertise and would be very unlikely to be employed except for specifically targeted
attacks. When always on cellular connectivity is combined with a robust incident reporting process
and user training for rapid response to device loss or theft, the associated risks can be minimized.
WiFi only (includes ‘on-demand’ cellular)
WiFi only devices do not include cellular radios or include cellular radio that must be manually
activated or ‘connected’ to the cellular network. They connect to the network or internet through
WiFi ‘hotspots’ or external access points or manually to cellular networks. Some MDM or device
configurations may be able to limit the types and specific WiFi access points the device can
connect to, which may change the risk scenario of the device to a similar risk scenario as the
Cellular Network Only scenario. However, if mobile devices are permitted (through technical and
or policy decisions) to connect to any WiFi access point designated by the device user, the overall
device risk scenario is high and the device may be accessible to a large number of potential network
based attack vectors. Unrestricted WiFi access is not recommended on any agency owned device,
but must be assumed to exist on any personally owned device authorized to access CJI. Significant
compensating controls may be needed to ensure devices accessing CJI over ‘public’ WiFi access
points are not susceptible to communications network eavesdropping, credential hijacking or any
of the various potential man-in-the-middle attacks possible through access point spoofing. The
communications security risks can be significantly mitigated by mandatory device configurations
(e.g. MDM based policy) that only allow devices to connect to cryptographically verified agency
controlled WiFi access points.
WiFi only or devices with ‘on-demand’ cellular access (e.g. user or event driven cellular access
initiated from the device and not from a centralized management location) are significantly more
at risk from data loss subsequent to device loss or theft as there is no guarantee the tracking or
remote wipe can be initiated once the device is out of agency control. This can be mitigated by
utilizing tracking/anti-theft products that require a periodic network connection to authorize access
and perform automated device locking (‘bricking’) or remote wipe if network connections are not
made within a specified period. Software of this nature is generally available for full featured
laptops but may not be available for limited feature mobile operating systems.
Cellular (always on) + WiFi Network
This is a hybrid scenario that has become typical with most ‘smartphones’. These devices contain
both the always on cellular connection, but may also be configured to access local WiFi networks
for enhanced bandwidth. In considering devices with these technical characteristics, the theft/loss
risks are similar to the cellular only scenario (due to tracking and remote access through the cellular
connection), while the data and network based risks must be considered to be similar to the WiFi
scenario unless the capability of the device to connect to WiFi networks is limited by technology
or policy to agency owned WiFi Access Points configured in accordance with the CJIS Security
Policy. Careful consideration must be made to the particular configurations, management systems,
and human oriented operational policies based on the particular technical capabilities and
configurations of these types of devices.
Incident Handling (CJIS Security Policy Section 5.3)
Additional or enhanced incident reporting and handing procedures will need to be developed to
cover mobile device operating scenarios. Various exploits and methods to compromise mobile
devices require either specialized equipment or lengthy operations to implement. Rapid response
to mobile device related incidents can significantly mitigate the risks associated with illicit data
access either on the device itself or within online data resources associated with the device through
an application or specialized interface. However, parallel or special incident handling procedures
with associated equipment or systems may need to be put in place to properly respond to incidents
involving mobile devices. This section lists three areas where enhanced incident handling and
response processes may need to be implemented to ensure mobile device compliance to the
incident handling policy in Section 5.3.
If personally owned devices are utilized within the environment in a Bring Your Own device
(BYOD) scenario, specialized and costly incident handling procedures and processes may need to
be developed to support compliance for those devices. The costs associated with enhanced incident
handling procedures may need to be incorporated in the cost and risk based analysis to allow
personally owned devices in the BYOD scenario, as the technical methods and risk to achieve
compliance under BYOD scenarios may exceed any cost savings potentially achieved through
BYOD.
Loss of device Control
Mobile device users should be trained and provided with explicit user actions in case positive
control of a mobile device is lost for any period of time. Loss of positive control means the device
is in the physical control of non-CJIS authorized individual or the device is left unattended in an
unsecure location (e.g. counter of the coffee shop). Even if the device is recovered quickly there
is significant risk that either the device settings could be tampered with or data on the device could
be illicitly accessed. The level of detail and particular scenarios identified in the agency incident
response plan should be consistent with the presence of persistent CJI on the device or the technical
means used to access CJI from the device (e.g. ask the question: “Is it reasonable to assume CJI
could be accessed”) as well as the degree of device configuration control exercised by the user
from the device main login. At a minimum, special incident handling procedures should be
developed for the following scenarios:
Device known to be locked, control loss of minimal duration
Device lock state unknown at time of control loss, duration of loss minimal
Device lock state unknown at time of control loss, duration of loss extended
Device known to be unlocked at time of control loss, duration of loss more than
momentary.
NOTE: Organizations should define appropriate time value criteria based on the operational
environment for the above scenarios. For instance, a ‘momentary’ loss of control might be
considered a matter of seconds in a situation where no one could reasonably have accessed the
device, while ‘minimal’ durations might include a few minutes of time and ‘extended’ periods
would be any time longer than a few minutes.
Other scenarios should be addressed as appropriate to the intended device employment, with
explicit user and organizational actions identified based on the device technologies and any
organizational management capabilities.
Total Loss of device
Incident response scenarios for the total loss of the device should be developed based on the
methods/storage of CJI on the device, the lock state of the device at time of loss (known locked,
known unlocked, or unknown), and the technical methods available for remote tracking or wiping
of the device. It is critical to implement incident handling procedures quickly in this case. Remote
wipe functions can be implemented for always on cellular devices with a high potential for success
that may include positive confirmation from the device that the wipe was completed. However, for
WiFi only and on demand cellular devices, incident handling procedures that lock the device out
of accessing CJI may be necessary, while there would be no guarantee that any CJI stored on the
device could not eventually be accessed. For this reason, CJI should not generally be stored directly
on WiFi only or on-demand cellular devices unless an extremely robust anti-tamper system is in
place on the device itself.
Potential device Compromise (software/application)
Incident response scenarios for potential device compromise through intentional or unintentional
user action should be developed to ensure compliance with policy. This includes rooting,
jailbreaking or malicious application installation on the device during a loss of device control
scenario or inappropriate user action in the installation of applications to the device (compromise
can occur from either intentional threat agent actions or accidental user actions). Triggers for this
incident handling process may be driven from either user notification or electronic detection of
device tampering from an audit or MDM compliance check.
Audit and Accountability (CJIS Security Policy Section 5.4)
The ability to implement some Audit and Accountability functions specified in the CJIS Security
Policy on mobile devices with limited function operating systems (e.g. Android, Apple iOS) is not
natively included within the operating system. Either additional device management systems,
enterprise mobility management (EMM) or MDM, or auditing from systems accessed by the
mobile device with be necessary to ensure appropriate levels of auditing exist.
Auditable Events (reference 5.4.1)
Some of the specific audit requirements in the CJIS Security Policy may not be technically relevant
to the mobile operating system due to its internal functioning. To achieve compliance with the
CJIS Security Policy it will be necessary in most cases to utilize some form of MDM or EMM
system. Additional auditable events that compensate for the technical limitations of limited
function mobile operating systems may be available through the use of MDM systems (e.g.
association of event with global positioning system (GPS) location of the device). Specific
auditable events of interest in the mobile environment will depend on the intended device usage,
compartmentalization of data on the device, and options available with the specific technologies
employed. For instance, item 2 in Section 5.4.1.1 indicates an auditable event includes attempts to
modify elements of user account modification. Due to the limited internal functions of mobile
operating systems, this event type is not relevant to the operating system itself as they are generally
provisioned with only a single non-modifiable user account on the device. To achieve compliance
in a scenario where CJI is stored or accessed from a secure application on the device, auditing of
access to the secure application either through application design, or third party MDM capability
may provide an acceptable compensating control. For compliance with the policy each auditable
event and event content must be compared to the particular technologies and applications
employed to determine if adequate compensating controls are being met for audit items that either
do not apply to mobile technologies or cannot be implemented within the technology itself.
Alternative and compensating controls that provide detailed audit of access to CJI either on the
mobile device itself or through a controlled application to a central server may provide equivalent
auditing capability to the events specified in the policy. However, multiple auditing systems may
be required to replicate the auditing provided at the operating system level by a full function
operating system. Therefore, the overall auditing design should take into account retrieval and

consolidation of events or audit data from multiple auditing systems as appropriate to comply with
policy.
Audit Event Collection
Mobile devices without an ‘always-on’ cellular connection may pose technical challenges to
ensure any audit records collected and stored on the mobile device itself can be retrieved for review
and analysis per the CJIS Security Policy. Alternatively systems which explicitly require a network
connection to a central server to access data or decrypt on-device storage may provide acceptable
audit event collection and reporting since there is a guarantee that network connections must be in
pace for CJI to be accessed. Careful consideration should be made regarding the accessibility of
audit records when developing the mobile audit scheme.
Access Control (CJIS Policy Section 5.5)
Access control associated to limited functionality mobile operating systems will typically operate
in a different manner than full function operating systems. For instance there is normally not a
provision for multiple user accounts on many mobile operating systems which may mean the
policy requirements for access control (e.g. regarding account management) would not be apply
to the mobile operating system, but should rather be applied to a particular application, either
stand-alone to the device or as part of a client server architecture. Application of access control
policy identified in the CJIS Security Policy will often need to be applied to elements of the total
system beyond the device operating system.
For example, CJI stored or accessed from a secure mobile application that requires connectivity to
a CJIS authorized server architecture could potentially accomplish most or all of the access control
policy elements based on user authorization via the secured application and be largely independent
of the mobile operating system. Alternatively, if storing CJI in ‘general’ purpose data storage
containers on a mobile device it may not be possible to achieve compliance with the CJIS Security
Policy. Careful consideration and deliberate design of mobile applications or data storage will be
required to achieve compliance on mobile devices.
Due to the inherent nature of limited function mobile operating systems, very tight access controls
to specific data is actually implemented within the operating system. This effectively prevents
applications from accessing or manipulating data associated with other applications to a very high
degree of confidence as long as the device is not rooted or jailbroken. However, the device user is
automatically granted access to all device data through the associated application unless the
application itself has a secondary authentication and access control methodology. Additionally,
since basic device functions (e.g. phone) are typically protected using the same password or PIN
as the device level encryption, use of a weak PIN to allow easy access to basic device functions
largely negates the value of the integrated device encryption.
If personally owned devices are utilized within the environment (BYOD scenario), specialized and
costly access control methods may be required to reach compliance with CJIS Security Policy. The
costs associated with enhanced access control procedures and technologies should be incorporated
in the cost and risk based analysis to determine whether or not to allow personally BYOD, as the
technical methods and compensating controls required for CJIS Security Policy compliance are
likely to exceed any potential cost savings for implementing BYOD.

Device Control levels and access.
Limited function mobile operating systems are typically very constrained on the levels of access
provided to the user. However, intentional user actions (e.g. installing an application and accepting
inappropriate security access levels for that application) my bypass some of the built in security
protections inherent in the limited functionality devices. Compliance with CJIS Security Policy
may be difficult without the addition of strict device control policy. In a mixed environment (e.g.
agency owned devices and BYOD), access control policy with BYOD systems may be impractical
or impossible to fully implement.
Embedded passwords/login tied to device PIN.
Limited function mobile operating systems typically allow the association of multiple passwords
and access credentials with particular applications. The system access provided by these embedded
credentials will often be tied to the device password or PIN. An example would be access to device
integrated email and calendar applications. Alternatively a ‘corporate’ email application may
independently encrypt the data associated with the application and required a separate login from
the device itself. Access to CJI utilizing only the device level password or PIN and device
embedded credentials is not compliant with CJIS Security Policy unless protected with Advanced
Authentication, which is not currently possible on most devices. Therefore, use of integrated
device functions (e.g. built in email or chat) to store or transmit CJI would also not be compliant.
Access requirement specification
In general, due to weaknesses associated with password guessing based on analysis of fingerprints
or swipes on the device touch screen, short (4-8 digit) device PIN numbers provide limited security
to a determined password guessing attack. Conversely, utilization of a robust password at the
device level may be inconsistent with quick access to basic device functions (e.g. phone). When
developing specific CJIS compliant access control and authentication schemas a layered approach
with the device PIN protecting only the basic device functions (e.g. phone, camera, non-secure
applications) and a more robust password or multifactor authentication used to protect applications
or data storage may achieve policy compliance where the device password/PIN would not. In a
layered security deployment, careful attention must be placed on the capability to share data (e.g.
cut and paste or screenshot functions) between secure applications with CJI or CJI access and basic
device functions with limited security controls.
Special Login attempt limit
Depending on the access and authentication scheme applied to the mobile device, it may be
appropriate to fully comply with the CJIS login attempt limits within a secure application or
container and not solely at the device level. However, the device itself should have login attempt
limits consistent with the risk associated to the data or configurations accessible on the device
itself. Since mobile devices are inherently portable, and can easily be removed from a location.
Brute force attempts to gain access to the system, especially when protected only by a short PIN,
are likely to be successful given sufficient time. Special consideration should be made based on
device connectivity methods (cellular, WiFi, etc) on the appropriate number of unsuccessful login
attempts that will be allowed and the resultant actions taken by the device. Most devices either
natively allow for the device to wipe itself after a failed number of attempts, or allow the
application of EMM/MDM applications to perform wiping actions after a predetermined number
of failed login attempts.
Login failure actions
Mobile devices with or without MDM software can typically be configured to perform actions
based on serial unsuccessful login attempts. Appropriate actions to configure may be dependent
on the data resident on the device and the connectivity method employed by the device. Most
devices can be configured to delete all data on the device and/or issue an alert to the network if a
number of incorrect passwords are entered. This is a very advantageous feature, however specific
configuration of the number of attempts and resultant action must be considered against the state
of the device after an unsuccessful attempt action is triggered. A full device wipe will typically
leave the device in a fully or partially non-functional state which could introduce risk if part of the
intended use is time critical phone calls. Where possible, full device wipe associated with
unsuccessful attempts at the device level password should be configured but the number of invalid
attempts may exceed the CJIS Security Policy at the device level if all CJI on the device is
protected by an additional layer of encryption protected by a subsequent secure application
authentication method that is technically prevented (via complexity rules or entry rules) from being
the same as the device level authentication and the secure application is configured in accordance
with the policy and also contains a secure data wipe capability after a specified number of incorrect
authentication attempts.
System use Notification (CJIS Policy reference 5.5.4)
Agency policy should include specific mandatory language consistent with the CJIS Security
Policy to identify the device restrictions and consent. However, due to screen size limits, some
mobile devices may not be technically capable of displaying the full text used with traditional
operating systems. To achieve compliance agencies should contact their legal department for
appropriate wording of a short version of the system use notification that can be set to display
within the constraints of the device lock screen. This may be accomplished through embedding
the text into an image displayed on the lock screen or some other external device labeling method
if the device does not permit sufficient text to be displayed.
In a BYOD environment or mixed (agency owned and BYOD), it may be necessary to develop or
deploy custom applications that can achieve compliance with the system use notification upon
access and prior to any CJI access being allowed.
Session Lock (CJIS Policy reference 5.5.5)
Due to the portable nature of mobile devices the session lock limit in the general CJIS Security
Policy may be excessive in the mobile environment for certain device functions and insufficient
for other functions based on intended device usage. Agencies should examine the minimum lock
time practical for all mobile devices based on their employment scenario and ease for which a user
can manually lock the device. The actual session lock times should be adjusted as appropriate to
the device type, device operational location, and the data accessible on the device when unlocked.
Pocket size devices are at greatest risk if screen lock times are insufficient, however, for devices
used in emergency response or communication, extended lock times at the basic device level may
be considered if CJI is subsequently protected by an application or web interface utilizing more
stringent secure locking functions. A well designed solution may include multiple session lock
settings at the device and individual application levels to ensure the CJIS Security Policy
requirements are met for CJI access, while other device functions are accessible under different
session lock configurations.
Device WiFi Policy
Specific WiFi configuration policy should be developed based on the intended use environment
and data access requirements for the device. The policy should explicitly cover configuration of
device connections. Technical methods specific to the mobile technologies may need to be
implemented to ensure all mobile devices are compliant with CJIS Security Policy. Current CJIS
Security Policy provides detailed configuration requirements for WiFi connections, however it
was originally intended for defining requirements for fixed infrastructure WiFi (802.11)
supporting wireless within a facility. The security requirements identified for fixed infrastructure
installations are applicable to mobile usage, however there are several mobile specific scenarios
where the requirements may not be clear. The following sections identify areas not specifically
covered in the existing policy that will require special handling to ensure wireless connections are
compliant.
Hotspot capability
Many mobile devices now include the capability to activate an internal WiFi hotspot that allows
other devices to connect through the hosting device to the internet over the devices cellular radio.
While this is a potentially valuable capability when multiple law enforcement devices may need
localized internet or network access, mobile hotspots should be configured as consistent with the
CJIS Security Policy on wireless access points. Connections must only be accepted from known
and approved devices in order to protect the integrity of the hosting device as well as the
communications security of other connected devices. Since most mobile hotspots are not
technically capable of providing the device authentication required for infrastructure wireless, use
of mobile hotspot capability should assume the overall portable WiFi network itself is not secure
and CJI should not be transmitted or exposed on the network without appropriate encryption.
Connection to public hotspots
There are significant risks to connecting to public wireless access points. Rogue access points
masquerading as legitimate public access points may allow for man-in-the-middle, eavesdropping,
and session hijacking attacks. While not specifically prohibited in the current CJIS Security Policy,
it is recommended that connection to public internet access points be technically restricted by
device configuration or MDM systems if possible. CJI access mechanisms from mobile devices
should include robust authentication methods specifically designed to prevent interception or
hijacking of CJI or user information through the use of a rogue access point masquerading as a
legitimate public wireless access point. Transmission encryption alone may not provide sufficient
protections when device connections originate at public hotspots. Since the public hotspot controls
access to all network services at the connection point (e.g. Domain Name System) attacks against
the transmission path are possible that would not normally be feasible in a fixed environment
where communications exist between two secured network enclaves.
Cellular Service abroad
If mobile devices are used outside of the United States, especially if connected to foreign cellular
networks, specific handling procedures may need to be developed for the use of the device while
abroad and the assessment or configuration check of the device state once the devices are returned
to the United States. Certain device internal functions on cellular devices may be modified or
compromised by the cellular carrier as the devices are intended to have certain parameters
configured by the cellular service provider which is considered a ‘trusted’ entity by the device.
Cellular carriers within the United States are constrained by United States laws regarding
acceptable modifications to devices. Similar legal constraints cannot be assumed to exist in some
areas of the world where laws and regulations for data and personal privacy may allow cellular
carriers significantly more leeway in changes made to devices on their networks.
Security plans involving cellular connected devices that will be connected to foreign cellular
networks should include technical and policy controls to ensure device use while abroad, data
resident on the device while abroad, and the software integrity of the device once returned to the
United States are all appropriate to the specific device and threat levels associated with the
expected foreign travel. This should explicitly include considerations for devices in which an
internal subscriber identity module (SIM) card is inserted into the device to obtain Global System
for Mobile (GSM) cellular connections abroad to ensure any residual data on the SIM card is
properly purged. Additionally, incident handling procedures may need to specify more stringent
responses to even momentary loss of device control, and it may not be possible to assume tracking,
anti-theft, and remote data wipe functions that work in the United States would be functional in all
potentially visited geographic and political regions.
Bluetooth
Mobile devices utilizing Bluetooth should be evaluated for their ability to comply with the CJIS
Security Policy Bluetooth requirements prior to acquisition. This includes the data device itself
and any authorized Bluetooth accessories which will be associated to the device. While the
technical security in current versions of Bluetooth is significantly stronger than legacy versions,
mis-configuration of devices can still pose a significant threat in the mobile environment. If not
specifically utilized for a required purpose, it would likely be most cost effective to disable or
restrict the device Bluetooth radio utilizing device configurations or an MDM product.
Additionally, the using agency may need to develop technically extensive training or user
awareness programs to ensure use of Bluetooth capability does not render the device out of
compliance if device users have the ability to make Bluetooth associations to the device. Specific
instructions or guidance for specific devices could be developed to ensure all implementations are
compliant.
Voice/Voice over IP (VoIP)
Cellular voice transmissions are distinctly different at the technical level than Voice over IP (VoIP)
transmissions using voice/video applications (e.g. FaceTime, Skype). The use of VoIP is not
specifically granted the exemption identified in CJIS Security Policy Section 5.5.7.3.2. Agencies
wishing to use capability of this type should ensure the specific technical implementation complies
with the Policy on authentication and data encryption.
Chat/Text
Device integrated chat/texting applications and many common third party chat applications
authenticate and are identified using embedded passwords or the device identifier only. These
functions should not be considered secure or appropriate for transmission of CJI data. Texting
functions that utilize a cellular service providers Short Message Service (SMS) or Multimedia
Messaging Services (MMS) functions do not constitute a secure transmission medium. Third party
applications utilizing appropriate encryption and authentication methods independent of the device
password/PIN may provide a compliant solution where the device integrated utilities are will not
provide a compliant solution.
Administrative Access
Local administrative access to the mobile device, regardless of device category should be restricted
by some mechanism. For traditional operating systems, configuration of a separate administrative
account other than that used for normal logins to the device is an acceptable method to ensure
appropriate access permissions to the mobile user for which they are authorized. However for
limited functionality mobile operating systems (e.g. Android, Apple iOS) internal permissions and
accounts assume a single authorized device user with explicitly defined permissions. Those
permissions may be modified through policy applied to the device, but are typically global to the
device itself. As a result, to ensure appropriate separation of access permissions, it may be required
to ensure specific applications or software on the device are configured with individual
authentication methods to separate application data from ‘general user’ access. Without additional
authentication at the application level, access to specific application data would be available to any
user with the ability to unlock the device. This may be appropriate in some scenarios with a high
degree of assurance that the device can only be accessed by a single user, but sufficiently stringent
device passwords and short screen lock times may prove problematic for practical use of some
device functions. An alternate method to ensure strict separation of ‘routine’ device functions
which may be accessed by multiple individuals (e.g. phone function if loaned to someone for a
critical call) is to ensure any method used to access or store CJI has a separate and more stringent
authentication method configured with rules that make it impossible to use the same authentication
credential (e.g. PIN/Password) on both the device authentication and the application or function
with access to CJI.
Rooting/Jailbreaking
‘Rooting’ (Android OS) or ‘Jailbreaking (Apple iOS) refer to intentional modifications to the
mobile device operating system in order to grant the device user or an installed application elevated
control that would not normally exist on the device. The security model internal to the various
mobile device architectures vary significantly, however the common effect of rooting or
jailbreaking the devices is to bypass many or all of the built in security features. The security
feature bypass may be universal to all device features and installed applications once completed.
Intentionally rooting or jailbreaking mobile devices should be avoided in any scenario as it
potentially defeats all built-in data access and segregation controls on the device. Additionally the
rooting or jailbreaking process itself has a heightened risk of introducing malicious code as part of
the process, and also substantially increases the risk for malware to infect the device through user
action. Extreme caution should be used if software is being installed that requires the devices to
be rooted or jailbroken for the software or application to function. This is inclusive of purported
security software that requires a rooted or jailbroken device to function. For example, on both the
Android and Apple iOS platforms, the built-in security features for data access and memory
segmentation prevent the effective operation of ‘traditional’ anti-virus and intrusion
detection/prevention software. Software or applications purporting to perform these functions but
requiring rooting or jailbreaking of the device and may actually accomplish the anti-virus or
IDS/IPS function but are also likely to significantly increase the overall risk associated to the
device by effectively disabling most or all of the integrated security features. A careful risk-based
assessment should be conducted by a trained security professional prior to allowing the operation
of any rooted or jailbroken mobile devices regardless of intended use. Significant compensating
controls would be required to return a rooted or jailbroken device to minimal compliance with
most of the CJIS Security Policy and would likely not be a cost effective approach.
NOTE: There is a distinction between rooting a ‘stock’ Android installation vice the installation
of a separately supported secure operating system. There are secure versions of Android available
or that can be developed based on the open source Android source code and compiled for
installation on a particular hardware device. Installation of a secure, supported mobile operating
system that replaces the device original operating system may significantly enhance the security
of the device and should not be confused with ‘rooting’ and Android installation. Due to the close
integration of operating system security with hardware elements, and the proprietary nature of
Apple source code, there are not currently separate ‘secure’ versions of the Apple iOS and it is
unlikely they will be developed.
Identity and Authentication
Due to the technical methods used for identity and authentication on many limited functionality
mobile operating systems, achieving compliance to CJIS Security Policy may require layering of
identification and authentication mechanisms. With the complexity and large number of potential
identity and authentication solutions in the mobile environment emphasis must be placed on
designing secure identity management and authentication architecture prior to the selection of
individual devices or applications. Failure to consider a robust identity and authentication scheme
as part of system design or acquisition will significantly increase the risk of subsequent
noncompliance with CJIS Security Policy and potential added costs for a remedial solution. Many
identity and authentication schemes used by existing commercial applications may make claims
that appear to be consistent with CJIS Security Policy Advanced Authentication requirements,
however, extreme care must be taken to ensure the actual technical implementation is compliant
with policy.
Utilizing Unique device Identification
Some commercial applications and features integrated with some mobile operating systems permit
the mobile device to be uniquely identified in a cryptographically robust manner. Any
authentication schema that considers the possession of the mobile device as a factor in uniquely
identifying and authenticating a CJIS authorized user must also include factors beyond than mere
possession of the device. Larger form factor devices that cannot be carried on the person of the
authorized user should not rely on possession of the device as an identifying factor, but may still
include identifying capability within the device to provide assurance that the device itself is an
authorized device. This should still be coupled with multi-factor advanced authentication to the
device itself or the application hosting CJI. Coupling unique device authentication with robust
advanced authentication of the user provides a high degree of confidence that both the specific
device and the operator of the device are correctly identified. Utilizing device unique identification
in order to authorize initial connections from the remote device back to the CJI hosting system or
enclave provides additional protection to the CJI hosting system to reduce the attack surface of the
hosting system and should be considered a good practice, but not in itself an authentication
mechanism for the device user.

Certificate Use
One method for uniquely identifying mobile devices is to place part of a public key pair on the
device in the form of a public key certificate. While there is value to ensuring the device itself can
authenticate to a system supplying CJI, and may provide a critical layer of identification or
authentication in a larger scheme, a certificate alone placed on the device should not be considered
valid proof that the device is being operated by an authorized CJIS user, only that the device itself
is authorized to host CJIS users. Additional user identification and authentication should be used
to supplement any device certificate installed. Using a PIN or password separate from the device
login to ‘unlock’ the certificate from cryptographic storage within a secure application will provide
an additional layer of security and may increase the confidence level the device is being used by
the intended user. However, use of public/private key pairs or pre-shared encryption keys can be
utilized as part of an architecture to protect against certain session hijacking or man-in-the-middle
attacks a mobile device may be susceptible to if connected to public internet connections.
Certificate Protections
Any certificates or cryptographic keys stored on any mobile device should include protections
against the certificate or key being extracted from the device. Additionally certificates or other
keys stored on mobile devices that grant the device special access or unique identification should
be configured for remote wipe on demand or self-deletion based on a number of unsuccessful login
or access attempts. Alternatively, methods may be used to revoke or invalidate the unique
certificate or keys associated with a device.
Minimum Password/Pin (Reference CJIS Security Policy Section 5.6.2.1)
The minimum password protections identified in the CJIS Security Policy may not be appropriate
for the device PIN/password due to immediate access requirement for some device functions (e.g.
phone function) secured by the device PIN/password and the difficulty to enter a complex
password under emergency conditions on a small screen. In cases where the risk of a complex
password on the device itself is deemed significant, a layered authentication approach may be
necessary where CJI or access to CJI is protected via one or more additional layers of access
control beyond the device PIN/password. In cases where the CJI or access to the CJI is
cryptographically segregated from applications accessible using the device level PIN/Password
(e.g. secure application or secure browser vice the built-in browser) the authentication mechanism
for the secure application or browser may satisfy the CJIS Security Policy requirements if fully
compliant as a stand-alone application.
Configuration Management
Due to the potential for inconsistent network access or monitoring capability on mobile devices,
methods used to monitor and manage the configuration of traditional full featured operating
systems may not function properly on limited function mobile operating systems. Configuration
Management systems in the mobile environment may be designed in order to duplicate some of
the functions typically performed by traditional anti-malware systems that will not function
properly on some mobile operating systems.
Mobile Device Management (MDM)/Enterprise Mobility Management (EMM)
MDM and EMM systems and applications coupled with device specific technical policy can
provide a robust method for device configuration management if properly implemented. MDM
capabilities include the application of mandatory policy settings on the device, detection of
unauthorized configurations or software/applications, detection of rooting/jailbreaking of the
device, and many other security policy related functions. In many cases, the most cost effective
way to achieve CJIS Security Policy compliance on mobile devices is the selection of MDM or
EMM applications and infrastructure appropriate to the mobile operating systems and intended
access to CJI on the mobile devices. MDM/EMM functions may be applicable to most of the CJIS
Security Policy requirements and allow for significant compensating controls in areas where
traditional methods of CJIS Security Policy compliance are not technically feasible. Section
5.5.7.3.3 of the CJIS Security Policy specifies the minimum functions required for MDM.
However, careful selection of the MDM product will potentially provide a cost effective method
for additional areas of compliance in the access, auditing, incident response, authentication, media
protection and system integrity sections of the CJIS Security Policy.
Device Backups/Images
Device images and backups provide protection against data loss, but also provide a method to
quickly recover a device after damage or potential compromise. Due to an inherently limited ability
to access the internal file structure of mobile devices, it can be difficult to easily identify a device
compromise or illicit modification of the device. Some device imaging and assessment software
may provide a secondary forensic capability, especially if there is intent for the device to be used
outside the United States.
Bring Your Own device (BYOD) employment
BYOD environments pose significant challenges to the management of secure device
configurations. In many cases it may be impossible to apply effective security that is acceptable to
the device owner or it may require extremely costly compensating controls to allow access to CJI
on personally owned devices. While allowed by the CJIS Security Policy, agencies are advised to
conduct a detailed cost analysis of the ancillary costs of compliance with CJIS Security Policy on
personally owned devices when they are approved for use. In some cases, a BYOD user may agree
to abide by the same device configurations and limitations as imposed on an agency owned device,
but signed user agreements should still be in place to ensure the agency has a legal right to recover
or clear the device of all data prior to device disposal or employee termination. In other cases,
robust secure applications may provide acceptable levels of compliance in a BYOD environment
for limited CJI access but application design and architecture should assume the device itself is
un-trusted. If MDM/EMM software capable of detecting rooting or jailbreaking of the device is
not installed, any CJIS or data access occurring from the device is at a substantially higher risk of
compromise.
Configurations and tests
Common configurations specific to all employed mobile devices should be developed to ensure
compliance. Configuration tests should be developed and executed on all versions of mobile
devices under all possible connectivity scenarios to ensure CJIS Security Policy compliance under
all expected operating conditions. Since mobile devices can expect to operate in different physical
and network environments, testing and validating correct security functions is more critical than
on fixed computing platforms. Additionally, security functions that function properly on one
version of a mobile operating system on a particular device may not function in the same manner
even on the same version on a different device or a different version on the same device.

Media Protection
Some mobile device hardware platforms include the ability to add removable storage in the form
of memory cards. This function is primarily related to Android and Windows mobile platforms
and is intentionally limited on Apple devices, but may be possible through certain application
functions. While the Android platform performs robust cryptographic separation of data stores
between applications within the ‘internal’ storage of the device, the Android OS does not provide
secure separation of data stores on ‘external’ storage. Some Android hardware devices include
additional storage hardwired inside the device that is classified by the operating system as external
storage and the normal separation between applications accessing that storage is not applied. Each
potential device considered for acquisition must be assessed regarding specific ‘external’ media
protection requirements which may actually include built-in media or storage.
Protection of device connected media
As a result of the limited protection and encryption capabilities applied to device removable media
and SIM cards for cellular provisioning that include onboard data storage, all externally removable
media or memory should be handled consistently with the CJIS Security Policy on media
protection.
Encryption for device media
While most mobile operating systems have the capability to encrypt internal storage, it may require
specific device settings to be enabled. All mobile device storage should meet the encryption
requirements identified for media in the CJIS Security Policy. Specific settings may need to be
applied to ensure proper encryption is actually employed. Additionally, the device built-in
encryption capability is typically tied to the device PIN or password. Depending on the device PIN
or password requirements the integrated encryption may be easily bypassed by password guessing
and appropriate consideration should be made to ensure additional encryption protected by
advanced authentication methods be applied to all CJI.
Physical Protection
Due to small form factors and the fact that mobile devices are often stored in lower security areas
and vehicles, physical protection of the devices must be considered in both policy and training.
Physical protections will often be the responsibility of the assigned device user and physical
protections typically inherited by individual information systems from a secure facility will not be
available to mobile devices which will require compensating controls to achieve compliance.
Device Tracking/Recovery
MDM software as well as some integrated mobile operating system functions may allow tracking
of stolen or lost devices via ‘always-on’ cellular data connections and the devices built-in GPS.
Device tracking with WiFi only or ‘on-demand’ cellular access may not be reliable. Enabling
device tracking capabilities, while not a replacement for secure storage, could be a compensating
control used to substantially reduce overall device risk in some scenarios. Device tracking is not
currently required in the CJIS Security Policy but should be applied to agency owned devices
where possible as a risk mitigation factor. Enabling of device tracking on personally owned devices
in a BYOD environment may raise employee privacy concerns and should be considered only for
critical systems with the full knowledge of the employee and concurrence of the legal department.
This is an enhanced risk that must be accepted for BYOD employments and should be considered
when allowing BYOD employment. Device tracking is available for both limited function mobile
operating systems as well as traditional operating systems installed on laptop devices.
Access to device tracking software or applications within the organization should be controlled
with limits and formal processes required to initiate a tracking action. It is advisable to include
appropriate clauses in user agreements under what conditions and controls the organization applies
to device tracking.
Devices utilizing unique device identification/certificates
Devices utilizing unique device identification or have installed certificates may require additional
physical protection and/or additional incident handling steps in case of device loss in order to
ensure the device unique identifier or certificate is immediately revoked or disabled. Additional
physical protection rules or policy would be appropriate for any device which contains access
mechanisms tied to the device.
System Integrity (CJIS Policy Section 5.10)
Managing system integrity on limited function mobile operating systems may require methods and
technologies significantly different from traditional full feature operating systems. In many cases
the requirements of Section 5.10 of the CJIS Security Policy cannot be met with a mobile device
without the installation of a third party MDM or EMM application and supporting server
infrastructure.
Patching/Updates
MDM software may provide compliance to the Section 5.10.4.1 patch management requirements
for particular platforms and software versions. However, devices without ‘always-on’ cellular
connections may not be reachable for extended periods of time by the MDM or EMM solution
either to report status or initiate patching. Supplementary or manual device accountability methods
may need to be implemented to account for devices without persistent connections to ensure their
patch and update state is current. Alternatively, some patches or system updates may not be
practical over cellular connections and will require connection of devices to a WiFi network.
Compliance with CJIS Security Policy requirements through purely technical means may not be
practical and considerations should be made for aggressive management of devices through
training and mandatory periodic connection of devices to organizationally managed WiFi
networks.
TECHNOLOGY NOTE: Apple and Android based devices have different potential issues
regarding device operating system updates. Apple maintains support for updating the operating
system on Apple hardware for several device generations (typically 3-5 years) and provides a
robust mechanism for system updates. However, updates to Android based systems are driven by
the individual device manufacturer which may or may not support regular updates to current
Android operating system versions. Additionally, different Android device vendors may offer
updates/upgrades to the Android operating system on different schedules, which can complicate
environments utilizing Android devices from multiple manufacturers.
Malicious code protection/Restriction of installed applications and application permissions
MDM or EMM software will typically allow restrictions on installed applications. One of the few
effective attack vectors to compromise mobile operating systems is to manipulate the device user
to install a malicious application. Even though the application may be restricted from accessing
other application data, it may have some access to common data stores on the device and access
to device functions (e.g. GPS, microphone, and camera) that are undesirable. Unrestricted
installation of applications by the device user could pose a significant risk to the device.
Malicious code protection using traditional virus scanning software is technically infeasible on
most limited function mobile operating systems that are not rooted or jailbroken. The integrated
data and program separations prevent any third party installed program from accessing or
‘scanning’ within another application data container. Even if feasible, power and storage
limitations would be prohibitive in the effect on device battery life and storage capacity on most
mobile devices. However, the cryptographic separation between applications and effective
application virtualization technologies built into common mobile operating systems partially
compensate for the lack of traditional virus scanning technologies. Appropriately configured
MDM software is capable of checking the installed applications on the device and reporting the
software inventory to a central management console in a matter analogous to traditional virus scan
detection of unauthorized software. This behavior is analogous to the software inventory
performed by anti-virus products and can provide a high degree of confidence that only known
software or applications are installed on the device. While it is theoretically possible to bypass the
application sandboxing and data segregation protections to compromise a mobile device through
the web browser, the attack methods required are significantly more advanced than those required
for a traditional full featured operating system. Malicious code protections on the device web
browser can be enforced through the use of a properly protected web proxy which the device is
configured to use as a mandatory device policy. The most common method of malicious code
installation is enticing the user to manually install the malicious app which can be mitigated on
organizational devices using an MDM or other application installation restrictions which prevent
the user from installing unauthorized or unknown applications. Mitigation of this issue within
BYOD environments may not be possible and will present a significantly enhanced risk to the
device.
TECHNOLOGY NOTE: In the particular area of application installation there is a significant
difference between the behavior of Apple iOS and Android platforms. Apple cryptographically
restricts the way applications will execute on the device and assigns mandatory application
permissions when the application code is signed prior to release on the Apple App Store for
distribution. Apps on the Apple platform must conform to Apple’s policy on app behavior and
cannot exceed their design permissions on access to common device functions once the app has
been signed and distributed. However, the Apple method does not typically advertise the precise
internal permissions granted to the app to the user prior to installation. At runtime, the app is
required to request user permission to access certain device functions, and the user may agree or
not agree, which may introduce risk if they are unaware of what they are agreeing to allow.
Unsigned or un-trusted apps are cryptographically prevented from executing on non-jailbroken
iOS devices. Apple provides a mechanism for organizations to distribute custom apps within an
organization with equivalent protections but all receiving devices must have a special certificate
installed that will only allow official App Store and the organization custom apps to execute.
Conversely, the Android platform, while also requiring app code signing, allows for self-signed
code which can be distributed be means other than an official app store and execute on any Android
device. Application permissions are presented to the user once at app installation but ramifications
of agreement to certain app permissions may not be obvious to a non-technical user. Permissions
in the Android model require user acceptance of all app requested permissions or the app is denied
installation, which can result in unwise user acceptance of excessive permissions in order to gain
functionality provided by the app.
On either platform user installation of applications can significantly change the security state of
the device. Applications may be able to transmit and receive data or share device common data
with other devices over the network or local WiFi or Bluetooth connection. On either platform it
is highly desirable to limit allowable applications to a pre-approved pool of apps via MDM or
organizational App store structures and device policy. However, the risks associated with
uncontrolled app installation is several orders of magnitude greater on Android based devices.
WARNING: Rooted or jailbroken devices are modified in such a manner that the built in
protections against malicious code are effectively disabled. A rooted or jailbroken device would
require significant and costly compensating controls to achieve compliance.
Firewall/IDS capability
Traditional device or “personal’ firewalls as identified in CJIS Security Policy Section 5.10.4.4
may not be practical on limited function mobile device operating systems but significant
compensating controls are available. By default, mobile device operating systems have a limited
number of system services installed and carefully controlled network access. To a certain extent
the mobile operating system performs similar effective functions as a personal firewall would
perform on a general purpose operating system. Potential compensating controls for the five (5)
personal firewall requirements specified in Section 5.10.4.4 are listed below:
1. Manage Program Access to the Internet: On agency controlled devices with an MDM,
limiting the apps installed on the device will effectively perform the same function. Since
no software or apps can be installed without MDM approval a robust approval process
can effectively ensure internet access is only granted to approved apps. Built-in apps and
functions can also be limited on network access by the MDM.
2. Block unsolicited requests to connect to the user device: Default configurations for
mobile operating system platforms typically block incoming requests. It is possible to
install an app that may ‘listen’ on the network and accept connections, but the same
compensating control identified in item 1 will mitigate the likelihood of that occurring.
3. Filter incoming traffic by IP address or protocol: Protocol filtering effectively occurs due
to the limited function of the operating sys long as no installed application opens network
access ports. The mitigations in 1 effectively compensate for this control as well.
4. Filter incoming traffic by destination ports: Same as 3.
5. Maintain an IP traffic log: This may not be technically feasible on most mobile operating
system platforms as maintaining this log would require access to lower level operating
system functions that are not accessible unless the device is rooted or jailbroken.
However, individual Apps that communicate over the network or accept connections
from the network may permit logs of IP traffic associated to that application to be stored.

Spam Protection
Spam guards installed on corporate or organizational email systems may effectively accomplish
the spam protection requirements for the CJIS Security Policy on mobile devices if properly
configured to block spam before delivery to the device. If no upstream spam guard is installed on
the mail server the mobile devices accesses, the device may not have adequate spam protection.
Additionally access to internet based email (web mail) would need to be restricted to web mail
with appropriate spam and/or antivirus protections to ensure compliance.
Periodic system integrity checks
One method to compensate for the technical infeasibility of traditional anti-virus and malicious
code protection is to install an MDM that performs periodic system integrity checks that validate
device configuration and status against an approved baseline. Deviations may provide indicators
of potential device compromise or mis-configuration.

G.5 Administrator Accounts for Least Privilege and Separation of
Duties
Administrator Accounts for Least Privilege and Separation of Duties
PURPOSE:
This appendix is provided to describe industry best security practices for assigning separate
administrator accounts to support the concept of Least Privilege.
ATTRIBUTION:
SANS, “The Critical Security Controls for Effective Cyber Defense”, version 5.0
NIST SP 800-53, “Security and Privacy Controls for Federal Information Systems and
Organizations”, Revision 4 dated April 2013
NIST SP 800-12, “An Introduction to Computer Security: The NIST Handbook” dated October
1995
CNSSI-4009, “National Information Assurance (IA) Glossary”, dated April 2010

DEFINITIONS:
Least Privilege – The principle that security architecture be designed to grant individual users and
processes only the minimum accesses to system resources and authorizations required to perform
their official duties or function.
Separation of Duties – The security principle requiring the division of roles and responsibilities so
that a single individual cannot subvert a critical process or function.
SUMMARY:
The implementation of least privilege is accomplished by assigning user or process access to
system resources based on operational or business needs. Thus, access is granted to only those
resources required to perform assigned duties. For individuals who have multiple roles within the
organization requiring varying levels privileges, this assignment of access can be challenging.
Often times the agency will assign a single userid to the individual and elevate the privileges for
that account based on the different roles. While it may seem logical to allow the user access to all

required resources using a single account, security vulnerabilities can be introduced into the
system.
Associated with least privilege is separation of duties. This concept aids in maintaining the
integrity of the system by preventing the abuse of elevated privileges for making unauthorized
changes to the system. This objective essentially requires different individuals to perform separate
functions with relation to (primarily) administrative duties. For instance, those with the ability to
create and assign user access to system should not be able to access the audit logs that contain the
evidence of the account actions.
USER ACCESS AND ACCOUNT MANAGEMENT:
Several factors influence the manner in which an agency implements and manages user access.
Many times, the size of the agency and the technical expertise of the IT staff employed by the
agency become primary drivers. Larger agencies with a broad base of technically savvy personnel
normally have the ability to dedicate resources specifically to the administration and management
of user access. This could translate to the use of multiple accounts for a single user performing
duties requiring varying levels of access.
Smaller agencies with few or no technically experienced personnel will often assign single user
accounts with the highest level of access required by users. Other smaller agencies may go as far
as assigning every user an account with elevated privileges so there are no delays or problems
requiring intervention by already overburdened system administrators. It is not uncommon for a
smaller agency to outsource system administration duties.
Regardless of the size or resources of an organization, each agency should base the process for
assigning access to system resources based on their operational requirements and a thorough risk
assessment. To mitigate risk for accessing system resources, industry best security practices
prescribe those individuals performing duties requiring elevated privileges be assigned a separate
userid to be used in the performance of those duties. This account would be separate from a
standard user account.
Why are some agencies unwilling to implement controls for least privilege? One common
reason/perception is administrative overhead. There is a time factor for a system administrator to
create user accounts and configure those accounts correctly based on the user’s role. In larger
agencies with many employees, this could add up to a significant impact on the system
administrator(s) especially if there is a high level of turnover. Resources in some agencies may
allow for a single system administrator dedicated strictly for account management. On the other
end of the spectrum, in agencies with fewer employees, the impact may be more burdensome.
While there are fewer user accounts to manage, a full-time system administrator for account

management may not be feasible. Those duties then become shared between a few people or added
to the duties of a lone person.
Another reason may be the burden on system administrators to remember multiple userids and
passwords. This could result in the user using the same password for each account or the user
writing down the credentials for ease of remembrance. Additionally, an administrator could get
the credentials mixed up between accounts causing an account lockout. This could then require
system administrator intervention to reset or unlock the account.
Some agencies may feel that creating additional accounts reduces system resources. Depending on
the size of the agency, this could be a concern. In most cases, the number of individuals that would
require a secondary account would be minimal. The impact could be limited to a slight increase in
disk space usage on the systems accessed by the system administrators with the separate accounts
and perhaps the server housing the account information.
THREATS:
A primary goal of attackers is to gain administrative or root privileges on a network or system.
Therefore, protection of credentials with that level of access is a key to preventing unauthorized
access. Attackers may use many methods in attempts to gain unauthorized, privileged access to
computer or network systems. There are two common techniques that take advantage of
improperly managed administrative privileges.
Phishing Attacks
In this first method, consider a small organization with limited system administrative resources.
Each user is assigned an account with elevated privileges that allows them to perform a myriad of
duties including gaining access to critical system security resources. Because this is the only
account the user has, normal non-administrative duties are also performed with administrative
rights. While checking their email, the user is fooled into reading a message and opening a
malicious attachment. Because the user’s account has elevated privileges, malware is now installed
on the system with elevated privileges. The malware could now allow the attacker to take over the
system and install other malicious software such as key loggers, sniffers, or remote control
applications. Other key system resources such as firewalls, routers, switches, or intrusion detection
systems are now also compromised.
Password Brute Force Guessing / Cracking
The second method may not be as easy as the first and involves the guessing or cracking of
passwords on the part of the attacker. Based on human nature, we tend to develop passwords that
are easy to remember and most likely contain some kind of information that is pertinent to us.
Some passwords could be easily guessed with a minimal amount of social engineering or fact
finding. Consider again an agency that assigns users a single account to perform all duties
including those requiring elevated privileges. A user has created a password that, while meeting
the requirements of the CJIS Security Policy, is comprised of easily guessed information about the
user. An attacker has previously determined the userid and is now able to begin guessing the
password. Upon success, the attacker will have unauthorized access to critical system resources.
MITIGATION:
The first step to implementing least privilege is to create separate user accounts for those
individuals that require elevated privileges for their duties. These duties could include system or
security administration, reviewing audit logs, backup administration, or configuring network
devices (e.g. firewalls, routers). The passwords associated with these accounts should have a
higher level of complexity than an account without elevated privileges. By disassociating the
access levels required for system administration functions from an individual’s “everyday use
account”, should a password be compromised, access would be limited to that of a user with nonelevated privileges.
Second is to implement procedures to ensure accounts with elevated privileges are used only for
those duties requiring the higher level of access. This would mean disabling or blocking access to
email, web browsers, and other external facing connections. While technical processes are the
preferred method of preventing the misuse of accounts with elevated privileges, written policies
can be used in situations where technology does not support that type of account management.
Several governance organizations recognize the importance of the security value of Least
Privilege. The Payment Card Industry (PCI) includes requirements in their Data Security Standards
(DSS). The National Institute of Standards and Technology (NIST) addresses the concept of Least
Privilege in its Special Publication (SP) 800-53 rev. 4. While not considered a governance
organization, the System Administration, Networking, and Security (SANS) Institute publishes a
list of the top 20 security controls which includes “Controlled Use of Administrator Privileges” at
number 12. Although the actual security controls or required implementation may slightly differ,
the concept is consistent across the groups. The actual controls from NIST and SANS are included
here in this appendix.
NIST CONSIDERATIONS FOR LEAST PRIVILEGE:
NIST Special Publication 800-53 rev. 4 includes controls required for all systems under the Federal
Information Security Management Act. The publication specifies the guidance for Least Privilege
in the control catalog under the Access Control (AC) family and specifically as AC-6. While the
NIST requirements are not enforceable under the CJIS Security Policy, they were the genesis of
the Policy and do provide a sound security baseline that can be leveraged by the criminal and
noncriminal justice community. AC-6 is a key control having several enhancements which, when
implemented, bolster the overall security of the information system by reducing the risk of
compromise through the misuse or misconfiguration of access to system resources.
AC-6 Least Privilege
Control: The organization employs the principle of least privilege, allowing only authorized
accesses for users (or processes acting on behalf of users) which are necessary to accomplish
assigned tasks in accordance with organizational missions and business functions.
Supplemental Guidance: Organizations employ least privilege for specific duties and information
systems. The principle of least privilege is also applied to information system processes, ensuring
that the processes operate at privilege levels no higher than necessary to accomplish required
organizational missions/business functions. Organizations consider the creation of additional
processes, roles, and information system accounts as necessary, to achieve least privilege.
Organizations also apply least privilege to the development, implementation, and operation of
organizational information systems. Related controls: AC-2, AC-3, AC-5, CM-6, CM-7, PL-2.
Control Enhancements:
(1) LEAST PRIVILEGE | AUTHORIZE ACCESS TO SECURITY FUNCTIONS
The organization explicitly authorizes access to [Assignment: organization-defined security
functions (deployed in hardware, software, and firmware) and security-relevant information].
Supplemental Guidance: Security functions include, for example, establishing system accounts,
configuring access authorizations (i.e., permissions, privileges), setting events to be audited, and
setting intrusion detection parameters. Security-relevant information includes, for example,
filtering rules for routers/firewalls, cryptographic key management information, configuration
parameters for security services, and access control lists. Explicitly authorized personnel include,
for example, security administrators, system and network administrators, system security officers,
system maintenance personnel, system programmers, and other privileged users. Related controls:
AC-17, AC-18, AC-19.
Control Enhancements:
(2) LEAST PRIVILEGE | NON-PRIVILEGED ACCESS FOR NONSECURITY FUNCTIONS

The organization requires that users of information system accounts, or roles, with access to
[Assignment: organization-defined security functions or security-relevant information], use
non-privileged accounts or roles, when accessing nonsecurity functions.
Supplemental Guidance: This control enhancement limits exposure when operating from within
privileged accounts or roles. The inclusion of roles addresses situations where organizations
implement access control policies such as role-based access control and where a change of role
provides the same degree of assurance in the change of access authorizations for both the user and
all processes acting on behalf of the user as would be provided by a change between a privileged
and non-privileged account. Related control: PL-4.
(3) LEAST PRIVILEGE | NETWORK ACCESS TO PRIVILEGED COMMANDS
The organization authorizes network access to [Assignment: organization-defined privileged
commands] only for [Assignment: organization-defined compelling operational needs] and
documents the rationale for such access in the security plan for the information system.
Supplemental Guidance: Network access is any access across a network connection in lieu of local
access (i.e., user being physically present at the device). Related control: AC-17.
(4) LEAST PRIVILEGE | SEPARATE PROCESSING DOMAINS
The information system provides separate processing domains to enable finer-grained
allocation of user privileges.
Supplemental Guidance: Providing separate processing domains for finer-grained allocation of
user privileges includes, for example: (i) using virtualization techniques to allow additional
privileges within a virtual machine while restricting privileges to other virtual machines or to the
underlying actual machine; (ii) employing hardware and/or software domain separation
mechanisms; and (iii) implementing separate physical domains. Related controls: AC-4, SC-3, SC30, SC-32.
(5) LEAST PRIVILEGE | PRIVILEGED ACCOUNTS
The organization restricts privileged accounts on the information system to [Assignment:
organization-defined personnel or roles].

Supplemental Guidance: Privileged accounts, including super user accounts, are typically
described as system administrator for various types of commercial off-the-shelf operating systems.
Restricting privileged accounts to specific personnel or roles prevents day-to-day users from
having access to privileged information/functions. Organizations may differentiate in the
application of this control enhancement between allowed privileges for local accounts and for
domain accounts provided organizations retain the ability to control information system
configurations for key security parameters and as otherwise necessary to sufficiently mitigate risk.
Related control: CM-6.
(6) LEAST PRIVILEGE | PRIVILEGED ACCESS BY NON-ORGANIZATIONAL USERS
The organization prohibits privileged access to the information system by nonorganizational users.
Supplemental Guidance: Related control: IA-8.
(7) LEAST PRIVILEGE | REVIEW OF USER PRIVILEGES
The organization:
(a) Reviews [Assignment: organization-defined frequency] the privileges assigned to
[Assignment: organization-defined roles or classes of users] to validate the need for such
privileges; and
(b) Reassigns or removes privileges, if necessary, to correctly reflect organizational
mission/business needs.
Supplemental Guidance: The need for certain assigned user privileges may change over time
reflecting changes in organizational missions/business function, environments of operation,
technologies, or threat. Periodic review of assigned user privileges is necessary to determine if the
rationale for assigning such privileges remains valid. If the need cannot be revalidated,
organizations take appropriate corrective actions. Related control: CA-7.
(8) LEAST PRIVILEGE | PRIVILEGE LEVELS FOR CODE EXECUTION
The information system prevents [Assignment: organization-defined software] from executing
at higher privilege levels than users executing the software.
Supplemental Guidance: In certain situations, software applications/programs need to execute with
elevated privileges to perform required functions. However, if the privileges required for execution
are at a higher level than the privileges assigned to organizational users invoking such
applications/programs, those users are indirectly provided with greater privileges than assigned by
organizations.
(9) LEAST PRIVILEGE | AUDITING USE OF PRIVILEGED FUNCTIONS
The information system audits the execution of privileged functions.
Supplemental Guidance: Misuse of privileged functions, either intentionally or unintentionally by
authorized users, or by unauthorized external entities that have compromised information system
accounts, is a serious and ongoing concern and can have significant adverse impacts on
organizations. Auditing the use of privileged functions is one way to detect such misuse, and in
doing so, help mitigate the risk from insider threats and the advanced persistent threat (APT).
Related control: AU-2.
(10) LEAST PRIVILEGE | PROHIBIT NON-PRIVILEGED USERS FROM EXECUTING
PRIVILEGED FUNCTIONS
The information system prevents non-privileged users from executing privileged functions
to
include
disabling,
circumventing,
or
altering
implemented
security
safeguards/countermeasures.
Supplemental Guidance: Privileged functions include, for example, establishing information
system accounts, performing system integrity checks, or administering cryptographic key
management activities. Non-privileged users are individuals that do not possess appropriate
authorizations. Circumventing intrusion detection and prevention mechanisms or malicious code
protection mechanisms are examples of privileged functions that require protection from nonprivileged users.
References: None.
Priority and Baseline Allocation:

P1

LOW Not Selected

MOD AC-6 (1) (2) (5) (9) (10)

HIGH AC-6 (1) (2) (3) (5) (9) (10)

SYSTEM ADMINISTRATION,
NETWORKING,
CONSIDERATION FOR LEAST PRIVILEGE:
There are many negative factors that affect our cyber lives: massive data loss, intellectual property
theft, credit card breaches, and identity theft just to name a few. Cyber defense is rapidly evolving
to address the plethora of challenges we face. Defenders have access to a wide array of resources
to combat those wishing to do harm. Ranging from the collection of vast amounts of intelligence
data to security standards to training and certifications, security practitioners are well armed.
But can information overload actually worsen the problem? Organizations must decide, hopefully
based on risk analysis, how to wade through all available resources and select those best suited to
their own operating environment. The threats continue to evolve, the attackers become smarter,
and user access more mobile. The cloud beckons and can provide reduced cost and infrastructure
at a price of less control and accountability for vital information.
The SANS Institute publishes the “20 Critical Security Controls for Effective Cyber Defense”.
This list of controls is the combined result of work by an international community to create, adopt,
and support the controls. The components of the community provide insight, tools, information,
and solutions into threats and adversaries. This list includes the control titled “Controlled Use of
Administrative Privileges”. SANS describes this control as: The process and tools used to
track/control/prevent/correct the use, assignment, and configuration of administrative privileges
on computers, networks, and applications.
Critical Security Control (CSC) 12: Controlled Use of Administrative Privileges
The processes and tools used to track/control/prevent/correct the use, assignment, and
configuration of administrative privileges on computers, networks, and applications.

ID #
CSC 12--‐1

Description
Category
Minimize administrative privileges and only use Quick win (One of
administrative accounts when they are required. Implement the “First Five”)
focused auditing on the use of administrative privileged
functions and monitor for anomalous behavior.

CSC 12--‐2

Use automated tools to inventory all administrative accounts Quick win
and validate that each person with administrative privileges on
desktops, laptops, and servers is authorized by a senior
executive.
Configure all administrative passwords to be complex and Quick win
contain letters, numbers, and special characters intermixed,
and with no dictionary words present in the password. Pass
phrases containing multiple dictionary words, along with
special characters, are acceptable if they are of a reasonable
length.

CSC 12--‐3

CSC 12--‐4

Before deploying any new devices in a networked Quick win
environment, change all default passwords for applications,
operating systems, routers, firewalls, wireless access points,
and other systems to have values consistent with
administration--‐level accounts.

CSC 12--‐5

Ensure that all service accounts have long and difficult--‐ to--‐ Quick win
guess passwords that are changed on a periodic basis, as is
done for traditional user and administrative passwords.

CSC 12--‐6

Passwords should be hashed or encrypted in storage. Quick win
Passwords that are hashed should be salted and follow
guidance provided in NIST SP 800--‐132 or similar guidance.
Files containing these encrypted or hashed passwords required
for systems to authenticate users should be readable only with
super--‐user privileges.

CSC 12--‐7

Utilize access control lists to ensure that administrative Quick win
accounts are used only for system administration activities,
and not for reading e--‐mail, composing documents, or surfing
the Internet. Web browsers and e--‐mail clients especially
must be configured to never run as administrator.

CSC 12--‐8

Through policy and user awareness, require that administrators Quick win
establish unique, different passwords for their administrative
and non--‐administrative accounts. Each person requiring
administrative access should be given his/her own separate
account. Users should only use the Windows “administrator”
or UNIX “root” accounts in emergency situations. Domain
administration accounts should be used when required for
system administration instead of local administrative accounts.

CSC 12--‐9

Configure operating systems so that passwords cannot be re--‐ Quick win
used within a timeframe of six months.

CSC 12--‐10

Configure systems to issue a log entry and alert when an Visibility/
account is added to or removed from a domain administrators’ Attribution
group, or when a new local administrator account is added on
a system.

CSC 12--‐11

Configure systems to issue a log entry and alert when Visibility/
unsuccessful login to an administrative account is attempted. Attribution

(NEW)

CSC 12--‐12

Use multifactor authentication for all administrative access, Configuration/
including domain administrative access. Multi--‐ factor Hygiene
authentication can include a variety of techniques, to include
the use of smart cards with certificates, One Time Password
(OTP) tokens, and biometrics.

CSC 12--‐13

When using certificates to enable multi--‐factor certificate--‐ Configuration/
based authentication, ensure that the private keys are protected Hygiene
using strong passwords or are stored in trusted, secure
hardware tokens.

(NEW)
CSC 12--‐14

Block access to a machine (either remotely or locally) for Configuration/
administrator--‐level accounts. Instead, administrators should Hygiene
be required to access a system using a fully logged and non--‐
administrative account. Then, once logged on to the machine
without administrative privileges, the administrator should
transition to administrative privileges using tools such as Sudo
on Linux/UNIX, RunAs on Windows, and other similar
facilities for other types of systems. Users would use their own
administrative accounts and enter a password each time that is
different than their user account.

Quick win: Implementation provides significant risk reduction without major financial,
procedural, architectural, or technical changes to an environment, or that provide substantial and
immediate risk reduction against very common attacks that most security-aware organizations
prioritize these key controls.
Visibility / attribution: Measures to improve the process, architecture, and technical capabilities of
organizations to monitor their networks and computer systems to detect attack attempts, locate
points of entry, identify already-compromised machines, interrupt infiltrated attackers’ activities,
and gain information about the sources of an attack.
Configuration / hygiene: reduce the number and magnitude of security vulnerabilities and improve
the operations of networked computer systems, with a focus on protecting against poor security
practices by system administrators and end-users that could give an attacker an advantage.
SEPARATION OF DUTIES:
Separation of duties is another security control related to least privilege. Many of the same
challenges faced by least privilege apply to this concept as well. Agency size and resources play a
major in the implementation of separation of duties. As the name implies, some key functions
should be separated between different individuals. The goal of this concept is to provide protection
against a single individual’s ability to circumvent system security controls to gain unauthorized
access or perform unauthorized actions without colluding with other individuals.
Simply put separation of duties entails distributing certain critical mission oriented functions or
system administrative support functions amongst different individuals or roles. It also includes
delineating information system support duties such as auditing, configuration control, or network
security between different individuals.
As with least privilege, an agency’s ability to implement separation of duties is typically based on
financial and personnel resources. While a very large agency may have ready availability to those
resources to ensure critical functions are spread across multiple individuals, a small agency
probably does not have that luxury.
THREATS:
What effect can an individual with carte blanc access to all critical functions of a system have?
Consider a single individual with the ability to install nefarious applications on a system (e.g. a
keylogger). If this same individual also has the ability to edit any audit logs that would have
recorded the actions of installing the software, those entries could be deleted and any evidence of
the installation eliminated.
Perhaps a disgruntled system administrator wants to open a port on a firewall to allow a remote
backdoor connection into the information system in order to siphon off criminal justice
information. Because the perpetrator has access to the firewall and all logs, the port can be opened
and the logs tampered with to eliminate records of the action.
As mentioned previously, the two concepts of least privilege and separation of duties are related.
Additional threats are presented when a system administrator using a single account with unlimited
elevated privileges across the information system uses that account to check email. In a successful
phishing attack that compromises this account, the attacker now has unrestricted unauthorized
access to all system resources and the ability to hide their tracks.
MITIGATION:
The primary method to avoid these situations is to configure system privileges and duties such that
a single person is unable to effect questionable change to the system and then are able to erase any
evidence of the change.

Technical configurations are most secure and sound enforceable policies compliment the technical
solutions. When an information system does not support separating duties, strong policies help
mitigate risk.
NIST CONSIDERATIONS FOR SEPARATION OF DUTIES:
NIST Special Publication 800-53 specifies the guidance for separation of duties in the control
catalog under the Access Control (AC) family and specifically as AC-5. While the NIST
requirements are not enforceable under the CJIS Security Policy, they were the genesis of the
Policy and do provide a sound security baseline that can be leveraged by the criminal and
noncriminal justice community. AC-5 is a relatively small control with no enhancements but it is
significant in protecting the integrity of an information system.
AC-5 Separation of Duties
Control: The organization:
a. Separates [Assignment: organization-defined duties of individuals];
b. Documents separation of duties of individuals; and
c. Defines information system access authorizations to support separation of duties.
Supplemental Guidance: Separation of duties addresses the potential for abuse of authorized
privileges and helps to reduce the risk of malevolent activity without collusion. Separation of
duties includes, for example: (i) dividing mission functions and information system support
functions among different individuals and/or roles; (ii) conducting information system support
functions with different individuals (e.g., system management, programming, configuration
management, quality assurance and testing, and network security); and (iii) ensuring security
personnel administering access control functions do not also administer audit functions. Related
controls: AC-3, AC-6, PE-3, PE-4, PS-2.
Control Enhancements: None.
References: None.
Priority and Baseline Allocation:

P1

LOW Not Selected

APPENDIX H SECURITY ADDENDUM
The following pages contain the legal authority, purpose, and genesis of the Criminal Justice
Information Services Security Addendum (H2-H4); the Security Addendum itself (H5-H6); and
the Security Addendum Certification page (H7).

FEDERAL BUREAU OF INVESTIGATION
CRIMINAL JUSTICE INFORMATION SERVICES
SECURITY ADDENDUM
Legal Authority for and Purpose and Genesis of the
Security Addendum
Traditionally, law enforcement and other criminal justice agencies have been
responsible for the confidentiality of their information. Accordingly, until mid-1999, the
Code of Federal Regulations Title 28, Part 20, subpart C, and the National Crime Information
Center (NCIC) policy paper approved December 6, 1982, required that the management and
exchange of criminal justice information be performed by a criminal justice agency or, in
certain circumstances, by a noncriminal justice agency under the management control of a
criminal justice agency.
In light of the increasing desire of governmental agencies to contract with private
entities to perform administration of criminal justice functions, the FBI sought and obtained
approval from the United States Department of Justice (DOJ) to permit such privatization of
traditional law enforcement functions under certain controlled circumstances. In the Federal
Register of May 10, 1999, the FBI published a Notice of Proposed Rulemaking,
announcing as follows:
1. Access to CHRI [Criminal History Record Information] and Related
Information, Subject to Appropriate Controls, by a Private Contractor Pursuant
to a Specific Agreement with an Authorized Governmental Agency To Perform
an Administration of Criminal Justice Function (Privatization). Section 534 of
title 28 of the United States Code authorizes the Attorney General to exchange
identification, criminal identification, crime, and other records for the official
use of authorized officials of the federal government, the states, cities, and
penal and other institutions. This statute also provides, however, that such
exchanges are subject to cancellation if dissemination is made outside the
receiving departments or related agencies. Agencies authorized access to
CHRI traditionally have been hesitant to disclose that information, even in
furtherance of authorized criminal justice functions, to anyone other than actual
agency employees lest such disclosure be viewed as unauthorized. In recent
years, however, governmental agencies seeking greater efficiency and
economy have become increasingly interested in obtaining support services for
the administration of criminal justice from the private sector. With the
concurrence of the FBI’s Criminal Justice Information Services (CJIS)
Advisory Policy Board, the DOJ has concluded that disclosures to private
persons and entities providing support services for criminal justice agencies
may, when subject to appropriate controls, properly be viewed as permissible
disclosures for purposes of compliance with 28 U.S.C. 534.
We are therefore proposing to revise 28 CFR 20.33(a)(7) to provide
express authority for such arrangements. The proposed authority is similar to
the authority that already exists in 28 CFR 20.21(b)(3) for state and local CHRI
systems. Provision of CHRI under this authority would only be permitted
pursuant to a specific agreement with an authorized governmental agency for
the purpose of providing services for the administration of criminal justice.
The agreement would be required to incorporate a security addendum approved
by the Director of the FBI (acting for the Attorney General). The security
addendum would specifically authorize access to CHRI, limit the use of the
information to the specific purposes for which it is being provided, ensure the
security and confidentiality of the information consistent with applicable laws
and regulations, provide for sanctions, and contain such other provisions as the
Director of the FBI (acting for the Attorney General) may require. The security
addendum, buttressed by ongoing audit programs of both the FBI and the
sponsoring governmental agency, will provide an appropriate balance between
the benefits of privatization, protection of individual privacy interests, and
preservation of the security of the FBI’s CHRI systems.
The FBI will develop a security addendum to be made available to
interested governmental agencies. We anticipate that the security addendum
will include physical and personnel security constraints historically required
by NCIC security practices and other programmatic requirements, together
with personal integrity and electronic security provisions comparable to those
in NCIC User Agreements between the FBI and criminal justice agencies, and
in existing Management Control Agreements between criminal justice
agencies and noncriminal justice governmental entities. The security
addendum will make clear that access to CHRI will be limited to those officers
and employees of the private contractor or its subcontractor who require the
information to properly perform services for the sponsoring governmental
agency, and that the service provider may not access, modify, use, or
disseminate such information for inconsistent or unauthorized purposes.
Consistent with such intent, Title 28 of the Code of Federal Regulations (C.F.R.) was
amended to read:
§ 20.33 Dissemination of criminal history record information.
a) Criminal history record information contained in the Interstate
Identification Index (III) System and the Fingerprint Identification Records
System (FIRS) may be made available:
1) To criminal justice agencies for criminal justice purposes, which
purposes include the screening of employees or applicants for
employment hired by criminal justice agencies.
2) To noncriminal justice governmental agencies performing criminal
justice dispatching functions or data processing/information services
for criminal justice agencies; and
3) To private contractors pursuant to a specific agreement with an agency
identified in paragraphs (a)(1) or (a)(6) of this section and for the
purpose of providing services for the administration of criminal justice
pursuant to that agreement. The agreement must incorporate a security
addendum approved by the Attorney General of the United States,
which shall specifically authorize access to criminal history record
information, limit the use of the information to the purposes for which
it is provided, ensure the security and confidentiality of the information
consistent with these regulations, provide for sanctions, and contain
such other provisions as the Attorney General may require. The power
and authority of the Attorney General hereunder shall be exercised by
the FBI Director (or the Director’s designee).
This Security Addendum, appended to and incorporated by reference in a
government-private sector contract entered into for such purpose, is intended to insure that
the benefits of privatization are not attained with any accompanying degradation in the
security of the national system of criminal records accessed by the contracting private party.
This Security Addendum addresses both concerns for personal integrity and electronic
security which have been addressed in previously executed user agreements and management
control agreements.
A government agency may privatize functions traditionally performed by criminal
justice agencies (or noncriminal justice agencies acting under a management control
agreement), subject to the terms of this Security Addendum. If privatized, access by a private
contractor's personnel to NCIC data and other CJIS information is restricted to only that
necessary to perform the privatized tasks consistent with the government agency's function
and the focus of the contract. If privatized the contractor may not access, modify, use or
disseminate such data in any manner not expressly authorized by the government agency in
consultation with the FBI.

FEDERAL BUREAU OF INVESTIGATION
CRIMINAL JUSTICE INFORMATION SERVICES
SECURITY ADDENDUM
The goal of this document is to augment the CJIS Security Policy to ensure adequate
security is provided for criminal justice systems while (1) under the control or management of
a private entity or (2) connectivity to FBI CJIS Systems has been provided to a private entity
(contractor). Adequate security is defined in Office of Management and Budget Circular A130 as “security commensurate with the risk and magnitude of harm resulting from the loss,
misuse, or unauthorized access to or modification of information.”
The intent of this Security Addendum is to require that the Contractor maintain a
security program consistent with federal and state laws, regulations, and standards (including
the CJIS Security Policy in effect when the contract is executed), as well as with policies and
standards established by the Criminal Justice Information Services (CJIS) Advisory Policy
Board (APB).
This Security Addendum identifies the duties and responsibilities with respect to the
installation and maintenance of adequate internal controls within the contractual relationship so
that the security and integrity of the FBI's information resources are not compromised. The
security program shall include consideration of personnel security, site security, system
security, and data security, and technical security.
The provisions of this Security Addendum apply to all personnel, systems, networks and
support facilities supporting and/or acting on behalf of the government agency.
1.00

Definitions

1.01 Contracting Government Agency (CGA) - the government agency, whether a Criminal
Justice Agency or a Noncriminal Justice Agency, which enters into an agreement with a private
contractor subject to this Security Addendum.
1.02 Contractor - a private business, organization or individual which has entered into an
agreement for the administration of criminal justice with a Criminal Justice Agency or a
Noncriminal Justice Agency.
2.00

Responsibilities of the Contracting Government Agency.

2.01 The CGA will ensure that each Contractor employee receives a copy of the Security
Addendum and the CJIS Security Policy and executes an acknowledgment of such receipt and
the contents of the Security Addendum. The signed acknowledgments shall remain in the
possession of the CGA and available for audit purposes. The acknowledgement may be signed
by hand or via digital signature (see glossary for definition of digital signature).
3.00

Responsibilities of the Contractor.

3.01 The Contractor will maintain a security program consistent with federal and state laws,
regulations, and standards (including the CJIS Security Policy in effect when the contract is
executed and all subsequent versions), as well as with policies and standards established by the
Criminal Justice Information Services (CJIS) Advisory Policy Board (APB).
4.00

Security Violations.

4.01 The CGA must report security violations to the CJIS Systems Officer (CSO) and the
Director, FBI, along with indications of actions taken by the CGA and Contractor.
4.02

Security violations can justify termination of the appended agreement.

4.03

Upon notification, the FBI reserves the right to:
a. Investigate or decline to investigate any report of unauthorized use;
b. Suspend or terminate access and services, including telecommunications links. The
FBI will provide the CSO with timely written notice of the suspension. Access and
services will be reinstated only after satisfactory assurances have been provided to
the FBI by the CGA and Contractor. Upon termination, the Contractor's records
containing CHRI must be deleted or returned to the CGA.

5.00

Audit

5.01 The FBI is authorized to perform a final audit of the Contractor's systems after
termination of the Security Addendum.
6.00

Scope and Authority

6.01 This Security Addendum does not confer, grant, or authorize any rights, privileges, or
obligations on any persons other than the Contractor, CGA, CJA (where applicable), CSA, and
FBI.
6.02 The following documents are incorporated by reference and made part of this
agreement: (1) the Security Addendum; (2) the NCIC 2000 Operating Manual; (3) the CJIS
Security Policy; and (4) Title 28, Code of Federal Regulations, Part 20. The parties are also
subject to applicable federal and state laws and regulations.
6.03 The terms set forth in this document do not constitute the sole understanding by and
between the parties hereto; rather they augment the provisions of the CJIS Security Policy to
provide a minimum basis for the security of the system and contained information and it is
understood that there may be terms and conditions of the appended Agreement which impose
more stringent requirements upon the Contractor.
6.04 This Security Addendum may only be modified by the FBI, and may not be modified
by the parties to the appended Agreement without the consent of the FBI.
6.05

All notices and correspondence shall be forwarded by First Class mail to:

Information Security Officer
Criminal Justice Information Services Division, FBI
1000 Custer Hollow Road
Clarksburg, West Virginia 26306

FEDERAL BUREAU OF INVESTIGATION
CRIMINAL JUSTICE INFORMATION SERVICES
SECURITY ADDENDUM
CERTIFICATION
I hereby certify that I am familiar with the contents of (1) the Security Addendum,
including its legal authority and purpose; (2) the NCIC Operating Manual; (3) the CJIS Security
Policy; and (4) Title 28, Code of Federal Regulations, Part 20, and agree to be bound by their
provisions.
I recognize that criminal history record information and related data, by its very nature,
is sensitive and has potential for great harm if misused. I acknowledge that access to criminal
history record information and related data is therefore limited to the purpose(s) for which a
government agency has entered into the contract incorporating this Security Addendum. I
understand that misuse of the system by, among other things: accessing it without
authorization; accessing it by exceeding authorization; accessing it for an improper purpose;
using, disseminating or re-disseminating information received as a result of this contract for a
purpose other than that envisioned by the contract, may subject me to administrative and
criminal penalties. I understand that accessing the system for an appropriate purpose and then
using, disseminating or re-disseminating the information received for another purpose other
than execution of the contract also constitutes misuse. I further understand that the occurrence
of misuse does not depend upon whether or not I receive additional compensation for such
authorized activity. Such exposure for misuse includes, but is not limited to, suspension or loss
of employment and prosecution for state and federal crimes.

_______________________________________
Printed Name/Signature of Contractor Employee

______________________________________
Printed Name/Signature of Contractor Representative

_______________
Date

_______________
Date

______________________________________
Organization and Title of Contractor Representative

APPENDIX I

REFERENCES

White House Memo entitled “Designation and Sharing of Controlled Unclassified Information
(CUI)”, May 9, 2008
[CJIS RA] CJIS Security Policy Risk Assessment Report; August 2008; For Official Use Only;
Prepared by: Noblis; Prepared for: U.S. Department of Justice, Federal Bureau
of Investigation, Criminal Justice Information Services Division, 1000 Custer
Hollow Road, Clarksburg, WV 26306
[CNSS Instruction No. 4009] National Information Assurance (IA) Glossary; Committee on
National Security Systems (CNSS) Instruction No. 4009; 26 April 2010
[FBI SA 8/2006] Federal Bureau of Investigation, Criminal Justice Information Services,
Security Addendum; 8/2006; Assistant Director, Criminal Justice Information
Services, FBI, 1000 Custer Hollow Road, Clarksburg, West Virginia 26306
[FISMA] Federal Information Security Management Act of 2002; House of Representatives
Bill 2458, Title III–Information Security
[FIPS 199] Standards for Security Categorization of Federal Information and Information
Systems; Federal Information Processing Standards Publication, FIPS PUB
199; February 2004
[FIPS 200] Minimum Security Requirements for Federal Information and Information
Systems; Federal Information Processing Standards Publication, FIPS PUB
200; March 2006
[FIPS 201] Personal Identity Verification for Federal Employees and Contractors; Federal
Information Processing Standards Publication, FIPS PUB 201-1
[NIST SP 800–14] Generally Accepted Principles and Practices for Securing Information
Technology Systems; NIST Special Publication 800–14
[NIST SP 800–25] Federal Agency Use of Public Key Technology for Digital Signatures and
Authentication; NIST Special Publication 800–25
[NIST SP 800–30] Risk Management Guide for Information Technology Systems; NIST
Special Publication 800–36
[NIST SP 800–32] Introduction to Public Key Technology and the Federal PKI
Infrastructure; NIST Special Publication 800–32
[NIST SP 800–34] Contingency Planning Guide for Information Technology Systems; NIST
Special Publication 800–34
[NIST SP 800–35] Guide to Information Technology Security Services; NIST Special
Publication 800–35
[NIST SP 800–36] Guide to Selecting Information Technology Security Products; NIST
Special Publication 800–36
[NIST SP 800–39] Managing Risk from Information Systems, An Organizational Perspective;
NIST Special Publication 800–39
[NIST SP 800–40] Procedures for Handling Security Patches; NIST Special Publication 800–
40
[NIST SP 800–44] Guidelines on Securing Public Web Servers; NIST Special Publication
800–44
[NIST SP 800–45] Guidelines on Electronic Mail Security; NIST Special Publication 800–45,
Version 2
[NIST SP 800–46] Security for Telecommuting and Broadband Communications; NIST
Special Publication 800–46
[NIST SP 800–48] Wireless Network Security: 802.11, Bluetooth, and Handheld Devices;
NIST Special Publication 800–48
[NIST SP 800–52] Guidelines on the Selection and Use of Transport Layer Security; NIST
Special Publication 800–52
[NIST SP 800–53] Recommended Security Controls for Federal Information Systems; NIST
Special Publication 800–53, Revision 2
[NIST SP 800–53A] Guide for Assessing the Security Controls in Federal Information
Systems, Building Effective Security Assessment Plans; NIST Special
Publication 800–53A
[NIST SP 800–58] Security Considerations for Voice over IP Systems; NIST Special
Publication 800–58
[NIST SP 800–60] Guide for Mapping Types of Information and Information Systems to
Security Categories; NIST Special Publication 800–60, Revision 1, DRAFT
[NIST SP 800–63–1] Electronic Authentication Guideline; NIST Special Publication 800–63–
1; DRAFT
[NIST SP 800–64] NIST Special Publication 800–64
[NIST SP 800–66] An Introductory Resource Guide for Implementing the Health Insurance
Portability and Accountability Act (HIPAA); NIST Special Publication 800–66
[NIST SP 800–68] Guidance for Securing Microsoft Windows XP Systems for IT
Professionals: A NIST Security Configuration Checklist; NIST Special
Publication 800–68
[NIST SP 800–70] Security Configuration Checklists Program for IT Products; NIST Special
Publication 800–70
[NIST SP 800–72] Guidelines on PDA Forensics; NIST Special Publication 800–72
[NIST SP 800–73] Integrated Circuit Card for Personal Identification Verification; NIST
Special Publication 800–73; Revision 1
[NIST SP 800–76] Biometric Data Specification for Personal Identity Verification; NIST
Special Publication 800–76
[NIST SP 800–77] Guide to IPSec VPNs; NIST Special Publication 800–77
[NIST SP 800–78] Cryptographic Algorithms and Key Sizes for Personal Identity
Verification; NIST Special Publication 800–78
[NIST SP 800–81] Secure Domain Name System (DNS) Deployment Guide; NIST Special
Publication 800–81
[NIST SP 800–84] Guide to Test, Training, and Exercise Programs for IT Plans and
Capabilities; NIST Special Publication 800–84
[NIST SP 800–86] Guide to Integrating Forensic Techniques into Incident Response; NIST
Special Publication 800–86
[NIST SP 800–87] Codes for the Identification of Federal and Federally Assisted Agencies;
NIST Special Publication 800–87
[NIST SP 800–96] PIV Card / Reader Interoperability Guidelines; NIST Special Publication
800–96
[NIST SP 800–97] Guide to IEEE 802.11i: Robust Security Networks; NIST Special
Publication 800–97
[NIST SP 800–121] Guide to Bluetooth Security, NIST Special Publication 800-121
[NIST SP 800–124] Guidelines on Cell Phone and PDA Security, NIST Special Publication
800-124
[NIST SP 800-125] Guide to Security for Full Virtualization Technologies; NIST Special
Publication 800-125
[NIST SP 800–144] Guidelines on Security and Privacy in Public Cloud Computing; NIST
Special Publication 800-144
[NIST SP 800–145] The NIST Definition of Cloud Computing; NIST Special Publication 800145
[NIST SP 800–146] Cloud Computing Synopsis and Recommendations; NIST Special
Publication 800-146
[OMB A–130] Management of Federal Information Resources; Circular No. A–130;
Revised; February 8, 1996
[OMB M–04–04] E-Authentication Guidance for Federal Agencies; OMB Memo 04–04;
December 16, 2003
[OMB M–06–15] Safeguarding Personally Identifiable Information; OMB Memo 06–15;
May 22, 2006
[OMB M–06–16] Protection of Sensitive Agency Information; OMB Memo 06–16; June 23,
2006
[OMB M–06–19] Reporting Incidents Involving Personally Identifiable Information and
Incorporating the Cost for Security in Agency Information Technology
Investments; OMB Memo 06–19; July 12, 2006
[OMB M–07–16] Safeguarding Against and Responding to the Breach of Personally
Identifiable Information; OMB Meme 07–16; May 22, 2007
[Surviving Security] Surviving Security: How to Integrate People, Process, and Technology;
Second Edition; 2004
[USC Title 5, Section 552] Public information; agency rules, opinions, orders, records, and
proceedings; United States Code, Title 5 - Government Agency and
Employees, Part I - The Agencies Generally, Chapter 5 - Administrative
Procedure, Subchapter II - Administrative Procedure, Section 552. Public
information; agency rules, opinions, orders, records, and proceedings
[USC Title 44, Section 3506] Federal Information Policy; 01/02/2006; United States Code,
Title 44 - Public Printing and Documents; Chapter 35 - Coordination of
Federal Information Policy; Subchapter I - Federal Information Policy, Section
3506

APPENDIX J NONCRIMINAL JUSTICE AGENCY
SUPPLEMENTAL GUIDANCE
This appendix is not intended to be used in lieu of the CJIS Security Policy (CSP) but
rather should be used as supplemental guidance specifically for those Noncriminal Justice
Agencies (NCJA) with access to Criminal Justice Information (CJI) as authorized by legislative
enactment or federal executive order to request civil fingerprint-based background checks for
licensing, employment, or other noncriminal justice purposes, via their State Identification
Bureau (SIB) and/or Channeling agency. Examples of the target audience for the Appendix J
supplemental guidance include school boards, banks, medical boards, gaming commissions,
alcohol and tobacco control boards, social services agencies, pharmacy boards, etc.
The CSP is the minimum standard policy used by both criminal and noncriminal justice
agencies requiring access to CJI maintained by the FBI CJIS Division. The essential premise
of the CSP is to provide appropriate controls to protect the full lifecycle of CJI, whether at rest
or in transit. The CSP provides guidance for the creation, viewing, modification, transmission,
dissemination, storage, and destruction of CJI. This Policy applies to every individual—
contractor, private entity, noncriminal justice agency representative, or member of a criminal
justice entity—with access to, or who operate in support of, criminal justice services and
information.
For those NCJAs new to the CSP and Advisory Policy Board (APB) auditing process
(all NCJAs will be periodically audited by the CJIS Systems Agency (CSA)/SIB and may be
included in a sampling of triennial audits conducted by the FBI) it is strongly recommended
that each system processing CJI should be individually reviewed to determine which CSP
requirements may apply. In the interim however this supplemental guidance provides a
minimum starting point that every NCJA processing CJI can immediately put into place. Once
the broader array of security controls are gleaned for a specific system, agencies can then
leverage the (already implemented) controls described in this appendix as a launching pad
towards full policy compliance.
The following information is organized to provide the section and section title within
the CSP, along with a brief summary and background on the guidance itself. For the specific
“shall” statement please go to the referenced section within the main body of the CSP.
General CJI Guidance
The following information provides NCJAs guidance to maintain security compliance when
setting up any system capable of sending and/or receiving CJI:
a. 3.2.9 – Local Agency Security Officer (LASO)
It is the responsibility of the CJIS Systems Officer (CSO) to ensure each agency having
access to CJI has someone designated as the Local Agency Security Officer (LASO) per
CSP Section 3.2.2(2e).
The LASO serves as the primary point of contact (POC) between the local NCJA and
their respective CSA CSO or Information Security Officer (ISO) who interfaces with
the FBI CJIS Division. The LASO actively represents their agency in all matters
pertaining to information security, disseminates information security alerts and other
material to their constituents, maintains information security documentation (including
system configuration data), assists with Information Security audits of hardware and
procedures, and keeps the CSA (i.e., CSO or ISO) informed as to any information
security needs and problems.
b. 5.1.1.6 – Agency User Agreements
When an NCJA (private or public) is permitted to request civil fingerprint-based
background checks, with the full consent of the individual to whom a background check
is taking place, for noncriminal justice functions as authorized pursuant to federal law
or state statute approved by the U.S. Attorney General, the information received from
the background check, such as criminal history record information (CHRI) or personally
identifiable information (PII), must be protected as CJI. In order to receive access to CJI
the NCJA must enter into a signed written agreement, i.e., an agency user agreement,
with the appropriate signatory authority of the CSA, SIB, or authorized agency
providing the CJI access. An example of a NCJA (private) is a local bank. An example
of a NCJA (public) is a county school board.
Note 1: The CSA, SIB, or authorized agency providing the CJI access term should be
part of the agency user agreement.
Note 2: Any NCJA that directly accesses FBI CJIS must allow the FBI to periodically
test the ability to penetrate the FBI’s network through the external network connection
or system per authorization of Department of Justice (DOJ) Order 2640.2F.
c. 5.1.3 – Secondary Dissemination
Secondary dissemination is the promulgation of CJI from a releasing agency to an
authorized recipient agency that has not been previously identified in a formal
information exchange agreement.
If CHRI is released to another authorized agency, that is not part of the releasing
agency’s primary information exchange agreement(s), the releasing agency must log
such dissemination.
d. 5.2.1.1 – All Personnel (Security Awareness Training)
Basic security awareness training is required for all personnel who have access to CJI within
six months of initial assignment, and biennially thereafter. CSP Section 5.2.1.1 describes
the topics that must be addressed within baseline security awareness training for all
authorized personnel with access to CJI.
Note: The CSO/SIB may accept the documentation of the completion of security awareness
training from another agency. Accepting such documentation from another agency means
that the accepting agency assumes the risk that the training may not meet a particular
requirement or process required by federal, state, or local laws.

e. 5.3 – Incident Response
CSP Section 5.3 assists agencies with response and reporting procedures for accidental
and malicious computer and network attacks. The requirements within Section 5.3 will
help NCJAs with:
(i)

Establishing an operational incident handling capability for agency information
systems that includes adequate preparation, detection, analysis, containment,
recovery, and user response activities; and,

(ii)

Tracking, documenting, and reporting incidents to appropriate agency officials
and/or authorities.

CSP Section 5.3.1 describes the requirements for reporting security events and describes
the responsibilities of the FBI CJIS Division and the CSA ISO.
CSP Section 5.3.2 describes the requirements for managing security incidents, to
include: incident handling and the collection of evidence.
CSP Section 5.3.3 describes the requirement for an agency to ensure general incident
response roles responsibilities are included as part of required security awareness
training.
CSP Section 5.3.4 describes the requirement for an agency to track and document
information system security incidents on an ongoing basis.
Note 1: CSA ISOs serve as the POC on security-related issues for their respective
agencies and must ensure LASOs institute the CSA incident response reporting
procedures at the local level. The CSA ISO shall maintain completed security incident
reporting forms until the subsequent FBI triennial audit or until legal action (if
warranted) is complete; whichever time-frame is greater.
Note 2: CSP Appendix F contains a sample incident notification letter for use when
communicating the details of an incident to the FBI CJIS ISO.
f. 5.4 – Auditing and Accountability
CSP Section 5.4 assists agencies in assessing the inventory of components that compose
their information systems to determine which security controls are applicable to the
various components and implement required audit and accountability controls.
CSP Section 5.4.1 describes the required parameters for agencies to generate audit
records and content for defined events and periodically review and update the list of
agency-defined auditable events.
CSP Section 5.4.2 describes the requirement for agencies to provide alerts to
appropriate agency officials in the event of an audit processing failure, such as
software/hardware errors, failures in the audit capturing mechanisms, and audit storage
capacity being reached or exceeded.
CSP Section 5.4.3 describes the requirements for audit review/analysis frequency and
to designate an individual or position to review/analyze information system audit
records for indications of inappropriate or unusual activity, investigate suspicious
activity or suspected violations, to report findings to appropriate officials, and to take
necessary actions.
CSP Section 5.4.4 describes the requirement to establish information system time stamp
parameters for use in audit record generation.
CSP Section 5.4.5 describes the requirement to protect audit information and audit tools
from modification, deletion and unauthorized access.
CSP Section 5.4.6 describes the requirement for an agency to retain audit records for at
least one (1) year.

Note: The agency will continue to retain audit records for longer than one (1) year until
it is determined they are no longer needed for administrative, legal, audit, or other
operational purposes - for example, retention and availability of audit records relative
to Freedom of Information Act (FOIA) requests, subpoena, and law enforcement
actions.
CSP Section 5.4.7 describes the requirements for logging National Crime Information
Center (NCIC) and Interstate Identification Index (III) transactions. A log must be
maintained for a minimum of one (1) year on all NCIC and III transactions. The III
portion of the log will clearly identify both the operator and the authorized receiving
agency. III logs must also clearly identify the requester and the secondary recipient.
The identification on the log will take the form of a unique identifier that shall remain
unique to the individual requester and to the secondary recipient throughout the
minimum one (1) year retention period.
g. 5.8 – Media Protection
CJIS Security Policy Section 5.8 assists agencies to document and implement media
protection policy and procedures required to ensure that access to electronic and
physical media in all forms is restricted to authorized individuals for securely handling,
transporting and storing media.
“Electronic media” is electronic storage media, such as memory devices in laptops and
computers (hard drives) and any removable, transportable digital memory media, such
as magnetic tape or disk, optical disk, flash drives, external hard drives, or digital
memory card. “Physical media” refers to CJI in physical form, e.g. printed documents,
printed imagery, etc.
CSP Section 5.8.1 describes the requirement for agencies to securely store electronic
and physical media within physically secure locations or controlled areas and restrict
access to electronic and physical media to authorized individuals. If physical and
personnel restrictions are not feasible then the data must be encrypted per CSP Section
5.10.1.2.
CSP Section 5.8.2 describes the requirements for agencies to protect and control both
electronic and physical media during transport outside of controlled areas and restrict
the activities associated with transport of such media to authorized personnel. The
agency is responsible for implementing controls to protect electronic media containing
CJI while in transport (physically moved from one location to another) to help prevent
compromise of the data. Encryption, as defined in CSP Section 5.10.1.2, is the optimal
control; however, if encryption of the data isn’t possible then each agency must institute
other controls to ensure the security of the data.
CSP Section 5.8.3 describes the requirements for agencies to maintain written
documentation of the steps taken to sanitize or destroy electronic media. Agencies must
sanitize (electronically overwrite the data at least three times) or degauss electronic
media prior to disposal or release for reuse by unauthorized individuals. This
sanitization or destruction needs to be witnessed or carried out only by authorized
personnel. Inoperable electronic media must be destroyed (cut up, shredded, etc.).
CSP Section 5.8.4 describes the requirements for physical media to be securely disposed
of when no longer required, using established formal procedures. Physical media must
be destroyed by shredding or incineration. This disposal or destruction needs to be
witnessed or carried out only by authorized personnel.
h. 5.9 Physical Protection
CSP Section 5.9 explains the physical protection policy and procedures that are required
to ensure CJI and information system hardware, software, and media are physically
protected through access control measures.
CSP Section 5.9.1 details the requirements for establishing a Physically Secure Location
- a facility, a criminal justice conveyance, an area, a room, or a group of rooms within a
facility with both the physical and personnel security controls sufficient to protect CJI
and associated information systems. Sections 5.9.1.1 – 5.9.1.8 describe the physical
control requirements that must be implemented in order to establish a physically secure
location.
CSP Section 5.9.2 details the requirements for establishing a Controlled Area. The
controlled area is an area, a room, or a storage container established for the purpose of
day-to-day CJI access, storage, or processing in the event an agency is unable to meet
all of the controls required for establishing a physically secure location. Access to the
controlled area needs to be restricted to only authorized personnel whenever CJI is
processed. The CJI material needs to be locked away when unattended to prevent
unauthorized and unintentional access. Additionally, the encryption standards of CSP
Section 5.10.1.2 apply to the electronic storage (i.e. data “at rest”) of CJI.
i. 5.11 – Formal Audits
CSP Section 5.11 explains the formal audit process to help agencies understand the audit
procedures.
CSP Section 5.11.1 details the requirements for compliance and security audits by the
FBI CJIS Division. The FBI CJIS Division is authorized to conduct audits, once every
three (3) years as a minimum, to assess agency compliance with applicable statutes,
regulations and policies.
The CJIS Audit Unit (CAU) will conduct triennial audits of each CSA in order to verify
compliance with applicable statutes, regulations and policies. This audit includes a
sample of Criminal Justice Agency (CJA) and NCJAs, in coordination with the SIB.
Note 1: Audits may be conducted on a more frequent basis if the audit reveals that an
agency has not complied with applicable statutes, regulations and policies.
Note 2: The FBI CJIS Division has the authority to conduct unannounced security
inspections and scheduled audits of Contractor facilities.
CSP Section 5.11.2 describes the requirements for the CSA to triennially audit all CJAs
and NCJAs with direct access to the state system, establish a process to periodically
audit all NCJAs with access to CJI, establish the authority to conduct unannounced
security inspections and scheduled audits of Contractor facilities.
CSP Section 5.11.3 describes the requirement that all agencies with access to CJI must
permit an inspection team to conduct an appropriate inquiry and audit of any alleged
security violations. The inspection team, appointed by the APB, will include at least one
representative of the CJIS Division. All results of the inquiry and audit will be reported
to the APB with appropriate recommendations.
Agencies located within states having passed legislation authorizing or requiring civil
fingerprint-based background checks for personnel with access to criminal history record
information for the purposes of licensing or employment need to follow the guidance in Section
5.12 (referenced below).
j. 5.12 – Personnel Security
CSP Section 5.12 provides agencies the security terms and requirements as they apply
to all personnel who have access to unencrypted CJI, including individuals with only
physical or logical access to devices that store, process or transmit unencrypted CJI.
CSP Section 5.12.1 details the minimum screening requirements for all individuals
requiring access to CJI - listed in CSP Section 5.12.1.1. In addition to the requirements
listed in CSP Section 5.12.1.1 contractors and vendors must undergo additional
screening requirements as listed in CSP Section 5.12.1.2.2.
CSP Section 5.12.2 describes the requirement for an agency to immediately terminate
CJI access for an individual upon termination of employment.
CSP Section 5.12.3 describes the requirement for an agency to review CJI access
authorizations and initiate appropriate actions (such as closing and establishing accounts
and changing system access authorizations) whenever personnel are reassigned or
transferred to other positions within the agency.
CSP Section 5.12.4 describes the requirement for an agency to employ a formal
sanctions process for personnel failing to comply with established information security
policies and procedures.
Agencies located within states that have not passed legislation authorizing or requiring civil
fingerprint-based background checks are exempted from this requirement until such time as
appropriate legislation has been written into law.
The following scenarios are intended to help the reader identify areas within the CSP that
NCJAs may often come across. Each scenario should be reviewed for applicability in
conjunction with the above General CJI Guidance section. The specific requirements
found with the CSP are not shown; however specific sections are referenced along with a
requirements summary.
Hard Copy CJI Storage and Accessibility
When an NCJA receives CJI via a paper copy from a CJA and stores the paper within a locked
file cabinet, the NCJA should, in addition to the General CJI Guidance, focus on compliance
with policy section:
a. 4.2.4 – Storage
When storing CJI, appropriate administrative, technical, and physical safeguards must
be implemented to ensure the security and confidentiality of the information.
Electronic CJI Storage and Accessibility – Controlled Area
When an NCJA creates an electronic copy of CJI (e.g. scanning a document or creation of a
spreadsheet) and subsequently stores this static CJI on either a local hard drive or shared
network drive in a controlled area for indirect access by Authorized Recipients, the NCJA
should, in addition to the General CJI Guidance, focus on compliance with policy section:
a. 5.5.2.4 (3) – Access Control – Encryption
CSP Section 5.5.2.4 item 3 – Encryption describes the requirement for utilizing
encryption as the primary access control mechanism which is necessary in this
situation. Encrypted information can only be read by personnel possessing the
appropriate cryptographic key (e.g., passphrase) to decrypt. Refer to Section 5.10.1.2
for specific encryption requirements.
Electronic CJI Storage and Accessibility – Physically Secure Location
When an NCJA receives or creates an electronic copy of CJI and subsequently stores this CJI
within a Records Management System (RMS), located within a physically secure location that
may be queried by Authorized Recipients, the NCJA should, in addition to the General CJI
Guidance, focus on compliance with policy sections:
a. 5.5 – Access Control
CSP Section 5.5 describes the requirements and parameters for utilizing access control
mechanisms for restricting CJI access (such as the reading, writing, processing and
transmission of CJIS information) and the modification of information systems,
applications, services and communication configurations allowing access to CJI to only
authorized personnel.
b. 5.6 – Identification and Authentication
CSP Section 5.6 describes the requirements and parameters agencies must implement to
validate and authenticate the identity of information system users and processes acting
on behalf of users the identities prior to granting access to CJI or agency information
systems/services that process CJI.
c. 5.7 – Configuration Management
CSP Section 5.7 describes the requirements for implementing access restrictions that
will only permit authorized and qualified individuals access to information system
components for purposes of initiating changes, including upgrades, and modifications.
CSP Section 5.7.1 describes the requirements for implementing the concept of least
privilege (5.7.1.1) and for developing and maintaining network diagrams (5.7.1.2) that
detail how the RMS is interconnected and protected within the network. See Appendix
C for sample network diagrams.
CSP Section 5.7.2 details the requirement for agencies to protect the system
documentation from unauthorized access consistent with the provisions described in
Section 5.5 Access Control.
d. 5.10 – System and Communications Protection and Information Integrity
CSP Section 5.10 details the requirements for network infrastructures within physically
secure locations through establishment of system and communication boundary and
transmission protection safeguards that assist in securing an agency’s environment, even
when virtualized. In addition, this section describes the requirements for providing the
capability to ensure system integrity through the detection and protection against
unauthorized changes to software and information for applications, services, and
information systems.

Use Case Scenarios
1. Indirect Access to Criminal Justice Information (CJI) Stored on a Network Server
A county board of education is converting all employee records, including background
check information containing CJI, to an electronic format. The records will be scanned
from hard copy to electronic files and placed on network server that has indirect access to
CJI and is located in a secure data center within the board of education offices. The data
center meets all the requirements to be labeled a physically secure location as defined in
Section 5.9.1 of the CSP.
Keeping in mind the scenario as described, an authorized user needs access to an
employee’s electronic record. This user is not located in the secure data center and will
have to use remote access to access the file. The user is therefore required to provide
identification and authentication credentials to prove they are an authorized user. To
access the record, the user is prompted to enter their unique username and password.
Because the record resides on a system with indirect access to CJI (does not allow the user
to query a state or national criminal record repository), AA is not required to access the
record.
NOTE: If the Authorized User has direct access to CJI (the ability to query a state or
national criminal record repository) in the above scenario, AA would be required.
2. Encryption for Data at Rest (Exemption for FIPS 140-2 Certified Encryption)
A county board of education is converting all employee records, including background
check information containing CJI, to an electronic format. The records will be scanned
from hard copy to electronic files and placed on network server that is not located in a
secure data center. Because the data center does not meet the requirements of a physically
secure location, as defined in Section 5.9.1 of the CSP, the files, at rest (in storage) on the
server, are required to be encrypted.
To prevent unauthorized access, the IT staff has decided to encrypt the entire folder that
contains the files. They will use a product that provides an advanced encryption standard
(AES) encryption algorithm at 256 bit strength to comply with the CSP and employ a CSP
compliant passphrase to lock the folder’s encryption. When an authorized user needs to
access an employee’s record, they access the folder on the server and are prompted to
enter the designated passphrase to decrypt (unlock) the folder. The user can then access all
files within the folder.
NOTE: Whenever authorized personnel no longer require access to the encrypted folder,
the passphrase must be changed to prevent future access by that user.

APPENDIX K CRIMINAL JUSTICE AGENCY
SUPPLEMENTAL GUIDANCE
This appendix is not intended to be used in lieu of the CJIS Security Policy (CSP) but
rather should be used as supplemental guidance specifically for those Criminal Justice Agencies
(CJA) that have historically not been subject to audit under the CJIS Security Policy guidelines.
The target audience typically gains access to CJI via fax, hardcopy distribution or voice calls;
does not have the capability to query state or national databases for criminal justice information;
and may have been assigned an originating agency identifier (ORI) but is dependent on other
agencies to run queries on their behalf. This guidance is not intended for criminal justice
agencies covered under an active information exchange agreement with another agency for
direct or indirect connectivity to the state CJIS Systems Agency (CSA) – in other words those
agencies traditionally identified as “terminal agencies”.
The CSP is the minimum standard policy used by both criminal and noncriminal justice
agencies requiring access to criminal justice information (CJI) maintained by the FBI CJIS
Division. The essential premise of the CSP is to provide appropriate controls to protect the full
lifecycle of CJI, whether at rest or in transit. The CSP provides guidance for the creation,
viewing, modification, transmission, dissemination, storage, and destruction of CJI. This Policy
applies to every individual—contractor, private entity, noncriminal justice agency
representative, or member of a criminal justice entity—with access to, or who operate in support
of, criminal justice services and information.
For those CJAs new to the CSP it is strongly recommended that each system processing
CJI should be individually reviewed to determine which CSP requirements may apply. In the
interim however this supplemental guidance provides a minimum starting point that every CJA
processing CJI can immediately put into place. Once the broader array of security controls are
gleaned for a specific system, agencies can then leverage the (already implemented) controls
described in this appendix as a launching pad towards full policy compliance.
The following information is organized to provide the section and section title within
the CSP, along with a brief summary and background on the guidance itself. For the specific
“shall” statement please go to the referenced section within the main body of the CSP.
General CJI Guidance
The following information provides CJAs guidance to maintain security compliance when
setting up any system capable of sending and/or receiving CJI:
a. 3.2.9 – Local Agency Security Officer (LASO)
It is the responsibility of the CJIS Systems Officer (CSO) to ensure each agency having
access to CJI has someone designated as the Local Agency Security Officer (LASO) per
CSP Section 3.2.2(2e).
The LASO serves as the primary point of contact (POC) between the local CJA and their
respective CSA CSO or Information Security Officer (ISO) who interfaces with the FBI
CJIS Division. The LASO actively represents their agency in all matters pertaining to
information security, disseminates information security alerts and other material to their
constituents, maintains information security documentation (including system
configuration data), assists with Information Security audits of hardware and
procedures, and keeps the CSA (i.e., CSO or ISO) informed as to any information
security needs and problems.
b. 5.1.1.3 – Criminal Justice Agency User Agreements
Any CJA receiving access to CJI must enter into a signed agreement with the CSA
providing the access. The agreement specifies the services and systems the agency will
access. It must also specify all pertinent governance policies to which the agency must
adhere.
c. 5.1.3 – Secondary Dissemination
Secondary dissemination is the promulgation of CJI from a releasing agency to an
authorized recipient agency that has not been previously identified in a formal
information exchange agreement.
If CHRI is released to another authorized agency, that is not part of the releasing
agency’s primary information exchange agreement(s), the releasing agency must log
such dissemination.
d. 5.2 – Security Awareness Training
Basic security awareness training is required for all personnel who have access to CJI within
six months of initial assignment, and biennially thereafter. CSP Section 5.2.1.1 describes
the topics that must be addressed within baseline security awareness training for all
authorized personnel with access to CJI.

CSP Section 5.2.1.2 describes the topics required to be discussed for personnel that have
both physical and logical access to CJI. These topics are covered in addition to the ones
addressed in basic security awareness training.
CSP Section 5.2.1.3 describes topics to be covered for those personnel assigned
information technology roles. Topics covered in this section are in addition to the topics
addressed in Sections 5.2.1.1 and 5.2.1.2.
Note: The CSO may accept the documentation of the completion of security awareness
training from another agency. Accepting such documentation from another agency means
that the accepting agency assumes the risk that the training may not meet a particular
requirement or process required by federal, state, or local laws.

e. 5.3 – Incident Response
CSP Section 5.3 assists agencies with response and reporting procedures for accidental
and malicious computer and network attacks. The requirements within Section 5.3 will
help CJAs with:
(iii)

Establishing an operational incident handling capability for agency information
systems that includes adequate preparation, detection, analysis, containment,
recovery, and user response activities; and,

(iv)

Tracking, documenting, and reporting incidents to appropriate agency officials
and/or authorities.

CSP Section 5.3.1 describes the requirements for reporting security events and describes
the responsibilities of the FBI CJIS Division and the CSA ISO.
CSP Section 5.3.2 describes the requirements for managing security incidents, to
include: incident handling and the collection of evidence.
CSP Section 5.3.3 describes the requirement for an agency to ensure general incident
response roles responsibilities are included as part of required security awareness
training.
CSP Section 5.3.4 describes the requirement for an agency to track and document
information system security incidents on an ongoing basis.
Note 1: CSA ISOs serve as the POC on security-related issues for their respective
agencies and must ensure LASOs institute the CSA incident response reporting
procedures at the local level. The CSA ISO shall maintain completed security incident
reporting forms until the subsequent FBI triennial audit or until legal action (if
warranted) is complete; whichever time-frame is greater.
Note 2: CSP Appendix F contains a sample incident notification letter for use when
communicating the details of an incident to the FBI CJIS ISO.
f. 5.4 – Auditing and Accountability
CSP Section 5.4 assists agencies in assessing the inventory of components that compose
their information systems to determine which security controls are applicable to the
various components and implement required audit and accountability controls.
CSP Section 5.4.1 describes the required parameters for agencies to generate audit
records and content for defined events and periodically review and update the list of
agency-defined auditable events.
CSP Section 5.4.2 describes the requirement for agencies to provide alerts to appropriate
agency officials in the event of an audit processing failure, such as software/hardware
errors, failures in the audit capturing mechanisms, and audit storage capacity being
reached or exceeded.
CSP Section 5.4.3 describes the requirements for audit review/analysis frequency and
to designate an individual or position to review/analyze information system audit
records for indications of inappropriate or unusual activity, investigate suspicious
activity or suspected violations, to report findings to appropriate officials, and to take
necessary actions.
CSP Section 5.4.4 describes the requirement to establish information system time stamp
parameters for use in audit record generation.
CSP Section 5.4.5 describes the requirement to protect audit information and audit tools
from modification, deletion and unauthorized access.
CSP Section 5.4.6 describes the requirement for an agency to retain audit records for at
least one (1) year.
Note: The agency will continue to retain audit records for longer than one (1) year until
it is determined they are no longer needed for administrative, legal, audit, or other
operational purposes - for example, retention and availability of audit records relative
to Freedom of Information Act (FOIA) requests, subpoena, and law enforcement
actions.
CSP Section 5.4.7 describes the requirements for logging National Crime Information
Center (NCIC) and Interstate Identification Index (III) transactions. A log must be
maintained for a minimum of one (1) year on all NCIC and III transactions. The III
portion of the log will clearly identify both the operator and the authorized receiving
agency. III logs must also clearly identify the requester and the secondary recipient.
The identification on the log will take the form of a unique identifier that shall remain
unique to the individual requester and to the secondary recipient throughout the
minimum one (1) year retention period.
g. 5.8 – Media Protection
CJIS Security Policy Section 5.8 assists agencies to document and implement media
protection policy and procedures required to ensure that access to digital and physical
media in all forms is restricted to authorized individuals for securely handling,
transporting and storing media.
“Digital media” is electronic storage media, such as memory devices in laptops and
computers (hard drives) and any removable, transportable digital memory media, such
as magnetic tape or disk, optical disk, flash drives, external hard drives, or digital
memory card. “Physical media” refers to CJI in physical form, e.g. printed documents,
printed imagery, etc.
CSP Section 5.8.1 describes the requirement for agencies to securely store digital and
physical media within physically secure locations or controlled areas and restrict access
to electronic and physical media to authorized individuals. If physical and personnel
restrictions are not feasible then the data must be encrypted per CSP Section 5.10.1.2.
CSP Section 5.8.2 describes the requirements for agencies to protect and control both
digital and physical media during transport outside of controlled areas and restrict the
activities associated with transport of such media to authorized personnel. The agency
is responsible for implementing controls to protect electronic media containing CJI
while in transport (physically moved from one location to another) to help prevent
compromise of the data. Encryption, as defined in CSP Section 5.10.1.2, is the optimal
control; however, if encryption of the data isn’t possible then each agency must institute
other controls to ensure the security of the data.
CSP Section 5.8.3 describes the requirements for agencies to maintain written
documentation of the steps taken to sanitize or destroy digital media. Agencies must
sanitize (electronically overwrite the data at least three times) or degauss electronic
media prior to disposal or release for reuse by unauthorized individuals. This
sanitization or destruction needs to be witnessed or carried out only by authorized
personnel. Inoperable electronic media must be destroyed (cut up, shredded, etc.).
CSP Section 5.8.4 describes the requirements for physical media to be securely disposed
of when no longer required, using established formal procedures. Physical media must
be destroyed by shredding or incineration. This disposal or destruction needs to be
witnessed or carried out only by authorized personnel.
h. 5.9 Physical Protection
CSP Section 5.9 explains the physical protection policy and procedures that are required
to ensure CJI and information system hardware, software, and media are physically
protected through access control measures.
CSP Section 5.9.1 details the requirements for establishing a Physically Secure Location
- a facility, a police vehicle, an area, a room, or a group of rooms within a facility with
both the physical and personnel security controls sufficient to protect CJI and associated
information systems. Sections 5.9.1.1 – 5.9.1.8 describe the physical control
requirements that must be implemented in order to establish a physically secure location.
CSP Section 5.9.2 details the requirements for establishing a Controlled Area. The
controlled area is an area, a room, or a storage container established for the purpose of
day-to-day CJI access, storage, or processing in the event an agency is unable to meet
all of the controls required for establishing a physically secure location. Access to the
controlled area needs to be restricted to only authorized personnel whenever CJI is
processed. The CJI material needs to be locked away when unattended to prevent
unauthorized and unintentional access. Additionally, the encryption standards of CSP
Section 5.10.1.2 apply to the electronic storage (i.e. data “at rest”) of CJI.
i. 5.10 – System and Communications Protection and Information Integrity
CSP Section 5.10 explains the technical safeguards ranging from boundary and
transmission protection to security an agency’s virtualized environment.
CSP Section 5.10.1.2 details the requirements for the encryption of CJI whether in
transit or at rest. FIPS 140-2 certification is required when CJI is in transit outside a
physically secure location. When at rest outside a physically secure location, encryption
methods can use Advanced Encryption Standard (AES) at 256 bit strength or a FIPS
140-2 certified method.
CSP Section 5.10.3 explains the use of virtualization and partitioning when processing
CJI in a virtual environment. A virtualized environment can be configured such that
those parts of the system which process CJI are either physically or virtually separated
from those that do not.
CSP Section 5.10.4 explains system and information integrity policy and procedures.
This includes areas such as patch management, malicious code protection, and spam and
spyware protection.
j. 5.11 – Formal Audits
CSP Section 5.11 explains the formal audit process to help agencies understand the audit
procedures.
CSP Section 5.11.1 details the requirements for compliance and security audits by the
FBI CJIS Division. The FBI CJIS Division is authorized to conduct audits, once every
three (3) years as a minimum, to assess agency compliance with applicable statutes,
regulations and policies.
The CJIS Audit Unit (CAU) will conduct triennial audits of each CSA in order to verify
compliance with applicable statutes, regulations and policies. This audit includes a
sample of Criminal Justice Agency (CJA) and NCJAs, in coordination with the SIB.
Note 1: Audits may be conducted on a more frequent basis if the audit reveals that an
agency has not complied with applicable statutes, regulations and policies.
Note 2: The FBI CJIS Division has the authority to conduct unannounced security
inspections and scheduled audits of Contractor facilities.
CSP Section 5.11.2 describes the requirements for the CSA to triennially audit all CJAs
and NCJAs with direct access to the state system, establish a process to periodically
audit all NCJAs with access to CJI, establish the authority to conduct unannounced
security inspections and scheduled audits of Contractor facilities.
CSP Section 5.11.3 describes the requirement that all agencies with access to CJI must
permit an inspection team to conduct an appropriate inquiry and audit of any alleged
security violations. The inspection team, appointed by the APB, will include at least one
representative of the CJIS Division. All results of the inquiry and audit will be reported
to the APB with appropriate recommendations.
k. 5.12 – Personnel Security
CSP Section 5.12 provides agencies the security terms and requirements as they apply
to all personnel who have access to unencrypted CJI, including individuals with only
physical or logical access to devices that store, process or transmit unencrypted CJI.
CSP Section 5.12.1 details the minimum screening requirements for all individuals
requiring access to CJI - listed in CSP Section 5.12.1.1. In addition to the requirements
listed in CSP Section 5.12.1.1 contractors and vendors must undergo additional
screening requirements as listed in CSP Section 5.12.1.2.
CSP Section 5.12.2 describes the requirement for an agency to immediately terminate
CJI access for an individual upon termination of employment.
CSP Section 5.12.3 describes the requirement for an agency to review CJI access
authorizations and initiate appropriate actions (such as closing and establishing accounts
and changing system access authorizations) whenever personnel are reassigned or
transferred to other positions within the agency.
CSP Section 5.12.4 describes the requirement for an agency to employ a formal
sanctions process for personnel failing to comply with established information security
policies and procedures.
l. 5.13 – Mobile Devices
When access to CJI using mobile devices such as laptops, smartphones, and tablets is
authorized, CSP Section 5.13 explains the controls required to manage those devices to
ensure the information remains protected.
The following scenarios are intended to help the reader identify areas within the CSP that
CJAs may often come across. Each scenario should be reviewed for applicability in
conjunction with the above “General CJI Guidance” section. The specific requirements
found with the CSP are not shown; however specific sections are referenced along with a
requirements summary.
Hard Copy CJI Storage and Accessibility
When CJI is received in hard copy and the agency stores the paper within a locked file cabinet,
the CJA should, in addition to the “General CJI Guidance”, focus on compliance with policy
section:
a. 4.2.4 – Storage
When storing CJI, appropriate administrative, technical, and physical safeguards must
be implemented to ensure the security and confidentiality of the information.
Electronic CJI Storage and Accessibility – Controlled Area
When an agency creates an electronic copy of CJI (e.g. scanning a document or creation of a
spreadsheet) and subsequently stores this static CJI on either a local hard drive or shared
network drive in a controlled area for indirect access by Authorized Recipients, the agency
should, in addition to the “General CJI Guidance”, focus on compliance with policy section:
a. 5.5.2.4 (3) – Access Control Mechanisms – Encryption
CSP Section 5.5.2.4 item 3, Encryption – This describes the requirement for utilizing
encryption as the primary access control mechanism which is necessary in this
situation. Encrypted information can only be read by personnel possessing the
appropriate cryptographic key (e.g., passphrase) to decrypt. Refer to Section 5.10.1.2
for specific encryption requirements.
Electronic CJI Storage and Accessibility – Physically Secure Location
When an agency receives or creates an electronic copy of CJI and subsequently stores this CJI
within a Records Management System (RMS), located within a physically secure location that
may be queried by Authorized Recipients, the agency should, in addition to the “General CJI
Guidance”, focus on compliance with policy sections:
a. 5.5 – Access Control
CSP Section 5.5 describes the requirements and parameters for utilizing access control
mechanisms for restricting CJI access (such as the reading, writing, processing and
transmission of CJIS information) and the modification of information systems,
applications, services and communication configurations allowing access to CJI to only
authorized personnel.
b. 5.6 – Identification and Authentication
CSP Section 5.6 describes the requirements and parameters agencies must implement to
validate and authenticate the identity of information system users and processes acting
on behalf of users the identities prior to granting access to CJI or agency information
systems/services that process CJI.
c. 5.7 – Configuration Management
CSP Section 5.7 describes the requirements for implementing access restrictions that
will only permit authorized and qualified individuals access to information system
components for purposes of initiating changes, including upgrades, and modifications.
CSP Section 5.7.1 describes the requirements for implementing the concept of least
privilege (5.7.1.1) and for developing and maintaining network diagrams (5.7.1.2) that
detail how the RMS is interconnected and protected within the network. See Appendix
C for sample network diagrams.
CSP Section 5.7.2 details the requirement for agencies to protect the system
documentation from unauthorized access consistent with the provisions described in
Section 5.5 Access Control.
d. 5.10 – System and Communications Protection and Information Integrity
CSP Section 5.10 details the requirements for network infrastructures within physically
secure locations through establishment of system and communication boundary and
transmission protection safeguards that assist in securing an agency’s environment, even
when virtualized. In addition, this section describes the requirements for providing the
capability to ensure system integrity through the detection and protection against
unauthorized changes to software and information for applications, services, and
information systems.
Use Case Scenarios
1. Indirect Access to Criminal Justice Information (CJI) Stored on a Network Server
A county court scans hard copy case documents containing CJI into an electronic format.
The documents are placed on a network server which is located in a secure data center
within the court offices. The data center meets all the requirements to be labeled a
physically secure location as defined in Section 5.9.1 of the CSP.
Keeping in mind the scenario as described, an authorized user needs access to case
documents. This user is not located in the secure data center and will have to use remote
access to access the file. The user is therefore required to provide identification and
authentication credentials to prove they are an authorized user. To access the documents,
the user is prompted to enter their unique username and password. Because the documents
reside on a system with indirect access to CJI (does not allow the user to query a state or
national criminal record repository), AA is not required for access to the documents.
NOTE: If the Authorized User has direct access to CJI (the ability to query a state or
national criminal record repository) in the above scenario, AA would be required.
2. Encryption for Data at Rest (Exemption for FIPS 140-2 Certified Encryption)
A county court scans hard copy case documents containing CJI in an electronic format.
The documents are placed on a network server which is not located in a secure data center.
Because the data center does not meet the requirements of a physically secure location, as
defined in Section 5.9.1 of the CSP, the files, at rest (in storage) on the server, are required
to be encrypted.
To prevent unauthorized access, the IT staff has decided to encrypt the entire folder that
contains the files. They will use a product that provides an advanced encryption standard
(AES) algorithm at 256 bit strength to comply with the CSP and employ a CSP compliant
passphrase to lock the folder’s encryption. When an authorized user needs to access to the
case documents, they access the folder on the server and are prompted to enter the
designated passphrase to decrypt (unlock) the folder. The user can then access all files
within the folder. Additionally, because the documents reside on a system with indirect
access to CJI (does not allow the user to query a state or national criminal record
repository), AA is not required for access to the documents.
NOTE: Whenever authorized personnel no longer require access to the encrypted folder,
the passphrase must be changed to prevent future access by that user.

CJIS-5.6 (stripped).txt

U. S. Department of Justice
Federal Bureau of Investigation
Criminal Justice Information Services Division

Criminal Justice Information Services (CJIS)
Security Policy
Version 5.6
EXECUTIVE SUMMARY
Law enforcement needs timely and secure access to services that provide data wherever and
whenever for stopping and reducing crime. In response to these needs, the Advisory Policy Board
(APB) recommended to the Federal Bureau of Investigation (FBI) that the Criminal Justice
Information Services (CJIS) Division authorize the expansion of the existing security management
structure in 1998. Administered through a shared management philosophy, the CJIS Security
Policy contains information security requirements, guidelines, and agreements reflecting the will
of law enforcement and criminal justice agencies for protecting the sources, transmission, storage,
and generation of Criminal Justice Information (CJI). The Federal Information Security
Management Act of 2002 provides further legal basis for the APB approved management,
operational, and technical security requirements mandated to protect CJI and by extension the
hardware, software and infrastructure required to enable the services provided by the criminal
justice community.
The essential premise of the CJIS Security Policy is to provide appropriate controls to protect the
full lifecycle of CJI, whether at rest or in transit. The CJIS Security Policy provides guidance for
the creation, viewing, modification, transmission, dissemination, storage, and destruction of CJI.
This Policy applies to every individual—contractor, private entity, noncriminal justice agency
representative, or member of a criminal justice entity—with access to, or who operate in support
of, criminal justice services and information.
The CJIS Security Policy integrates presidential directives, federal laws, FBI directives and the
criminal justice community’s APB decisions along with nationally recognized guidance from the
National Institute of Standards and Technology. The Policy is presented at both strategic and
tactical levels and is periodically updated to reflect the security requirements of evolving business
models. The Policy features modular sections enabling more frequent updates to address emerging
threats and new security measures. The provided security criteria assists agencies with designing
and implementing systems to meet a uniform level of risk and security protection while enabling
agencies the latitude to institute more stringent security requirements and controls based on their
business model and local needs.
The CJIS Security Policy strengthens the partnership between the FBI and CJIS Systems Agencies
(CSA), including, in those states with separate authorities, the State Identification Bureaus (SIB).
Further, as use of criminal history record information for noncriminal justice purposes continues
to expand, the CJIS Security Policy becomes increasingly important in guiding the National Crime
Prevention and Privacy Compact Council and State Compact Officers in the secure exchange of
criminal justice records.
The Policy describes the vision and captures the security concepts that set the policies, protections,
roles, and responsibilities with minimal impact from changes in technology. The Policy empowers
CSAs with the insight and ability to tune their security programs according to their risks, needs,
budgets, and resource constraints while remaining compliant with the baseline level of security set
forth in this Policy. The CJIS Security Policy provides a secure framework of laws, standards, and
elements of published and vetted policies for accomplishing the mission across the broad spectrum
of the criminal justice and noncriminal justice communities.

CHANGE MANAGEMENT
Revision

Change Description

Created/Changed by

Date

Approved By

5.0

Policy Rewrite

Security Policy
Working Group

SUMMARY OF CHANGES
Version 5.6
APB Approved Changes
1. Section 5.6.2.1 Standard Authenticators: add language concerning tokens and one-time
passwords, Fall 2016, APB16, SA4, Standard Authenticator Use in the CJIS Security
Policy.
2. Section 5.6.2.1 Standard Authenticators: add new Section 5.6.2.1.3 One-time Passwords
(OTP), Fall 2016, APB16, SA4, Standard Authenticator Use in the CJIS Security Policy.
3. Section 5.10.1.2 Encryption: modify language in section, Spring 2016, APB15, SA4,
Clarifying Encryption Requirements in the CJIS Security Policy.
4. Section 5.10.1.2.1 Encryption for CJI in Transit: create new section and realign
requirements, Spring 2016, APB14, SA4, Clarifying Encryption Requirements in the
CJIS Security Policy.
5. Section 5.10.1.2.2 Encryption for CJI at Rest: create new section and realign
requirements, Spring 2016, APB15, SA4, Clarifying Encryption Requirements in the
CJIS Security Policy.
6. Section 5.10.1.2.2 Encryption for CJI at Rest: remove the reference to National Security
Agency (NSA) Suite B Cryptography, Fall 2016, APB16, SA2, Update to Encryption for
Criminal Justice Information (CJI) at Rest.
7. Section 5.10.1.2.3 Public Key Infrastructure (PKI) Technology: create new section and
add language, Spring 2016, APB15, SA4, Clarifying Encryption Requirements in the
CJIS Security Policy.
8. Appendix A Terms and Definitions: add new definitions – “Asymmetric Encryption”,
“Hybrid Encryption”, “Symmetric Encryption”, Spring 2016, APB15, SA4, Clarifying
Encryption Requirements in the CJIS Security Policy.
9. Appendix B Acronyms: add new acronyms – “OTP – One-time Password”, Fall 2016,
APB16, SA4, Standard Authenticator Use in the CJIS Security Policy,
10. Appendix G.3 Cloud Computing: modify language throughout the appendix, Fall 2016,
APB16, SA3, Encrypting CJI Stored or Accessed within a Cloud Environment.
11. Appendix G.6 Encryption: create a new best practices appendix, Spring 2016, APB15,
SA4, Clarifying Encryption Requirements in the CJIS Security Policy.
Administrative Changes1
1. Section 5.1.1.4, change “inter-agency” to “interagency” for consistency.
2. Section 5.1.2, change “inter-agency” to “interagency” for consistency.
3. Section 5.10.1.1 Boundary Protection: bullet 5, modify language, “(i.e. the device shall
“failfails open” vs. “failfails closed”).”
4. Section 5.11 Formal Audits: add new Section 5.11.4 Compliance Subcommittees and add
language
5. Section 5.11.4 References/Citations/Directives: renumber to Section 5.11.5

1

Administrative changes are vetted through the Security and Access Subcommittee and not the entire APB process.

6. Section 5.12.1.1 Minimum Screening Requirements for Individuals Requiring Access to
CJI: bullet 6, remove language “, and, if applicable, the appropriate board maintaining
management control,”
7. Section 5.13.1.1 802.11 Wireless Protocols: change “80.11i” to “802.11i”
8. Appendix A Terms and Definitions: add new definitions – “Decryption”, “Encryption”
9. Appendix G.6 Encryption: Add language describing FIPS-140-2 certification

KEY TO APB APPROVED CHANGES (e.g. “Fall 2013, APB11, SA6, Future CSP for Mobile
Devices”):
Fall 2013 – Advisory Policy Board cycle and year
APB## – Advisory Policy Board Topic number
SA# – Security and Access Subcommittee Topic number
Topic Title

TABLE OF CONTENTS
Executive Summary ....................................................................................................................... i
Change Management .................................................................................................................... ii
Summary of Changes ................................................................................................................... iii
Table of Contents ...........................................................................................................................v
List of Figures ............................................................................................................................... xi
1 Introduction ............................................................................................................................1
1.1 Purpose.................................................................................................................................1
1.2 Scope ....................................................................................................................................1
1.3 Relationship to Local Security Policy and Other Policies ...................................................1
1.4 Terminology Used in This Document..................................................................................2
1.5 Distribution of the CJIS Security Policy ..............................................................................2
2 CJIS Security Policy Approach ............................................................................................3
2.1 CJIS Security Policy Vision Statement................................................................................3
2.2 Architecture Independent .....................................................................................................3
2.3 Risk Versus Realism ............................................................................................................3
3 Roles and Responsibilities .....................................................................................................4
3.1 Shared Management Philosophy..........................................................................................4
3.2 Roles and Responsibilities for Agencies and Parties ...........................................................4
3.2.1 CJIS Systems Agencies (CSA) ..................................................................................5
3.2.2 CJIS Systems Officer (CSO) ......................................................................................5
3.2.3 Terminal Agency Coordinator (TAC) ........................................................................6
3.2.4 Criminal Justice Agency (CJA)..................................................................................6
3.2.5 Noncriminal Justice Agency (NCJA) .........................................................................6
3.2.6 Contracting Government Agency (CGA) ..................................................................7
3.2.7 Agency Coordinator (AC) ..........................................................................................7
3.2.8 CJIS Systems Agency Information Security Officer (CSA ISO) ..............................7
3.2.9 Local Agency Security Officer (LASO) ....................................................................8
3.2.10 FBI CJIS Division Information Security Officer (FBI CJIS ISO) .............................8
3.2.11 Repository Manager ...................................................................................................9
3.2.12 Compact Officer .........................................................................................................9
4 Criminal Justice Information and Personally Identifiable Information ........................10
4.1 Criminal Justice Information (CJI) ....................................................................................10
4.1.1 Criminal History Record Information (CHRI) .........................................................10
4.2 Access, Use and Dissemination of Criminal History Record Information (CHRI), NCIC
Restricted Files Information, and NCIC Non-Restricted Files Information ......................11
4.2.1 Proper Access, Use, and Dissemination of CHRI ....................................................11
4.2.2 Proper Access, Use, and Dissemination of NCIC Restricted Files Information ......11
4.2.3 Proper Access, Use, and Dissemination of NCIC Non-Restricted Files
Information.....................................................................................................................11
4.2.3.1 For Official Purposes .........................................................................................11
4.2.3.2 For Other Authorized Purposes .........................................................................12
4.2.3.3 CSO Authority in Other Circumstances ............................................................12
4.2.4 Storage ......................................................................................................................12
4.2.5 Justification and Penalties ........................................................................................12

4.2.5.1 Justification ........................................................................................................12
4.2.5.2 Penalties .............................................................................................................12
4.3 Personally Identifiable Information (PII)...........................................................................12
5 Policy and Implementation .................................................................................................14
5.1 Policy Area 1: Information Exchange Agreements ...........................................................15
5.1.1 Information Exchange ..............................................................................................15
5.1.1.1 Information Handling.........................................................................................15
5.1.1.2 State and Federal Agency User Agreements .....................................................15
5.1.1.3 Criminal Justice Agency User Agreements .......................................................16
5.1.1.4 Interagency and Management Control Agreements ..........................................16
5.1.1.5 Private Contractor User Agreements and CJIS Security Addendum.................16
5.1.1.6 Agency User Agreements ..................................................................................17
5.1.1.7 Outsourcing Standards for Channelers ..............................................................17
5.1.1.8 Outsourcing Standards for Non-Channelers ......................................................18
5.1.2 Monitoring, Review, and Delivery of Services ........................................................18
5.1.2.1 Managing Changes to Service Providers ...........................................................18
5.1.3 Secondary Dissemination .........................................................................................18
5.1.4 Secondary Dissemination of Non-CHRI CJI ...........................................................18
5.1.5 References/Citations/Directives ...............................................................................19
5.2 Policy Area 2: Security Awareness Training .....................................................................20
5.2.1 Awareness Topics ....................................................................................................20
5.2.1.1 Level One Security Awareness Training ...........................................................20
5.2.1.2 Level Two Security Awareness Training ..........................................................20
5.2.1.3 Level Three Security Awareness Training ........................................................20
5.2.1.4 Level Four Security Awareness Training ..........................................................21
5.2.2 Security Training Records ........................................................................................22
5.2.3 References/Citations/Directives ...............................................................................22
5.3 Policy Area 3: Incident Response ......................................................................................24
5.3.1 Reporting Security Events ........................................................................................24
5.3.1.1 Reporting Structure and Responsibilities...........................................................24
5.3.1.1.1 FBI CJIS Division Responsibilities ............................................................ 24
5.3.1.1.2 CSA ISO Responsibilities ........................................................................... 24
5.3.2 Management of Security Incidents ...........................................................................25
5.3.2.1 Incident Handling...............................................................................................25
5.3.2.2 Collection of Evidence .......................................................................................25
5.3.3 Incident Response Training ......................................................................................25
5.3.4 Incident Monitoring..................................................................................................25
5.3.5 References/Citations/Directives ...............................................................................26
5.4 Policy Area 4: Auditing and Accountability ......................................................................27
5.4.1 Auditable Events and Content (Information Systems) .............................................27
5.4.1.1 Events .................................................................................................................27
5.4.1.1.1 Content ........................................................................................................ 28
5.4.2 Response to Audit Processing Failures ....................................................................28
5.4.3 Audit Monitoring, Analysis, and Reporting .............................................................28
5.4.4 Time Stamps .............................................................................................................28
5.4.5 Protection of Audit Information ...............................................................................28

5.4.6 Audit Record Retention ............................................................................................28
5.4.7 Logging NCIC and III Transactions .........................................................................29
5.4.8 References/Citations/Directives ...............................................................................29
5.5 Policy Area 5: Access Control ...........................................................................................30
5.5.1 Account Management ..............................................................................................30
5.5.2 Access Enforcement .................................................................................................30
5.5.2.1 Least Privilege ...................................................................................................31
5.5.2.2 System Access Control ......................................................................................31
5.5.2.3 Access Control Criteria ......................................................................................31
5.5.2.4 Access Control Mechanisms ..............................................................................31
5.5.3 Unsuccessful Login Attempts ..................................................................................32
5.5.4 System Use Notification...........................................................................................32
5.5.5 Session Lock ............................................................................................................32
5.5.6 Remote Access .........................................................................................................33
5.5.6.1 Personally Owned Information Systems ............................................................33
5.5.6.2 Publicly Accessible Computers .........................................................................34
5.5.7 References/Citations/Directives ...............................................................................34
5.6 Policy Area 6: Identification and Authentication ..............................................................35
5.6.1 Identification Policy and Procedures ........................................................................35
5.6.1.1 Use of Originating Agency Identifiers in Transactions and Information
Exchanges ..................................................................................................................35
5.6.2 Authentication Policy and Procedures .....................................................................35
5.6.2.1 Standard Authenticators .....................................................................................36
5.6.2.1.1 Password ..................................................................................................... 36
5.6.2.1.2 Personal Identification Number (PIN) ........................................................ 36
5.6.2.1.3 One-time Passwords (OTP) ........................................................................ 37
5.6.2.2 Advanced Authentication...................................................................................37
5.6.2.2.1 Advanced Authentication Policy and Rationale ......................................... 37
5.6.2.2.2 Advanced Authentication Decision Tree .................................................... 38
5.6.3 Identifier and Authenticator Management ...............................................................40
5.6.3.1 Identifier Management .......................................................................................40
5.6.3.2 Authenticator Management ................................................................................40
5.6.4 Assertions .................................................................................................................40
5.6.5 References/Citations/Directives ...............................................................................41
5.7 Policy Area 7: Configuration Management .......................................................................47
5.7.1 Access Restrictions for Changes ..............................................................................47
5.7.1.1 Least Functionality.............................................................................................47
5.7.1.2 Network Diagram...............................................................................................47
5.7.2 Security of Configuration Documentation ...............................................................47
5.7.3 References/Citations/Directives ...............................................................................47
5.8 Policy Area 8: Media Protection ........................................................................................49
5.8.1 Media Storage and Access .......................................................................................49
5.8.2 Media Transport .......................................................................................................49
5.8.2.1 Digital Media during Transport .........................................................................49
5.8.2.2 Physical Media in Transit ..................................................................................49
5.8.3 Digital Media Sanitization and Disposal ..................................................................49

5.8.4 Disposal of Physical Media ......................................................................................49
5.8.5 References/Citations/Directives ...............................................................................50
5.9 Policy Area 9: Physical Protection ....................................................................................51
5.9.1 Physically Secure Location ......................................................................................51
5.9.1.1 Security Perimeter ..............................................................................................51
5.9.1.2 Physical Access Authorizations .........................................................................51
5.9.1.3 Physical Access Control ....................................................................................51
5.9.1.4 Access Control for Transmission Medium ........................................................51
5.9.1.5 Access Control for Display Medium .................................................................51
5.9.1.6 Monitoring Physical Access ..............................................................................52
5.9.1.7 Visitor Control ...................................................................................................52
5.9.1.8 Delivery and Removal .......................................................................................52
5.9.2 Controlled Area ........................................................................................................52
5.9.3 References/Citations/Directives ...............................................................................52
5.10 Policy Area 10: System and Communications Protection and Information Integrity .......53
5.10.1 Information Flow Enforcement ................................................................................53
5.10.1.1 Boundary Protection ..........................................................................................53
5.10.1.2 Encryption ..........................................................................................................54
5.10.1.2.1 Encryption for CJI in Transit ...................................................................... 54
5.10.1.2.2 Encryption for CJI at Rest........................................................................... 55
5.10.1.2.3 Public Key Infrastructure (PKI) Technology .............................................. 55
5.10.1.3 Intrusion Detection Tools and Techniques ........................................................56
5.10.1.4 Voice over Internet Protocol ..............................................................................56
5.10.1.5 Cloud Computing ...............................................................................................56
5.10.2 Facsimile Transmission of CJI .................................................................................56
5.10.3 Partitioning and Virtualization .................................................................................57
5.10.3.1 Partitioning.........................................................................................................57
5.10.3.2 Virtualization .....................................................................................................57
5.10.4 System and Information Integrity Policy and Procedures ........................................58
5.10.4.1 Patch Management .............................................................................................58
5.10.4.2 Malicious Code Protection .................................................................................58
5.10.4.3 Spam and Spyware Protection ...........................................................................59
5.10.4.4 Security Alerts and Advisories ..........................................................................59
5.10.4.5 Information Input Restrictions ...........................................................................59
5.10.5 References/Citations/Directives ...............................................................................59
5.11 Policy Area 11: Formal Audits ..........................................................................................61
5.11.1 Audits by the FBI CJIS Division..............................................................................61
5.11.1.1 Triennial Compliance Audits by the FBI CJIS Division ...................................61
5.11.1.2 Triennial Security Audits by the FBI CJIS Division .........................................61
5.11.2 Audits by the CSA....................................................................................................61
5.11.3 Special Security Inquiries and Audits ......................................................................62
5.11.4 Compliance Subcommittees .....................................................................................62
5.11.5 References/Citations/Directives ...............................................................................62
5.12 Policy Area 12: Personnel Security ...................................................................................63
5.12.1 Personnel Security Policy and Procedures ...............................................................63
5.12.1.1 Minimum Screening Requirements for Individuals Requiring Access to CJI:..63

5.12.1.2 Personnel Screening for Contractors and Vendors ............................................64
5.12.2 Personnel Termination .............................................................................................64
5.12.3 Personnel Transfer ....................................................................................................65
5.12.4 Personnel Sanctions..................................................................................................65
5.12.5 References/Citations/Directives ...............................................................................65
5.13 Policy Area 13: Mobile Devices ........................................................................................66
5.13.1 Wireless Communications Technologies .................................................................66
5.13.1.1 802.11 Wireless Protocols .................................................................................66
5.13.1.2 Cellular Devices .................................................................................................67
5.13.1.2.1 Cellular Service Abroad .............................................................................. 68
5.13.1.2.2 Voice Transmissions Over Cellular Devices .............................................. 68
5.13.1.3 Bluetooth ............................................................................................................68
5.13.1.4 Mobile Hotspots .................................................................................................68
5.13.2 Mobile Device Management (MDM) ......................................................................69
5.13.3 Wireless Device Risk Mitigations ............................................................................69
5.13.4 System Integrity .......................................................................................................70
5.13.4.1 Patching/Updates ...............................................................................................70
5.13.4.2 Malicious Code Protection .................................................................................70
5.13.4.3 Personal Firewall ...............................................................................................70
5.13.5 Incident Response ....................................................................................................71
5.13.6 Access Control .........................................................................................................71
5.13.7 Identification and Authentication .............................................................................71
5.13.7.1 Local Device Authentication .............................................................................71
5.13.7.2 Advanced Authentication...................................................................................71
5.13.7.2.1 Compensating Controls ............................................................................... 72
5.13.7.3 Device Certificates .............................................................................................72
Appendices ................................................................................................................................. A-1
Appendix A Terms and Definitions ...................................................................................... A-1
Appendix B Acronyms ............................................................................................................B-1
Appendix C Network Topology Diagrams ........................................................................... C-1
Appendix D Sample Information Exchange Agreements ................................................... D-1
D.1 CJIS User Agreement ..................................................................................................... D-1
D.2 Management Control Agreement .................................................................................... D-9
D.3 Noncriminal Justice Agency Agreement & Memorandum of Understanding.............. D-10
D.4 Interagency Connection Agreement ............................................................................. D-16
Appendix E Security Forums and Organizational Entities .................................................E-1
Appendix F Sample Forms ..................................................................................................... F-1
F.1 Security Incident Response Form .................................................................................... F-2
Appendix G Best practices ..................................................................................................... G-1
G.1 Virtualization .................................................................................................................. G-1
G.2 Voice over Internet Protocol ........................................................................................... G-4
G.3 Cloud Computing .......................................................................................................... G-15
G.4 Mobile Appendix .......................................................................................................... G-32
G.5 Administrator Accounts for Least Privilege and Separation of Duties......................... G-53
G.6 Encryption ..................................................................................................................... G-66
Appendix H Security Addendum .......................................................................................... H-1

Appendix I References ............................................................................................................I-1
Appendix J Noncriminal Justice Agency Supplemental Guidance ................................... J-1
Appendix K Criminal Justice Agency Supplemental Guidance ........................................ K-1

LIST OF FIGURES
Figure 1 – Overview Diagram of Strategic Functions and Policy Components ..............................4
Figure 2 – Dissemination of restricted and non-restricted NCIC data...........................................13
Figure 3 – Information Exchange Agreements Implemented by a Local Police Department .......19
Figure 4 – Security Awareness Training Use Cases ......................................................................22
Figure 5 – Incident Response Process Initiated by an Incident in a Local Police Department .....26
Figure 6 – Local Police Department's Use of Audit Logs .............................................................29
Figure 7 – A Local Police Department’s Access Controls ............................................................34
Figure 8 – Advanced Authentication Use Cases............................................................................41
Figure 9 – Authentication Decision for Known Location .............................................................45
Figure 10 – Authentication Decision for Unknown Location .......................................................46
Figure 11 – A Local Police Department’s Configuration Management Controls .........................48
Figure 12 – A Local Police Department’s Media Management Policies.......................................50
Figure 13 – A Local Police Department's Physical Protection Measures ......................................52
Figure 14 – System and Communications Protection and Information Integrity Use Cases.........59
Figure 15 – The Audit of a Local Police Department ....................................................................62
Figure 16 – A Local Police Department's Personnel Security Controls ........................................65

1 INTRODUCTION
This section details the purpose of this document, its scope, relationship to other information
security policies, and its distribution constraints.

1.1 Purpose
The CJIS Security Policy provides Criminal Justice Agencies (CJA) and Noncriminal Justice
Agencies (NCJA) with a minimum set of security requirements for access to Federal Bureau of
Investigation (FBI) Criminal Justice Information Services (CJIS) Division systems and
information and to protect and safeguard Criminal Justice Information (CJI). This minimum
standard of security requirements ensures continuity of information protection. The essential
premise of the CJIS Security Policy is to provide the appropriate controls to protect CJI, from
creation through dissemination; whether at rest or in transit.
The CJIS Security Policy integrates presidential directives, federal laws, FBI directives, the
criminal justice community’s Advisory Policy Board (APB) decisions along with nationally
recognized guidance from the National Institute of Standards and Technology (NIST) and the
National Crime Prevention and Privacy Compact Council (Compact Council).

1.2 Scope
At the consent of the advisory process, and taking into consideration federal law and state statutes,
the CJIS Security Policy applies to all entities with access to, or who operate in support of, FBI
CJIS Division’s services and information. The CJIS Security Policy provides minimum security
requirements associated with the creation, viewing, modification, transmission, dissemination,
storage, or destruction of CJI.
Entities engaged in the interstate exchange of CJI data for noncriminal justice purposes are also
governed by the standards and rules promulgated by the Compact Council.

1.3 Relationship to Local Security Policy and Other Policies
The CJIS Security Policy may be used as the sole security policy for the agency. The local agency
may complement the CJIS Security Policy with a local policy, or the agency may develop their
own stand-alone security policy; however, the CJIS Security Policy shall always be the minimum
standard and local policy may augment, or increase the standards, but shall not detract from the
CJIS Security Policy standards.
The agency shall develop, disseminate, and maintain formal, documented procedures to facilitate
the implementation of the CJIS Security Policy and, where applicable, the local security policy.
The policies and procedures shall be consistent with applicable laws, executive orders, directives,
policies, regulations, standards, and guidance. Procedures developed for CJIS Security Policy
areas can be developed for the security program in general, and for a particular information system,
when required.
This document is a compendium of applicable policies in providing guidance on the minimum
security controls and requirements needed to access FBI CJIS information and services. These
policies include presidential directives, federal laws, FBI directives and the criminal justice
community’s APB decisions. State, local, and Tribal CJA may implement more stringent policies
and requirements. Appendix I contains the references while Appendix E lists the security forums
and organizational entities referenced in this document.

1.4 Terminology Used in This Document
The following terms are used interchangeably throughout this document:


Agency and Organization: The two terms in this document refer to any entity that submits
or receives information, by any means, to/from FBI CJIS systems or services.



Information and Data: Both terms refer to CJI.



System, Information System, Service, or named applications like NCIC: all refer to
connections to the FBI’s criminal justice information repositories and the equipment used
to establish said connections.

Appendix A and B provide an extensive list of the terms and acronyms.

1.5 Distribution of the CJIS Security Policy
The CJIS Security Policy, version 5.0 and later, is a publically available document and may be
posted and shared without restrictions.

2 CJIS SECURITY POLICY APPROACH
The CJIS Security Policy represents the shared responsibility between FBI CJIS, CJIS Systems
Agency (CSA), and the State Identification Bureaus (SIB) of the lawful use and appropriate
protection of CJI. The Policy provides a baseline of security requirements for current and planned
services and sets a minimum standard for new initiatives.

2.1 CJIS Security Policy Vision Statement
The executive summary of this document describes the vision in terms of business needs for
confidentiality, integrity, and availability of information. The APB collaborates with the FBI CJIS
Division to ensure that the Policy remains updated to meet evolving business, technology and
security needs.

2.2 Architecture Independent
Due to advancing technology and evolving business models, the FBI CJIS Division is transitioning
from legacy stovepipe systems and moving toward a flexible services approach. Systems such as
National Crime Information Center (NCIC), National Instant Criminal Background Check System
(NICS), and Next Generation Identification (NGI) will continue to evolve and may no longer retain
their current system platforms, hardware, or program name. However, the data and services
provided by these systems will remain stable.
The CJIS Security Policy looks at the data (information), services, and protection controls that
apply regardless of the implementation architecture. Architectural independence is not intended
to lessen the importance of systems, but provide for the replacement of one technology with
another while ensuring the controls required to protect the information remain constant. This
objective and conceptual focus on security policy areas provide the guidance and standards while
avoiding the impact of the constantly changing landscape of technical innovations. The
architectural independence of the Policy provides agencies with the flexibility for tuning their
information security infrastructure and policies to reflect their own environments.

2.3 Risk Versus Realism
Every “shall” statement contained within the CJIS Security Policy has been scrutinized for risk
versus the reality of resource constraints and real-world application. The purpose of the CJIS
Security Policy is to establish the minimum security requirements; therefore, individual agencies
are encouraged to implement additional controls to address agency specific risks. Each agency
faces risk unique to that agency. It is quite possible that several agencies could encounter the same
type of risk however depending on resources would mitigate that risk differently. In that light, a
risk-based approach can be used when implementing requirements.

3 ROLES AND RESPONSIBILITIES
3.1 Shared Management Philosophy
In the scope of information security, the FBI CJIS Division employs a shared management
philosophy with federal, state, local, and tribal law enforcement agencies. Although an advisory
policy board for the NCIC has existed since 1969, the Director of the FBI established the CJIS
APB in March 1994 to enable appropriate input and recommend policy with respect to CJIS
services. Through the APB and its Subcommittees and Working Groups, consideration is given
to the needs of the criminal justice and law enforcement community regarding public policy,
statutory and privacy aspects, as well as national security relative to CJIS systems and information.
The APB represents federal, state, local, and tribal law enforcement and criminal justice agencies
throughout the United States, its territories, and Canada.
The FBI has a similar relationship with the Compact Council, which governs the interstate
exchange of criminal history records for noncriminal justice purposes. The Compact Council is
mandated by federal law to promulgate rules and procedures for the use of the Interstate
Identification Index (III) for noncriminal justice purposes. To meet that responsibility, the
Compact Council depends on the CJIS Security Policy as the definitive source for standards
defining the security and privacy of records exchanged with noncriminal justice practitioners.

3.2 Roles and Responsibilities for Agencies and Parties
It is the responsibility of all agencies covered under this Policy to ensure the protection of CJI
between the FBI CJIS Division and its user community. The following figure provides an abstract
representation of the strategic functions and roles such as governance and operations.

Governance

Operations

Policy Structure/Design

CJIS Advisory Policy
Board

CSA Information
Security Officers

Laws and Directives

CJIS Systems Officers

CJIS Systems Agencies

Security Policy and
Implementation Standards

CJIS Working Groups

CJIS Subcommittees
FBI CJIS Information
Security Officer
FBI Director

Compact Officers
Local Agency Security
Officers

Security Standards: National
Institute of Standards and
Technology, International
Standards Organization,
Institute of Electrical and
Electronics Engineers

Repository Managers
Terminal Agency
Coordinators

Figure 1 – Overview Diagram of Strategic Functions and Policy Components

This section provides a description of the following entities and roles:
1. CJIS Systems Agency.
2. CJIS Systems Officer.
3. Terminal Agency Coordinator.
4. Criminal Justice Agency.
5. Noncriminal Justice Agency.
6. Contracting Government Agency.
7. Agency Coordinator.
8. CJIS Systems Agency Information Security Officer.
9. Local Agency Security Officer.
10. FBI CJIS Division Information Security Officer.
11. Repository Manager.
12. Compact Officer.
3.2.1 CJIS Systems Agencies (CSA)
The CSA is responsible for establishing and administering an information technology security
program throughout the CSA’s user community, to include the local levels. The head of each CSA
shall appoint a CJIS Systems Officer (CSO). The CSA may impose more stringent protection
measures than outlined in this document. Such decisions shall be documented and kept current.
3.2.2 CJIS Systems Officer (CSO)
The CSO is an individual located within the CSA responsible for the administration of the CJIS
network for the CSA. Pursuant to the Bylaws for the CJIS Advisory Policy Board and Working
Groups, the role of CSO shall not be outsourced. The CSO may delegate responsibilities to
subordinate agencies. The CSO shall set, maintain, and enforce the following:
1. Standards for the selection, supervision, and separation of personnel who have access to
CJI.
2. Policy governing the operation of computers, access devices, circuits, hubs, routers,
firewalls, and other components that comprise and support a telecommunications network
and related CJIS systems used to process, store, or transmit CJI, guaranteeing the priority,
confidentiality, integrity, and availability of service needed by the criminal justice
community.
a. Ensure appropriate use, enforce system discipline, and ensure CJIS Division
operating procedures are followed by all users of the respective services and
information.
b. Ensure state/federal agency compliance with policies approved by the APB and
adopted by the FBI.

c. Ensure the appointment of the CSA ISO and determine the extent of authority to
the CSA ISO.
d. The CSO, or designee, shall ensure that a Terminal Agency Coordinator (TAC) is
designated within each agency that has devices accessing CJIS systems.
e. Ensure each agency having access to CJI has someone designated as the Local
Agency Security Officer (LASO).
f. Approve access to FBI CJIS systems.
g. Assume ultimate responsibility for managing the security of CJIS systems within
their state and/or agency.
h. Perform other related duties outlined by the user agreements with the FBI CJIS
Division.
3. Outsourcing of Criminal Justice Functions
a. Responsibility for the management of the approved security requirements shall
remain with the CJA. Security control includes the authority to enforce the
standards for the selection, supervision, and separation of personnel who have
access to CJI; set and enforce policy governing the operation of computers, circuits,
and telecommunications terminals used to process, store, or transmit CJI; and to
guarantee the priority service needed by the criminal justice community.
b. Responsibility for the management control of network security shall remain with
the CJA. Management control of network security includes the authority to enforce
the standards for the selection, supervision, and separation of personnel who have
access to CJI; set and enforce policy governing the operation of circuits and
network equipment used to transmit CJI; and to guarantee the priority service as
determined by the criminal justice community.
3.2.3 Terminal Agency Coordinator (TAC)
The TAC serves as the point-of-contact at the local agency for matters relating to CJIS information
access. The TAC administers CJIS systems programs within the local agency and oversees the
agency’s compliance with CJIS systems policies.
3.2.4 Criminal Justice Agency (CJA)
A CJA is defined as a court, a governmental agency, or any subunit of a governmental agency
which performs the administration of criminal justice pursuant to a statute or executive order and
which allocates a substantial part of its annual budget to the administration of criminal justice.
State and federal Inspectors General Offices are included.
3.2.5 Noncriminal Justice Agency (NCJA)
A NCJA is defined (for the purposes of access to CJI) as an entity or any subunit thereof that
provides services primarily for purposes other than the administration of criminal justice.

3.2.6 Contracting Government Agency (CGA)
A CGA is a government agency, whether a CJA or a NCJA, that enters into an agreement with a
private contractor subject to the CJIS Security Addendum. The CGA entering into an agreement
with a contractor shall appoint an agency coordinator.
3.2.7 Agency Coordinator (AC)
An AC is a staff member of the CGA who manages the agreement between the Contractor and
agency. The AC shall be responsible for the supervision and integrity of the system, training and
continuing education of employees and operators, scheduling of initial training and testing, and
certification testing and all required reports by NCIC. The AC shall:
1. Understand the communications, records capabilities, and needs of the Contractor which
is accessing federal and state records through or because of its relationship with the CGA.
2. Participate in related meetings and provide input and comments for system improvement.
3. Receive information from the CGA (e.g., system updates) and disseminate it to appropriate
Contractor employees.
4. Maintain and update manuals applicable to the effectuation of the agreement, and provide
them to the Contractor.
5. Maintain up-to-date records of Contractor’s employees who access the system, including
name, date of birth, social security number, date fingerprint card(s) submitted, date security
clearance issued, and date initially trained, tested, certified or recertified (if applicable).
6. Train or ensure the training of Contractor personnel. If Contractor personnel access NCIC,
schedule the operators for testing or a certification exam with the CSA staff, or AC staff
with permission from the CSA staff. Schedule new operators for the certification exam
within six (6) months of assignment. Schedule certified operators for biennial recertification testing within thirty (30) days prior to the expiration of certification. Schedule
operators for other mandated class.
7. The AC will not permit an untrained/untested or non-certified Contractor employee to
access CJI or systems supporting CJI where access to CJI can be gained.
8. Where appropriate, ensure compliance by the Contractor with NCIC validation
requirements.
9. Provide completed applicant fingerprint cards on each Contractor employee who accesses
the system to the CGA (or, where appropriate, CSA) for criminal background investigation
prior to such employee accessing the system.
10. Any other responsibility for the AC promulgated by the FBI.
3.2.8 CJIS Systems Agency Information Security Officer (CSA ISO)
The CSA ISO shall:
1. Serve as the security point of contact (POC) to the FBI CJIS Division ISO.

2. Document technical compliance with the CJIS Security Policy with the goal to assure the
confidentiality, integrity, and availability of criminal justice information to the user
community throughout the CSA’s user community, to include the local level.
3. Document and provide assistance for implementing the security-related controls for the
Interface Agency and its users.
4. Establish a security incident response and reporting procedure to discover, investigate,
document, and report to the CSA, the affected criminal justice agency, and the FBI CJIS
Division ISO major incidents that significantly endanger the security or integrity of CJI.
3.2.9 Local Agency Security Officer (LASO)
Each LASO shall:
1. Identify who is using the CSA approved hardware, software, and firmware and ensure no
unauthorized individuals or processes have access to the same.
2. Identify and document how the equipment is connected to the state system.
3. Ensure that personnel security screening procedures are being followed as stated in this
Policy.
4. Ensure the approved and appropriate security measures are in place and working as
expected.
5. Support policy compliance and ensure the CSA ISO is promptly informed of security
incidents.
3.2.10 FBI CJIS Division Information Security Officer (FBI CJIS ISO)
The FBI CJIS ISO shall:
1. Maintain the CJIS Security Policy.
2. Disseminate the FBI Director approved CJIS Security Policy.
3. Serve as a liaison with the CSA’s ISO and with other personnel across the CJIS community
and in this regard provide technical guidance as to the intent and implementation of
operational and technical policy issues.
4. Serve as a point-of-contact (POC) for computer incident notification and distribution of
security alerts to the CSOs and ISOs.
5. Assist with developing audit compliance guidelines as well as identifying and reconciling
security-related issues.
6. Develop and participate in information security training programs for the CSOs and ISOs,
and provide a means by which to acquire feedback to measure the effectiveness and success
of such training.
7. Maintain a security policy resource center (SPRC) on FBI.gov and keep the CSOs and
ISOs updated on pertinent information.

3.2.11 Repository Manager
The State Identification Bureau (SIB) Chief, i.e. Repository Manager or Chief Administrator, is
the designated manager of the agency having oversight responsibility for a state’s fingerprint
identification services. If both state fingerprint identification services and CJIS systems control
are managed within the same state agency, the SIB Chief and CSO may be the same person.
3.2.12 Compact Officer
Pursuant to the National Crime Prevention and Privacy Compact, each party state shall appoint a
Compact Officer who shall ensure that Compact provisions and rules, procedures, and standards
established by the Compact Council are complied with in their respective state.

4 CRIMINAL JUSTICE INFORMATION AND PERSONALLY
IDENTIFIABLE INFORMATION
4.1 Criminal Justice Information (CJI)
Criminal Justice Information is the term used to refer to all of the FBI CJIS provided data necessary
for law enforcement and civil agencies to perform their missions including, but not limited to
biometric, identity history, biographic, property, and case/incident history data. The following
categories of CJI describe the various data sets housed by the FBI CJIS architecture:
1. Biometric Data—data derived from one or more intrinsic physical or behavioral traits of
humans typically for the purpose of uniquely identifying individuals from within a
population. Used to identify individuals, to include: fingerprints, palm prints, iris scans,
and facial recognition data.
2. Identity History Data—textual data that corresponds with an individual’s biometric data,
providing a history of criminal and/or civil events for the identified individual.
3. Biographic Data—information about individuals associated with a unique case, and not
necessarily connected to identity data. Biographic data does not provide a history of an
individual, only information related to a unique case.
4. Property Data—information about vehicles and property associated with crime when
accompanied by any personally identifiable information (PII).
5. Case/Incident History—information about the history of criminal incidents.
The following type of data are exempt from the protection levels required for CJI: transaction
control type numbers (e.g., ORI, NIC, FNU, etc.) when not accompanied by information that
reveals CJI or PII.
The intent of the CJIS Security Policy is to ensure the protection of the aforementioned CJI until
the information is: released to the public via authorized dissemination (e.g. within a court system;
presented in crime reports data; released in the interest of public safety); purged or destroyed in
accordance with applicable record retention rules.
4.1.1 Criminal History Record Information (CHRI)
Criminal History Record Information (CHRI), sometimes informally referred to as “restricted
data”, is a subset of CJI. Due to its comparatively sensitive nature, additional controls are required
for the access, use and dissemination of CHRI. In addition to the dissemination restrictions
outlined below, Title 28, Part 20, Code of Federal Regulations (CFR), defines CHRI and provides
the regulatory guidance for dissemination of CHRI. While the CJIS Security Policy attempts to
be architecturally independent, the III and the NCIC are specifically identified in Title 28, Part 20,
CFR, and the NCIC Operating Manual, as associated with CHRI.

4.2 Access, Use and Dissemination of Criminal History Record
Information (CHRI), NCIC Restricted Files Information, and
NCIC Non-Restricted Files Information
This section describes the requirements for the access, use and dissemination of CHRI, NCIC
restricted files information, and NCIC non-restricted files information.
4.2.1 Proper Access, Use, and Dissemination of CHRI
Information obtained from the III is considered CHRI. Rules governing the access, use, and
dissemination of CHRI are found in Title 28, Part 20, CFR. The III shall be accessed only for an
authorized purpose. Further, CHRI shall only be used for an authorized purpose consistent with
the purpose for which III was accessed. Dissemination to another agency is authorized if (a) the
other agency is an Authorized Recipient of such information and is being serviced by the accessing
agency, or (b) the other agency is performing personnel and appointment functions for criminal
justice employment applicants.
4.2.2 Proper Access, Use, and Dissemination of NCIC Restricted Files
Information
The NCIC hosts restricted files and non-restricted files. NCIC restricted files are distinguished
from NCIC non-restricted files by the policies governing their access and use. Proper access to,
use, and dissemination of data from restricted files shall be consistent with the access, use, and
dissemination policies concerning the III described in Title 28, Part 20, CFR, and the NCIC
Operating Manual. The restricted files, which shall be protected as CHRI, are as follows:
1. Gang Files
2. Known or Appropriately Suspected Terrorist Files
3. Supervised Release Files
4. National Sex Offender Registry Files
5. Historical Protection Order Files of the NCIC
6. Identity Theft Files
7. Protective Interest Files
8. Person With Information (PWI) data in the Missing Person Files
9. Violent Person File
10. NICS Denied Transactions File
The remaining NCIC files are considered non-restricted files.
4.2.3 Proper Access, Use, and Dissemination of NCIC Non-Restricted Files
Information
4.2.3.1 For Official Purposes

NCIC non-restricted files are those not listed as restricted files in Section 4.2.2. NCIC nonrestricted files information may be accessed and used for any authorized purpose consistent with
the inquiring agency’s responsibility. Information obtained may be disseminated to (a) other
government agencies or (b) private entities authorized by law to receive such information for any
purpose consistent with their responsibilities.
4.2.3.2 For Other Authorized Purposes

NCIC non-restricted files may be accessed for other purposes consistent with the resources of the
inquiring agency; however, requests for bulk data are discouraged. Information derived from
NCIC non-restricted files for other than law enforcement purposes can be used by authorized
criminal justice personnel only to confirm the status of a person or property (i.e., wanted or stolen).
An inquiring agency is authorized to charge a nominal administrative fee for such service. Nonrestricted files information shall not be disseminated commercially.
A response to a NCIC person inquiry may include NCIC restricted files information as well as
NCIC non-restricted files information. Agencies shall not disseminate restricted files information
for purposes other than law enforcement.
4.2.3.3 CSO Authority in Other Circumstances

If no federal, state or local law or policy prohibition exists, the CSO may exercise discretion to
approve or deny dissemination of NCIC non-restricted file information.
4.2.4 Storage
When CHRI is stored, agencies shall establish appropriate administrative, technical and physical
safeguards to ensure the security and confidentiality of the information. These records shall be
stored for extended periods only when they are key elements for the integrity and/or utility of case
files and/or criminal record files. See Section 5.9 for physical security controls.
4.2.5 Justification and Penalties
4.2.5.1 Justification

In addition to the use of purpose codes and logging information, all users shall provide a reason
for all III inquiries whenever requested by NCIC System Managers, CSAs, local agency
administrators, or their representatives.
4.2.5.2 Penalties

Improper access, use or dissemination of CHRI and NCIC Non-Restricted Files information is
serious and may result in administrative sanctions including, but not limited to, termination of
services and state and federal criminal penalties.

4.3 Personally Identifiable Information (PII)
For the purposes of this document, PII is information which can be used to distinguish or trace an
individual’s identity, such as name, social security number, or biometric records, alone or when
combined with other personal or identifying information which is linked or linkable to a specific
individual, such as date and place of birth, or mother’s maiden name. Any FBI CJIS provided data
maintained by an agency, including but not limited to, education, financial transactions, medical
history, and criminal or employment history may include PII. A criminal history record for

example inherently contains PII as would a Law Enforcement National Data Exchange (N-DEx)
case file.
PII shall be extracted from CJI for the purpose of official business only. Agencies shall develop
policies, based on state and local privacy rules, to ensure appropriate controls are applied when
handling PII extracted from CJI. Due to the expansive nature of PII, this Policy does not specify
auditing, logging, or personnel security requirements associated with the life cycle of PII.
Figure 2 – Dissemination of restricted and non-restricted NCIC data
A citizen of Springfield went to the Springfield Police Department to request whether his new
neighbor, who had been acting suspiciously, had an outstanding warrant. The Springfield Police
Department ran an NCIC persons inquiry, which produced a response that included a Wanted
Person File (non-restricted file) record and a Known or Appropriately Suspected Terrorist File
(restricted file) record. The Springfield Police Department advised the citizen of the
outstanding warrant, but did not disclose any information concerning the subject being a known
or appropriately suspected terrorist.

5 POLICY AND IMPLEMENTATION
The policy areas focus upon the data and services that the FBI CJIS Division exchanges and
provides to the criminal justice community and its partners. Each policy area provides both
strategic reasoning and tactical implementation requirements and standards.
While the major theme of the policy areas is concerned with electronic exchange directly with the
FBI, it is understood that further dissemination of CJI to Authorized Recipients by various means
(hard copy, e-mail, web posting, etc.) constitutes a significant portion of CJI exchanges.
Regardless of its form, use, or method of dissemination, CJI requires protection throughout its life.
Not every consumer of FBI CJIS services will encounter all of the policy areas therefore the
circumstances of applicability are based on individual agency/entity configurations and usage. Use
cases within each of the policy areas will help users relate the Policy to their own agency
circumstances. The policy areas are:


Policy Area 1—Information Exchange Agreements



Policy Area 2—Security Awareness Training



Policy Area 3—Incident Response



Policy Area 4—Auditing and Accountability



Policy Area 5—Access Control



Policy Area 6—Identification and Authentication



Policy Area 7—Configuration Management



Policy Area 8—Media Protection



Policy Area 9—Physical Protection



Policy Area 10—Systems and Communications Protection and Information Integrity



Policy Area 11—Formal Audits



Policy Area 12—Personnel Security



Policy Area 13—Mobile Devices

5.1 Policy Area 1: Information Exchange Agreements
The information shared through communication mediums shall be protected with appropriate
security safeguards. The agreements established by entities sharing information across systems
and communications mediums are vital to ensuring all parties fully understand and agree to a set
of security standards.
5.1.1 Information Exchange
Before exchanging CJI, agencies shall put formal agreements in place that specify security
controls. The exchange of information may take several forms including electronic mail, instant
messages, web services, facsimile, hard copy, and information systems sending, receiving and
storing CJI.
Information exchange agreements outline the roles, responsibilities, and data ownership between
agencies and any external parties. Information exchange agreements for agencies sharing CJI data
that is sent to and/or received from the FBI CJIS shall specify the security controls and conditions
described in this document.
Information exchange agreements shall be supported by documentation committing both parties
to the terms of information exchange. As described in subsequent sections, different agreements
and policies apply, depending on whether the parties involved are CJAs or NCJAs. See Appendix
D for examples of Information Exchange Agreements.
There may be instances, on an ad-hoc basis, where CJI is authorized for further dissemination to
Authorized Recipients not covered by an information exchange agreement with the releasing
agency. In these instances the dissemination of CJI is considered to be secondary dissemination.
Law Enforcement and civil agencies shall have a local policy to validate a requestor of CJI as an
authorized recipient before disseminating CJI. See Section 5.1.3 for secondary dissemination
guidance.
5.1.1.1 Information Handling

Procedures for handling and storage of information shall be established to protect that information
from unauthorized disclosure, alteration or misuse. Using the requirements in this Policy as a
starting point, the procedures shall apply to the handling, processing, storing, and communication
of CJI. These procedures apply to the exchange of CJI no matter the form of exchange.
The policies for information handling and protection also apply to using CJI shared with or
received from FBI CJIS for noncriminal justice purposes. In general, a noncriminal justice purpose
includes the use of criminal history records for purposes authorized by federal or state law other
than purposes relating to the administration of criminal justice, including – but not limited to employment suitability, licensing determinations, immigration and naturalization matters, and
national security clearances.
5.1.1.2 State and Federal Agency User Agreements

Each CSA head or SIB Chief shall execute a signed written user agreement with the FBI CJIS
Division stating their willingness to demonstrate conformity with this Policy before accessing and
participating in CJIS records information programs. This agreement shall include the standards
and sanctions governing utilization of CJIS systems. As coordinated through the particular CSA

or SIB Chief, each Interface Agency shall also allow the FBI to periodically test the ability to
penetrate the FBI’s network through the external network connection or system per authorization
of Department of Justice (DOJ) Order 0904. All user agreements with the FBI CJIS Division shall
be coordinated with the CSA head.
5.1.1.3 Criminal Justice Agency User Agreements

Any CJA receiving access to CJI shall enter into a signed written agreement with the appropriate
signatory authority of the CSA providing the access. The written agreement shall specify the FBI
CJIS systems and services to which the agency will have access, and the FBI CJIS Division
policies to which the agency must adhere. These agreements shall include:
1. Audit.
2. Dissemination.
3. Hit confirmation.
4. Logging.
5. Quality Assurance (QA).
6. Screening (Pre-Employment).
7. Security.
8. Timeliness.
9. Training.
10. Use of the system.
11. Validation.
5.1.1.4 Interagency and Management Control Agreements

A NCJA (government) designated to perform criminal justice functions for a CJA shall be eligible
for access to the CJI. Access shall be permitted when such designation is authorized pursuant to
executive order, statute, regulation, or interagency agreement. The NCJA shall sign and execute a
management control agreement (MCA) with the CJA, which stipulates management control of the
criminal justice function remains solely with the CJA. The MCA may be a separate document or
included with the language of an interagency agreement. An example of an NCJA (government)
is a city information technology (IT) department.
5.1.1.5 Private Contractor User Agreements and CJIS Security Addendum

The CJIS Security Addendum is a uniform addendum to an agreement between the government
agency and a private contractor, approved by the Attorney General of the United States, which
specifically authorizes access to CHRI, limits the use of the information to the purposes for which
it is provided, ensures the security and confidentiality of the information is consistent with existing
regulations and the CJIS Security Policy, provides for sanctions, and contains such other
provisions as the Attorney General may require.
Private contractors who perform criminal justice functions shall meet the same training and
certification criteria required by governmental agencies performing a similar function, and shall
be subject to the same extent of audit review as are local user agencies. All private contractors
who perform criminal justice functions shall acknowledge, via signing of the CJIS Security
Addendum Certification page, and abide by all aspects of the CJIS Security Addendum. The CJIS
Security Addendum is presented in Appendix H. Modifications to the CJIS Security Addendum
shall be enacted only by the FBI.
1. Private contractors designated to perform criminal justice functions for a CJA shall be
eligible for access to CJI. Access shall be permitted pursuant to an agreement which
specifically identifies the agency’s purpose and scope of providing services for the
administration of criminal justice. The agreement between the CJA and the private
contractor shall incorporate the CJIS Security Addendum approved by the Director of the
FBI, acting for the U.S. Attorney General, as referenced in Title 28 CFR 20.33 (a)(7).
2. Private contractors designated to perform criminal justice functions on behalf of a NCJA
(government) shall be eligible for access to CJI. Access shall be permitted pursuant to an
agreement which specifically identifies the agency’s purpose and scope of providing
services for the administration of criminal justice. The agreement between the NCJA and
the private contractor shall incorporate the CJIS Security Addendum approved by the
Director of the FBI, acting for the U.S. Attorney General, as referenced in Title 28 CFR
20.33 (a)(7).
5.1.1.6 Agency User Agreements

A NCJA (public) designated to request civil fingerprint-based background checks, with the full
consent of the individual to whom a background check is taking place, for noncriminal justice
functions, shall be eligible for access to CJI. Access shall be permitted when such designation is
authorized pursuant to federal law or state statute approved by the U.S. Attorney General. A NCJA
(public) receiving access to CJI shall enter into a signed written agreement with the appropriate
signatory authority of the CSA/SIB providing the access. An example of a NCJA (public) is a
county school board.
A NCJA (private) designated to request civil fingerprint-based background checks, with the full
consent of the individual to whom a background check is taking place, for noncriminal justice
functions, shall be eligible for access to CJI. Access shall be permitted when such designation is
authorized pursuant to federal law or state statute approved by the U.S. Attorney General. A NCJA
(private) receiving access to CJI shall enter into a signed written agreement with the appropriate
signatory authority of the CSA, SIB, or authorized agency providing the access. An example of a
NCJA (private) is a local bank.
All NCJAs accessing CJI shall be subject to all pertinent areas of the CJIS Security Policy (see
Appendix J for supplemental guidance). Each NCJA that directly accesses FBI CJI shall also
allow the FBI to periodically test the ability to penetrate the FBI’s network through the external
network connection or system per authorization of Department of Justice (DOJ) Order 0904.
5.1.1.7 Outsourcing Standards for Channelers

Channelers designated to request civil fingerprint-based background checks or noncriminal justice
ancillary functions on behalf of a NCJA (public) or NCJA (private) for noncriminal justice
functions shall be eligible for access to CJI. Access shall be permitted when such designation is
authorized pursuant to federal law or state statute approved by the U.S. Attorney General. All
Channelers accessing CJI shall be subject to the terms and conditions described in the Compact
Council Security and Management Control Outsourcing Standard. Each Channeler that directly
accesses CJI shall also allow the FBI to conduct periodic penetration testing.
Channelers leveraging CJI to perform civil functions on behalf of an Authorized Recipient shall
meet the same training and certification criteria required by governmental agencies performing a
similar function, and shall be subject to the same extent of audit review as are local user agencies.
5.1.1.8 Outsourcing Standards for Non-Channelers

Contractors designated to perform noncriminal justice ancillary functions on behalf of a NCJA
(public) or NCJA (private) for noncriminal justice functions shall be eligible for access to CJI.
Access shall be permitted when such designation is authorized pursuant to federal law or state
statute approved by the U.S. Attorney General. All contractors accessing CJI shall be subject to
the terms and conditions described in the Compact Council Outsourcing Standard for NonChannelers. Contractors leveraging CJI to perform civil functions on behalf of an Authorized
Recipient shall meet the same training and certification criteria required by governmental agencies
performing a similar function, and shall be subject to the same extent of audit review as are local
user agencies.
5.1.2 Monitoring, Review, and Delivery of Services
As specified in the interagency agreements, MCAs, and contractual agreements with private
contractors, the services, reports and records provided by the service provider shall be regularly
monitored and reviewed. The CJA, authorized agency, or FBI shall maintain sufficient overall
control and visibility into all security aspects to include, but not limited to, identification of
vulnerabilities and information security incident reporting/response.
The incident
reporting/response process used by the service provider shall conform to the incident
reporting/response specifications provided in this Policy.
5.1.2.1 Managing Changes to Service Providers

Any changes to services provided by a service provider shall be managed by the CJA, authorized
agency, or FBI. This includes provision of services, changes to existing services, and new services.
Evaluation of the risks to the agency shall be undertaken based on the criticality of the data, system,
and the impact of the change.
5.1.3 Secondary Dissemination
If CHRI is released to another authorized agency, and that agency was not part of the releasing
agency’s primary information exchange agreement(s), the releasing agency shall log such
dissemination.
5.1.4 Secondary Dissemination of Non-CHRI CJI
If CJI does not contain CHRI and is not part of an information exchange agreement then it does
not need to be logged. Dissemination shall conform to the local policy validating the requestor of
the CJI as an employee and/or contractor of a law enforcement agency or civil agency requiring
the CJI to perform their mission or a member of the public receiving CJI via authorized
dissemination.

5.1.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 3 – Information Exchange Agreements Implemented by a Local Police Department
A local police department executed a Memorandum of Understanding (MOU) for the interface
with their state CSA. The local police department also executed an MOU (which included an
MCA) with the county information technology (IT) department for the day-to-day operations of
their criminal-justice infrastructure. The county IT department, in turn, outsourced operations
to a local vendor who signed the CJIS Security Addendum.

5.2 Policy Area 2: Security Awareness Training
Basic security awareness training shall be required within six months of initial assignment, and
biennially thereafter, for all personnel who have access to CJI to include all personnel who have
unescorted access to a physically secure location. The CSO/SIB Chief may accept the
documentation of the completion of security awareness training from another agency. Accepting
such documentation from another agency means that the accepting agency assumes the risk that
the training may not meet a particular requirement or process required by federal, state, or local
laws.
5.2.1 Awareness Topics
A significant number of topics can be mentioned and briefly discussed in any awareness session
or campaign. To help further the development and implementation of individual agency security
awareness training programs the following baseline guidance is provided.
5.2.1.1 Level One Security Awareness Training

At a minimum, the following topics shall be addressed as baseline security awareness training for
all personnel who have unescorted access to a physically secure location:
1. Individual responsibilities and expected behavior with regard to being in the vicinity of CJI
usage and/or terminals.
2. Implications of noncompliance.
3. Incident response (Identify points of contact and individual actions).
4. Visitor control and physical access to spaces—discuss applicable physical security policy
and procedures, e.g., challenge strangers, report unusual activity, etc.
5.2.1.2 Level Two Security Awareness Training

In addition to 5.2.1.1 above, the following topics, at a minimum, shall be addressed as baseline
security awareness training for all authorized personnel with access to CJI:
1. Media protection.
2. Protect information subject to confidentiality concerns — hardcopy through destruction.
3. Proper handling and marking of CJI.
4. Threats, vulnerabilities, and risks associated with handling of CJI.
5. Social engineering.
6. Dissemination and destruction.
5.2.1.3 Level Three Security Awareness Training

In addition to 5.2.1.1 and 5.2.1.2 above, the following topics, at a minimum, shall be addressed as
baseline security awareness training for all authorized personnel with both physical and logical
access to CJI:
1. Rules that describe responsibilities and expected behavior with regard to information
system usage.
2. Password usage and management—including creation, frequency of changes, and
protection.
3. Protection from viruses, worms, Trojan horses, and other malicious code.
4. Unknown e-mail/attachments.
5. Web usage—allowed versus prohibited; monitoring of user activity.
6. Spam.
7. Physical Security—increases in risks to systems and data.
8. Handheld device security issues—address both physical and wireless security issues.
9. Use of encryption and the transmission of sensitive/confidential information over the
Internet—address agency policy, procedures, and technical contact for assistance.
10. Laptop security—address both physical and information security issues.
11. Personally owned equipment and software—state whether allowed or not (e.g.,
copyrights).
12. Access control issues—address least privilege and separation of duties.
13. Individual accountability—explain what this means in the agency.
14. Use of acknowledgement statements—passwords, access to systems and data, personal use
and gain.
15. Desktop security—discuss use of screensavers, restricting visitors’ view of information on
screen (mitigating “shoulder surfing”), battery backup devices, allowed access to systems.
16. Protect information subject to confidentiality concerns—in systems, archived, on backup
media, and until destroyed.
17. Threats, vulnerabilities, and risks associated with accessing CJIS Service systems and
services.
5.2.1.4 Level Four Security Awareness Training

In addition to 5.2.1.1, 5.2.1.2, and 5.1.2.3 above, the following topics at a minimum shall be
addressed as baseline security awareness training for all Information Technology personnel
(system administrators, security administrators, network administrators, etc.):
1. Protection from viruses, worms, Trojan horses, and other malicious code—scanning,
updating definitions.
2. Data backup and storage—centralized or decentralized approach.
3. Timely application of system patches—part of configuration management.
4. Access control measures.
5. Network infrastructure protection measures.

5.2.2 Security Training Records
Records of individual basic security awareness training and specific information system security
training shall be documented, kept current, and maintained by the CSO/SIB Chief/Compact
Officer. Maintenance of training records can be delegated to the local level.
5.2.3 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 4 – Security Awareness Training Use Cases
Use Case 1 - Security Awareness Training Program Implementation by a Local Police Department

A local police department with a staff of 20 sworn criminal justice professionals and 15 support
personnel worked with a vendor to develop role-specific security-awareness training, and
required all staff to complete this training upon assignment and every two years thereafter. The
local police department scheduled the sworn law-enforcement training to coincide with their
NCIC certification training. The vendor maintained the training records for the police
department’s entire staff, and provided reporting to the department to help it ensure compliance
with the CJIS Security Policy.
Use Case 2 - Level One Security Awareness Training
A local police department hires custodial staff that will have physical access throughout the PD (a
physically secure location) after normal business hours to clean the facility. These personnel have
unescorted access to a physically secure location and therefore must be given the baseline security
awareness training on all the topics identified in CSP Section 5.2.1.1 Level One Security
Awareness Training.
Use Case 3 – Level Two Security Awareness Training
A school district maintains a locked file cabinet with hard copies of background check results of all
teachers and employees which may include CJI (CHRI). Only authorized personnel who have the
ability to open the cabinet are required to be given the baseline security awareness training on all
the topics identified in CSP Sections 5.2.1.1 and 5.2.1.2.
Use Case 4 – Level Three Security Awareness Training
A County Sheriff’s Office has employed a number of dispatchers. Part of the function of these
dispatchers is to run CJI queries at the request of the Sheriff and deputies. As part of their daily
duties, the dispatchers have access to CJI both logically (running queries) and physically (printed
copies of reports containing CJI). These dispatchers are entrusted with direct access to CJI and are
therefore required to be given the baseline security awareness training on all the topics identified
in CSP Sections 5.2.1.1, 5.2.1.2, and 5.2.1.3.
Use Case 5 – Level Four Security Awareness Training
The State Police has hired a number of system and network administrator personnel to help bolster
security of the state network. Part of their daily duties may include creating accounts for new
personnel, implementing security patches for existing systems, creating backups of existing systems,
and implementing access controls throughout the network. These administrators have privileged
access to CJI and CJI-processing systems, and are therefore required to be given the baseline security
awareness training on all the topics identified in CSP Sections 5.2.1.1, 5.2.1.2, 5.2.1.3, and 5.2.1.4.

5.3 Policy Area 3: Incident Response
The security risk of both accidental and malicious attacks against government and private agencies,
remains persistent in both physical and logical environments. To ensure protection of CJI, agencies
shall: (i) establish operational incident handling procedures that include adequate preparation,
detection, analysis, containment, recovery, and user response activities; (ii) track, document, and
report incidents to appropriate agency officials and/or authorities.
ISOs have been identified as the POC on security-related issues for their respective agencies and
shall ensure LASOs institute the CSA incident response reporting procedures at the local level.
Appendix F contains a sample incident notification letter for use when communicating the details
of a CJI-related incident to the FBI CJIS ISO.
Refer to Section 5.13.5 for additional incident response requirements related to mobile devices
used to access CJI.
5.3.1 Reporting Security Events
The agency shall promptly report incident information to appropriate authorities. Security events,
including identified weaknesses associated with the event, shall be communicated in a manner
allowing timely corrective action to be taken. Formal event reporting and escalation procedures
shall be in place. Wherever feasible, the agency shall employ automated mechanisms to assist in
the reporting of security incidents. All employees, contractors and third party users shall be made
aware of the procedures for reporting the different types of event and weakness that might have an
impact on the security of agency assets and are required to report any security events and
weaknesses as quickly as possible to the designated point of contact.
5.3.1.1 Reporting Structure and Responsibilities
5.3.1.1.1 FBI CJIS Division Responsibilities

The FBI CJIS Division shall:
1. Manage and maintain the CJIS Division's Computer Security Incident Response Capability
(CSIRC).
2. Serve as a central clearinghouse for all reported intrusion incidents, security alerts,
bulletins, and other security-related material.
3. Ensure additional resources for all incidents affecting FBI CJIS Division controlled
systems as needed.
4. Disseminate prompt advisories of system threats and operating system vulnerabilities via
the security policy resource center on FBI.gov, to include but not limited to: Product
Security Bulletins, Virus Bulletins, and Security Clips.
5. Track all reported incidents and/or trends.
6. Monitor the resolution of all incidents.
5.3.1.1.2 CSA ISO Responsibilities

The CSA ISO shall:

1. Assign individuals in each state, federal, and international law enforcement organization
to be the primary point of contact for interfacing with the FBI CJIS Division concerning
incident handling and response.
2. Identify individuals who are responsible for reporting incidents within their area of
responsibility.
3. Collect incident information from those individuals for coordination and sharing among
other organizations that may or may not be affected by the incident.
4. Develop, implement, and maintain internal incident response procedures and coordinate
those procedures with other organizations that may or may not be affected.
5. Collect and disseminate all incident-related information received from the Department of
Justice (DOJ), FBI CJIS Division, and other entities to the appropriate local law
enforcement POCs within their area.
6. Act as a single POC for their jurisdictional area for requesting incident response assistance.
5.3.2 Management of Security Incidents
A consistent and effective approach shall be applied to the management of security incidents.
Responsibilities and procedures shall be in place to handle security events and weaknesses
effectively once they have been reported.
5.3.2.1 Incident Handling

The agency shall implement an incident handling capability for security incidents that includes
preparation, detection and analysis, containment, eradication, and recovery. Wherever feasible,
the agency shall employ automated mechanisms to support the incident handling process.
Incident-related information can be obtained from a variety of sources including, but not limited
to, audit monitoring, network monitoring, physical access monitoring, and user/administrator
reports. The agency should incorporate the lessons learned from ongoing incident handling
activities into the incident response procedures and implement the procedures accordingly.
5.3.2.2 Collection of Evidence

Where a follow-up action against a person or agency after an information security incident involves
legal action (either civil or criminal), evidence shall be collected, retained, and presented to
conform to the rules for evidence laid down in the relevant jurisdiction(s).
5.3.3 Incident Response Training
The agency shall ensure general incident response roles responsibilities are included as part of
required security awareness training.
5.3.4 Incident Monitoring
The agency shall track and document security incidents on an ongoing basis. The CSA ISO shall
maintain completed security incident reporting forms until the subsequent FBI triennial audit or
until legal action (if warranted) is complete; whichever time-frame is greater.

5.3.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 5 – Incident Response Process Initiated by an Incident in a Local Police Department
A state ISO received a notification from a local police department that suspicious network
activity from a known botnet was detected on their network. The state ISO began the process
of collecting all pertinent information about this incident, e.g. incident date/time, points-ofcontact, systems affected, nature of the incident, actions taken, etc. and requested that the local
police department confirm that their malware signatures were up to date. The state ISO
contacted both the FBI CJIS ISO and state CSO to relay the preliminary details of this incident.
The FBI CJIS ISO instructed the involved parties to continue their investigation and to submit
an incident response form once all the information had been gathered. The FBI CJIS ISO
contacted the lead for the FBI CSIRC to inform them that an incident response form was
forthcoming. The state ISO gathered the remainder of the information from the local police
department and submitted a completed incident response form to the FBI CJIS ISO who
subsequently provided it to the FBI CSIRC. The FBI CSIRC notified the Department of Justice
Computer Incident Response Team (DOJCIRT). The state ISO continued to monitor the
situation, passing relevant details to the FBI CJIS ISO, ultimately determining that the botnet
was eliminated from the local police department’s infrastructure. Subsequent investigations
determined that the botnet was restricted to the department’s administrative infrastructure and
thus no CJI was compromised.

5.4 Policy Area 4: Auditing and Accountability
Agencies shall implement audit and accountability controls to increase the probability of
authorized users conforming to a prescribed pattern of behavior. Agencies shall carefully assess
the inventory of components that compose their information systems to determine which security
controls are applicable to the various components.
Auditing controls are typically applied to the components of an information system that provide
auditing capability (servers, etc.) and would not necessarily be applied to every user-level
workstation within the agency. As technology advances, more powerful and diverse functionality
can be found in such devices as personal digital assistants and cellular telephones, which may
require the application of security controls in accordance with an agency assessment of risk.
Refer to Section 5.13.6 for additional audit requirements related to mobile devices used to access
CJI.
5.4.1 Auditable Events and Content (Information Systems)
The agency’s information system shall generate audit records for defined events. These defined
events include identifying significant events which need to be audited as relevant to the security
of the information system. The agency shall specify which information system components carry
out auditing activities. Auditing activity can affect information system performance and this issue
must be considered as a separate factor during the acquisition of information systems.
The agency’s information system shall produce, at the application and/or operating system level,
audit records containing sufficient information to establish what events occurred, the sources of
the events, and the outcomes of the events. The agency shall periodically review and update the
list of agency-defined auditable events. In the event an agency does not use an automated system,
manual recording of activities shall still take place.
5.4.1.1 Events

The following events shall be logged:
1. Successful and unsuccessful system log-on attempts.
2. Successful and unsuccessful attempts to use:
a. access permission on a user account, file, directory or other system resource;
b. create permission on a user account, file, directory or other system resource;
c. write permission on a user account, file, directory or other system resource;
d. delete permission on a user account, file, directory or other system resource;
e. change permission on a user account, file, directory or other system resource.
3. Successful and unsuccessful attempts to change account passwords.
4. Successful and unsuccessful actions by privileged accounts.
5. Successful and unsuccessful attempts for users to:
a. access the audit log file;
b. modify the audit log file;
c. destroy the audit log file.
5.4.1.1.1 Content

The following content shall be included with every audited event:
1. Date and time of the event.
2. The component of the information system (e.g., software component, hardware
component) where the event occurred.
3. Type of event.
4. User/subject identity.
5. Outcome (success or failure) of the event.
5.4.2 Response to Audit Processing Failures
The agency’s information system shall provide alerts to appropriate agency officials in the event
of an audit processing failure. Audit processing failures include, for example: software/hardware
errors, failures in the audit capturing mechanisms, and audit storage capacity being reached or
exceeded.
5.4.3 Audit Monitoring, Analysis, and Reporting
The responsible management official shall designate an individual or position to review/analyze
information system audit records for indications of inappropriate or unusual activity, investigate
suspicious activity or suspected violations, to report findings to appropriate officials, and to take
necessary actions. Audit review/analysis shall be conducted at a minimum once a week. The
frequency of review/analysis should be increased when the volume of an agency’s processing
indicates an elevated need for audit review. The agency shall increase the level of audit monitoring
and analysis activity within the information system whenever there is an indication of increased
risk to agency operations, agency assets, or individuals based on law enforcement information,
intelligence information, or other credible sources of information.
5.4.4 Time Stamps
The agency’s information system shall provide time stamps for use in audit record generation. The
time stamps shall include the date and time values generated by the internal system clocks in the
audit records. The agency shall synchronize internal information system clocks on an annual basis.
5.4.5 Protection of Audit Information
The agency’s information system shall protect audit information and audit tools from modification,
deletion and unauthorized access.
5.4.6 Audit Record Retention
The agency shall retain audit records for at least one (1) year. Once the minimum retention time
period has passed, the agency shall continue to retain audit records until it is determined they are
no longer needed for administrative, legal, audit, or other operational purposes. This includes, for
example, retention and availability of audit records relative to Freedom of Information Act (FOIA)
requests, subpoena, and law enforcement actions.
5.4.7 Logging NCIC and III Transactions
A log shall be maintained for a minimum of one (1) year on all NCIC and III transactions. The III
portion of the log shall clearly identify both the operator and the authorized receiving agency. III
logs shall also clearly identify the requester and the secondary recipient. The identification on the
log shall take the form of a unique identifier that shall remain unique to the individual requester
and to the secondary recipient throughout the minimum one year retention period.
5.4.8 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 6 – Local Police Department's Use of Audit Logs
A state CSO contacted a local police department regarding potentially inappropriate use of
CHRI that was retrieved using the local department’s ORI. The state CSO requested all relevant
information from the police department to reconcile state NCIC and III logs against local police
department logs. The police department provided the combination of their CJI processing
application’s logs with relevant operating system and network infrastructure logs to help verify
the identity of the users conducting these queries. The review of these logs substantiated the
CSO’s suspicion.

5.5 Policy Area 5: Access Control
Access control provides the planning and implementation of mechanisms to restrict reading,
writing, processing and transmission of CJIS information and the modification of information
systems, applications, services and communication configurations allowing access to CJIS
information.
Refer to Section 5.13.6 for additional access control requirements related to mobile devices used
to access CJI.
5.5.1 Account Management
The agency shall manage information system accounts, including establishing, activating,
modifying, reviewing, disabling, and removing accounts. The agency shall validate information
system accounts at least annually and shall document the validation process. The validation and
documentation of accounts can be delegated to local agencies.
Account management includes the identification of account types (i.e., individual, group, and
system), establishment of conditions for group membership, and assignment of associated
authorizations. The agency shall identify authorized users of the information system and specify
access rights/privileges. The agency shall grant access to the information system based on:
1. Valid need-to-know/need-to-share that is determined by assigned official duties.
2. Satisfaction of all personnel security criteria.
The agency responsible for account creation shall be notified when:
1. A user’s information system usage or need-to-know or need-to-share changes.
2. A user is terminated or transferred or associated accounts are removed, disabled, or
otherwise secured.
5.5.2 Access Enforcement
The information system shall enforce assigned authorizations for controlling access to the system
and contained information. The information system controls shall restrict access to privileged
functions (deployed in hardware, software, and firmware) and security-relevant information to
explicitly authorized personnel.
Explicitly authorized personnel include, for example, security administrators, system and network
administrators, and other privileged users with access to system control, monitoring, or
administration functions (e.g., system administrators, information system security officers,
maintainers, system programmers).
Access control policies (e.g., identity-based policies, role-based policies, rule-based policies) and
associated access enforcement mechanisms (e.g., access control lists, access control matrices,
cryptography) shall be employed by agencies to control access between users (or processes acting
on behalf of users) and objects (e.g., devices, files, records, processes, programs, domains) in the
information system.

5.5.2.1 Least Privilege

The agency shall approve individual access privileges and shall enforce physical and logical access
restrictions associated with changes to the information system; and generate, retain, and review
records reflecting all such changes. The agency shall enforce the most restrictive set of
rights/privileges or access needed by users for the performance of specified tasks. The agency
shall implement least privilege based on specific duties, operations, or information systems as
necessary to mitigate risk to CJI. This limits access to CJI to only authorized personnel with the
need and the right to know.
Logs of access privilege changes shall be maintained for a minimum of one year or at least equal
to the agency’s record retention policy – whichever is greater.
5.5.2.2 System Access Control

Access control mechanisms to enable access to CJI shall be restricted by object (e.g., data set,
volumes, files, records) including the ability to read, write, or delete the objects. Access controls
shall be in place and operational for all IT systems to:
1. Prevent multiple concurrent active sessions for one user identification, for those
applications accessing CJI, unless the agency grants authority based upon operational
business needs. Agencies shall document the parameters of the operational business needs
for multiple concurrent active sessions.
2. Ensure that only authorized personnel can add, change, or remove component devices, dialup connections, and remove or alter programs.
5.5.2.3 Access Control Criteria

Agencies shall control access to CJI based on one or more of the following:
1. Job assignment or function (i.e., the role) of the user seeking access.
2. Physical location.
3. Logical location.
4. Network addresses (e.g., users from sites within a given agency may be permitted greater
access than those from outside).
5. Time-of-day and day-of-week/month restrictions.
5.5.2.4 Access Control Mechanisms

When setting up access controls, agencies shall use one or more of the following mechanisms:
1. Access Control Lists (ACLs). ACLs are a register of users (including groups, machines,
processes) who have been given permission to use a particular object (system resource)
and the types of access they have been permitted.
2. Resource Restrictions. Access to specific functions is restricted by never allowing users
to request information, functions, or other resources for which they do not have access.
Three major types of resource restrictions are: menus, database views, and network
devices.

3. Encryption. Encrypted information can only be decrypted, and therefore read, by those
possessing the appropriate cryptographic key. While encryption can provide strong access
control, it is accompanied by the need for strong key management. Follow the guidance in
Section 5.10.2 for encryption requirements if encryption of stored information is employed
as an access enforcement mechanism.
4. Application Level. In addition to controlling access at the information system level, access
enforcement mechanisms are employed at the application level to provide increased
information security for the agency.
5.5.3 Unsuccessful Login Attempts
Where technically feasible, the system shall enforce a limit of no more than 5 consecutive invalid
access attempts by a user (attempting to access CJI or systems with access to CJI). The system
shall automatically lock the account/node for a 10 minute time period unless released by an
administrator.
5.5.4 System Use Notification
The information system shall display an approved system use notification message, before granting
access, informing potential users of various usages and monitoring rules. The system use
notification message shall, at a minimum, provide the following information:
1. The user is accessing a restricted information system.
2. System usage may be monitored, recorded, and subject to audit.
3. Unauthorized use of the system is prohibited and may be subject to criminal and/or civil
penalties.
4. Use of the system indicates consent to monitoring and recording.
The system use notification message shall provide appropriate privacy and security notices (based
on associated privacy and security policies or summaries) and remain on the screen until the user
acknowledges the notification and takes explicit actions to log on to the information system.
Privacy and security policies shall be consistent with applicable laws, executive orders, directives,
policies, regulations, standards, and guidance. System use notification messages can be
implemented in the form of warning banners displayed when individuals log in to the information
system. For publicly accessible systems:
(i) the system use information is available and when appropriate, is displayed before
granting access;
(ii) any references to monitoring, recording, or auditing are in keeping with privacy
accommodations for such systems that generally prohibit those activities; and
(iii) the notice given to public users of the information system includes a description of the
authorized uses of the system.
5.5.5 Session Lock
The information system shall prevent further access to the system by initiating a session lock after
a maximum of 30 minutes of inactivity, and the session lock remains in effect until the user
reestablishes access using appropriate identification and authentication procedures. Users shall
directly initiate session lock mechanisms to prevent inadvertent viewing when a device is
unattended. A session lock is not a substitute for logging out of the information system. In the
interest of safety, devices that are: (1) part of a criminal justice conveyance; or (2) used to perform
dispatch functions and located within a physically secure location; or (3) terminals designated
solely for the purpose of receiving alert notifications (i.e. receive only terminals or ROT) used
within physically secure location facilities that remain staffed when in operation, are exempt from
this requirement. Note: an example of a session lock is a screen saver with password.
5.5.6 Remote Access
The agency shall authorize, monitor, and control all methods of remote access to the information
system. Remote access is any temporary access to an agency’s information system by a user (or
an information system) communicating temporarily through an external, non-agency-controlled
network (e.g., the Internet).
The agency shall employ automated mechanisms to facilitate the monitoring and control of remote
access methods. The agency shall control all remote accesses through managed access control
points. The agency may permit remote access for privileged functions only for compelling
operational needs but shall document the technical and administrative process for enabling remote
access for privileged functions in the security plan for the information system.
Virtual escorting of privileged functions is permitted only when all the following conditions are
met:
1.
2.
3.
4.

The session shall be monitored at all times by an authorized escort
The escort shall be familiar with the system/area in which the work is being performed.
The escort shall have the ability to end the session at any time.
The remote administrative personnel connection shall be via an encrypted (FIPS 140-2
certified) path.
5. The remote administrative personnel shall be identified prior to access and authenticated
prior to or during the session. This authentication may be accomplished prior to the
session via an Advanced Authentication (AA) solution or during the session via active
teleconference with the escort throughout the session.
5.5.6.1 Personally Owned Information Systems

A personally owned information system shall not be authorized to access, process, store or transmit
CJI unless the agency has established and documented the specific terms and conditions for
personally owned information system usage. When personally owned mobile devices (i.e. bring
your own device [BYOD]) are authorized, they shall be controlled in accordance with the
requirements in Policy Area 13: Mobile Devices.
This control does not apply to the use of personally owned information systems to access agency’s
information systems and information that are intended for public access (e.g., an agency’s public
website that contains purely public information).

5.5.6.2 Publicly Accessible Computers

Publicly accessible computers shall not be used to access, process, store or transmit CJI. Publicly
accessible computers include but are not limited to: hotel business center computers, convention
center computers, public library computers, public kiosk computers, etc.
5.5.7 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.

Figure 7 – A Local Police Department’s Access Controls
A local police department purchased a new computer-assisted dispatch (CAD) system that
integrated with their state CSA’s CJI interfaces. In doing so, the police department employed
least-privilege practices to ensure that its employees were only given those privileges needed to
perform their jobs, and as such, excluding IT administrators, employees had only nonadministrative privileges on all equipment they used. The police department also used ACLs in
the operating systems to control access to the CAD client’s executables. The CAD system used
internal role-based access controls to ensure only those users that needed access to CJI were
given it. The police department performed annual audits of user accounts on all systems under
their control including remote access mechanisms, operating systems, and the CAD system to
ensure all accounts were in valid states. The police department implemented authenticationfailure account lockouts, system use notification via login banners, and screen-saver passwords
on all equipment that processes CJI.

5.6 Policy Area 6: Identification and Authentication
The agency shall identify information system users and processes acting on behalf of users and
authenticate the identities of those users or processes as a prerequisite to allowing access to agency
information systems or services.
5.6.1 Identification Policy and Procedures
Each person who is authorized to store, process, and/or transmit CJI shall be uniquely identified.
A unique identification shall also be required for all persons who administer and maintain the
system(s) that access CJI or networks leveraged for CJI transit. The unique identification can take
the form of a full name, badge number, serial number, or other unique alphanumeric identifier.
Agencies shall require users to identify themselves uniquely before the user is allowed to perform
any actions on the system. Agencies shall ensure that all user IDs belong to currently authorized
users. Identification data shall be kept current by adding new users and disabling and/or deleting
former users.
5.6.1.1 Use of Originating Agency Identifiers in Transactions and Information
Exchanges

An FBI authorized originating agency identifier (ORI) shall be used in each transaction on CJIS
systems in order to identify the sending agency and to ensure the proper level of access for each
transaction. The original identifier between the requesting agency and the CSA/SIB/Channeler
shall be the ORI, and other agency identifiers, such as user identification or personal identifier, an
access device mnemonic, or the Internet Protocol (IP) address.
Agencies may act as a servicing agency and perform transactions on behalf of authorized agencies
requesting the service. Servicing agencies performing inquiry transactions on behalf of another
agency may do so using the requesting agency’s ORI. Servicing agencies may also use their own
ORI to perform inquiry transactions on behalf of a requesting agency if the means and procedures
are in place to provide an audit trail for the current specified retention period. Because the agency
performing the transaction may not necessarily be the same as the agency requesting the
transaction, the CSA/SIB/Channeler shall ensure that the ORI for each transaction can be traced,
via audit trail, to the specific agency which is requesting the transaction.
Audit trails can be used to identify the requesting agency if there is a reason to inquire into the
details surrounding why an agency ran an inquiry on a subject. Agencies assigned a P (limited
access) ORI shall not use the full access ORI of another agency to conduct an inquiry transaction.
5.6.2 Authentication Policy and Procedures
Authentication refers to mechanisms or processes that verify users are valid once they are uniquely
identified. The CSA/SIB may develop an authentication strategy which centralizes oversight but
decentralizes the establishment and daily administration of the security measures for access to CJI.
Each individual’s identity shall be authenticated at either the local agency, CSA, SIB or Channeler
level. The authentication strategy shall be part of the agency’s audit for policy compliance. The
FBI CJIS Division shall identify and authenticate all individuals who establish direct web-based
interactive sessions with FBI CJIS Services. The FBI CJIS Division shall authenticate the ORI of
all message-based sessions between the FBI CJIS Division and its customer agencies but will not

further authenticate the user nor capture the unique identifier for the originating operator because
this function is performed at the local agency, CSA, SIB or Channeler level.
5.6.2.1 Standard Authenticators

Authenticators are (the something you know, something you are, or something you have) part of
the identification and authentication process. Examples of standard authenticators include
passwords, hard or soft tokens, biometrics, one-time passwords (OTP) and personal identification
numbers (PIN). Users shall not be allowed to use the same password or PIN in the same logon
sequence.
5.6.2.1.1 Password

Agencies shall follow the secure password attributes, below, to authenticate an individual’s unique
ID. Passwords shall:
1. Be a minimum length of eight (8) characters on all systems.
2. Not be a dictionary word or proper name.
3. Not be the same as the Userid.
4. Expire within a maximum of 90 calendar days.
5. Not be identical to the previous ten (10) passwords.
6. Not be transmitted in the clear outside the secure location.
7. Not be displayed when entered.
5.6.2.1.2 Personal Identification Number (PIN)

When agencies implement the use of a PIN as a standard authenticator, the PIN attributes shall
follow the guidance in section 5.6.2.1.1 (password). When agencies utilize a PIN in conjunction
with a certificate or a token (e.g. key fob with rolling numbers) for the purpose of advanced
authentication, agencies shall follow the PIN attributes described below. For example: A user
certificate is installed on a smartphone for the purpose of advanced authentication (AA). As the
user invokes that certificate, a PIN meeting the below attributes shall be used to access the
certificate for the AA process.
a.
b.
c.
d.
e.

Be a minimum of six (6) digits
Have no repeating digits (i.e., 112233)
Have no sequential patterns (i.e., 123456)
Not be the same as the Userid.
Expire within a maximum of 365 calendar days.
a. If a PIN is used to access a soft certificate which is the second factor of
authentication, AND the first factor is a password that complies with the
requirements in Section 5.6.2.1.1, then the 365 day expiration requirement can be
waived by the CSO.

f. Not be identical to the previous three (3) PINs.
g. Not be transmitted in the clear outside the secure location.
h. Not be displayed when entered.
EXCEPTION: When a PIN is used for local device authentication, the only requirement is that it
be a minimum of six (6) digits.
5.6.2.1.3 One-time Passwords (OTP)

One-time passwords are considered a “something you have” token for authentication. Examples
include bingo cards, hard or soft tokens, and out-of-band tokens (i.e. OTP received via a text
message).
When agencies implement the use of an OTP as an authenticator, the OTP shall meet the
requirements described below.
a. Be a minimum of six (6) randomly generated characters
b. Be valid for a single session
c. If not used, expire within a maximum of five (5) minutes after issuance

5.6.2.2 Advanced Authentication

Advanced Authentication (AA) provides for additional security to the typical user identification
and authentication of login ID and password, such as: biometric systems, user-based digital
certificates (e.g. public key infrastructure (PKI)), smart cards, software tokens, hardware tokens,
paper (inert) tokens, out-of-band authenticators (retrieved via a separate communication service
channel – e.g., authenticator is sent on demand via text message, phone call, etc.), or “Risk-based
Authentication” that includes a software token element comprised of a number of factors, such as
network information, user information, positive device identification (i.e. device forensics, user
pattern analysis and user binding), user profiling, and high-risk challenge/response questions.
When user-based certificates are used for authentication purposes, they shall:
1. Be specific to an individual user and not to a particular device.
2. Prohibit multiple users from utilizing the same certificate.
3. Require the user to “activate” that certificate for each use in some manner (e.g.,
passphrase or user-specific PIN).
5.6.2.2.1 Advanced Authentication Policy and Rationale

The requirement to use or not use AA is dependent upon the physical, personnel, and technical
security controls associated with the user location and whether CJI is accessed directly or
indirectly. AA shall not be required for users requesting access to CJI from within the perimeter
of a physically secure location (Section 5.9), when the technical security controls have been met
(Sections 5.5 and 5.10), or when the user has no ability to conduct transactional activities on state
and national repositories, applications, or services (i.e. indirect access). Conversely, if the
technical security controls have not been met, AA shall be required even if the request for CJI
originates from within a physically secure location. Section 5.6.2.2.2 provides agencies with a
decision tree to help guide AA decisions. The CSO will make the final determination of whether
access is considered indirect.
The intent of AA is to meet the standards of two-factor authentication. Two-factor authentication
employs the use of two of the following three factors of authentication: something you know (e.g.
password), something you have (e.g. hard token), something you are (e.g. biometric). The two
authentication factors shall be unique (i.e. password/token or biometric/password but not
password/password or token/token).
EXCEPTION:
AA shall be required when the requested service has built AA into its processes and requires a user
to provide AA before granting access. EXAMPLES:
a. A user, irrespective of his/her location, accesses the LEEP portal. The LEEP
has AA built into its services and requires AA prior to granting access. AA is
required.
b. A user, irrespective of their location, accesses a State’s portal through which
access to CJI is facilitated. The State Portal has AA built into its processes and
requires AA prior to granting access. AA is required.
5.6.2.2.2 Advanced Authentication Decision Tree

The following AA Decision Tree, coupled with figures 9 and 10 below, assists decision makers in
determining whether or not AA is required.
1. Can request’s physical originating location be determined?
If either (a) or (b) below are true the answer to the above question is “yes”. Proceed to
question 2.
a. The IP address is attributed to a physical structure; or
b. The mnemonic is attributed to a specific device assigned to a specific location
that is a physical structure.
If neither (a) or (b) above are true then the answer is “no”. Skip to question number 4.
2. Does request originate from within a physically secure location as described in Section
5.9.1?
If either (a) or (b) below are true the answer to the above question is “yes”. Proceed to
question 3.
a. The IP address is attributed to a physically secure location; or
b. If a mnemonic is used it is attributed to a specific device assigned to a specific
physically secure location.
If neither (a) or (b) above are true then the answer is “no”. Decision tree completed.
AA required.
3. Are all required technical controls implemented at this location or at the controlling
agency?
If either (a) or (b) below are true the answer to the above question is “yes”. Decision
tree completed. AA requirement waived.

a. Appropriate technical controls listed in Sections 5.5 and 5.10 are implemented;
or
b. The controlling agency (i.e. parent agency or agency leveraged as conduit to
CJI) extends its wide area network controls down to the requesting agency and
the extended controls provide assurance equal or greater to the controls listed
in Sections 5.5 and 5.10.
If neither (a) or (b) above are true then the answer is “no”. Decision tree completed.
AA required.
4. Does request originate from an agency-controlled user device?
If either (a) or (b) below are true the answer to the above question is “yes”. Proceed to
question 5.
a. The static IP address or MAC address can be traced to registered device; or
b. Certificates are issued to agency managed devices only and certificate exchange
is allowed only between authentication server and agency issued devices.
If neither (a) or (b) above are true then the answer is “no”. Decision tree completed.
AA required.
5. Is the agency managed user device associated with and located within a criminal justice
conveyance?
If any of the (a), (b), or (c) statements below is true the answer to the above question is
“yes”. Proceed to Figure 9 Step 3.
a. The static IP address or MAC address is associated with a device associated
with a criminal justice conveyance; or
b. The certificate presented is associated with a device associated with a criminal
justice conveyance; or
c. The mnemonic presented is associated with a specific device assigned and that
device is attributed to a criminal justice conveyance.
If none of the (a), (b), or (c) statements above are true then the answer is “no”. Skip to
question number 7.
6. Is the user device an agency-issued and controlled smartphone or tablet?
If both (a) and (b) below are true, the answer to the above question is “yes.” Proceed
to question number 7.
a. The law enforcement agency issued the device to an individual; and
b. The device is subject to administrative management control of the issuing
agency.
If either (a) or (b) above is false, then the answer is “no.” Decision tree completed.
AA required.
7. Does the agency-issued smartphone or tablet have CSO-approved AA compensating
controls implemented?
If (a) and (b) below are true, the answer to the above question is “yes.” Decision tree
completed. AA requirement is waived.
a. An agency cannot meet a requirement due to legitimate technical or business
constraints; and
b. The CSO has given written approval permitting AA compensating controls to
be implemented in lieu of the required AA control measures.
If either (a) or (b) above is false then the answer is “no.” Decision tree completed. AA
required.
5.6.3 Identifier and Authenticator Management
The agency shall establish identifier and authenticator management processes.
5.6.3.1 Identifier Management

In order to manage user identifiers, agencies shall:
1. Uniquely identify each user.
2. Verify the identity of each user.
3. Receive authorization to issue a user identifier from an appropriate agency official.
4. Issue the user identifier to the intended party.
5. Disable the user identifier after a specified period of inactivity.
6. Archive user identifiers.
5.6.3.2 Authenticator Management

In order to manage information system authenticators, agencies shall:
1. Define initial authenticator content.
2. Establish administrative procedures for initial authenticator distribution, for
lost/compromised, or damaged authenticators, and for revoking authenticators.
3. Change default authenticators upon information system installation.
4. Change/refresh authenticators periodically.
Information system authenticators include, for example, tokens, user-based PKI certificates,
biometrics, passwords, and key cards. Users shall take reasonable measures to safeguard
authenticators including maintaining possession of their individual authenticators, not loaning or
sharing authenticators with others, and immediately reporting lost or compromised authenticators.
5.6.4 Assertions
Identity providers can be leveraged to identify individuals and assert the individual’s identity to a
service or to a trusted broker who will in-turn assert the identity to a service. Assertion
mechanisms used to communicate the results of a remote authentication to other parties shall be:
1. Digitally signed by a trusted entity (e.g., the identity provider).

2. Obtained directly from a trusted entity (e.g. trusted broker) using a protocol where the
trusted entity authenticates to the relying party using a secure protocol (e.g. transport
layer security [TLS]) that cryptographically authenticates the verifier and protects the
assertion.
Assertions generated by a verifier shall expire after 12 hours and shall not be accepted thereafter
by the relying party.
5.6.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 8 – Advanced Authentication Use Cases
Use Case 1 - A Local Police Department Authentication Control Scenario
During the course of an investigation, a detective attempts to access Criminal Justice
Information (CJI) from a hotel room using an agency issued mobile broadband card. To gain
access, the detective first establishes the remote session via a secure virtual private network
(VPN) tunnel (satisfying the requirement for encryption). Upon connecting to the agency
network, the detective is challenged for a username (identification), password (“something
you know”), and a one-time password OTP (“something you have”) from a hardware token
to satisfy the requirement for advanced authentication. Once the detective’s credentials are
validated, his identity is asserted by the infrastructure to all authorized applications needed to
complete his queries.
Use Case 2 – Use of a Smart Card
A user is issued a smart card that is loaded with user-specific digital certificates from a
terminal within a controlled area. The user selects an application that will provide access to
Criminal Justice Information (CJI) then enters the proper username (identification) and
password (“something you know”). Once prompted, the user connects the smart card
(“something you have”) to the terminal. The user is prompted to enter a personal
identification number (PIN) to unlock the smart card. Once unlocked, the smart card sends
the certificates to the authentication management server at the local agency where the
combined username, password, and digital user certificates are validated. The user has
satisfied the requirement for AA and is granted access to CJI.
Use Case 3 – Out of Band One-Time-Password (OTP) – Mobile phone-based
Using an agency- issued laptop, a user connects to the agency network via an agency-issued
mobile broadband card and an encrypted virtual private network (VPN) tunnel. As part of an
on-going investigation, the user initiates an application that will permit access to Criminal
Justice Information (CJI). The user is prompted to enter a username (identification) and a
password (“something you know”). Once that has been completed, a text message containing
a one-time password (OTP) is sent via text message (out of band) to the user’s agency-issued
cell phone. The user is challenged via the CJI application for that OTP. The user enters the
OTP (“something you have”) then the username, password, and OTP are validated. The user
has satisfied the requirement for AA and is granted access to CJI.
Use Case 4 – Improper Use of a One-Time-Password (OTP) – Laptop
Using an agency- issued laptop, a user connects to the agency network via an agency-issued
mobile broadband card and an encrypted virtual private network (VPN) tunnel. As part of an
on-going investigation, the user initiates an application that will permit access to Criminal
Justice Information (CJI). The user is prompted to enter a username (identification) and a
password (“something you know”). Once that has been completed, a one-time password
(OTP) is sent to the user’s agency-issued laptop (in band) via pop-up message. The user is
challenged via the CJI application for that OTP; however, the delivery of the OTP to the
device that is being used to access CJI (in band) defeats the purpose of the second factor. This
method does not satisfy the requirement for AA, and therefore the user should not be granted
access to CJI. See the below explanation:
This method of receiving the necessary OTP (in band) does not guarantee the authenticity of
the user’s identity because anyone launching the CJI application and entering a valid
username/password combination is presented the OTP via a pop-up which is intend to be the
second factor of authentication. This method makes the application accessible to anyone with
knowledge of the valid username and password. Potentially, this is no more secure than using
only a single factor of authentication.
Use Case 5 – Risk-based Authentication (RBA) Implementation
A user has moved office locations and requires email access (containing Criminal Justice
Information) via an Outlook Web Access (OWA) client utilizes a risk-based authentication
(RBA) solution. The user launches the OWA client and is prompted to enter a username
(identification) and a password (“something you know”). The RBA detects this computer has
not previously been used by the user, is not listed under the user’s profile, and then presents
high-risk challenge/response question(s) which the user is prompted to answer. Once the
questions have been verified as correct, the user is authenticated and granted access to the
email. Meanwhile, the RBA logs and collects a number of device forensic information and
captures the user pattern analysis to update the user’s profile. The CJIS Security Policy
requirements for RBA have been satisfied.
Use Case 6 – Improper Risk-based Authentication (RBA) Implementation
A user has moved office locations and requires access to email containing Criminal Justice
Information (CJI) via an Outlook Web Access (OWA) client utilizing a risk-based
authentication (RBA) solution. The user launches the OWA client and is prompted to enter
a username (identification) and a password (“something you know”). The RBA detects this
computer has not previously been used by the user and is not listed under the user’s profile.
The user is prompted to answer high-risk challenge/response questions for verification and
authorization to access to the email; however, if the second authentication factor is to answer
additional questions presented every time the user logs on, then this solution is referred to as
a knowledge-based authentic on (KBA) solution. A KBA solution does not satisfy the
requirement for AA, and therefore the user should not be granted access to CJI.
See the below explanation:
A KBA solution is not a viable advanced authentication (AA) solution per the CJIS Security
Policy (CSP). The KBA asks questions and compares the answers to those stored within the
user’s profile. A KBA is neither a CSP compliant two factor authentication solution, nor does
it meet the CSP criteria of a risk-based authentication (RBA) solution which logs and collects
a number of device forensic information and captures the user pattern analysis to update the
user’s profile. Using this collected data, the RBA presents challenge/response questions when
changes to the user’s profile are noted versus every time the user logs in.
Use Case 7 – Advanced Authentication Compensating Controls on Agency-Issued
Smartphones
An authorized user is issued a smartphone that is administratively managed by the agencyinstalled mobile device management (MDM) solution to ensure device compliance with the
CJIS Security Policy. The user initiates an email client on the smartphone that contains emails
with CJI. The email client challenges the user to enter a username (identification) and a
password (one factor: something you know) which are forwarded to the local agency for
authentication. The smartphone lacks the technical capability to challenge the user for a
second factor of authentication. This email client is used across the state agency so access is
a necessity for the user’s job functions.
An audit by the CSA identifies the agency’s use of the agency smartphone as not compliant
with AA requirements due to the authorized user authenticating with only one factor instead
of the required two factors.
Subsequently, the agency performs a risk assessment of their smartphone authentication
solution and document a legitimate technical constraint due to the lack of technical solutions
for smartphone-based two-factor authentication. The risk assessment identifies the following
compensating controls that, when combined with the authorized user authenticating to the
local agency with their password, meet the intent of the AA requirement by providing a
similar level of security:
1. Enhance smartphone policy to enable possession of the smartphone to be considered a
factor of authentication (i.e. something you have). Require authorized users to treat the
smartphone as a controlled device and protect it as they would a personal credit card or an
issued firearm to ensure only they will be in possession of the device
2. Move the email client used to authenticate with the local agency inside an encrypted,
password-protected secure container on the smartphone ensuring only the authorized user can
access the email application to authenticate.
The agency submits an AA compensating controls request to the CSO outlining the technical
constraint identified by the risk assessment, what compensating controls will be employed,
and the desired duration of the compensating controls.

The CSO approves the agency’s request and provides documentation of the approval to the
agency to maintain for audit purposes. The agency enacts the compensating controls and
informs agency personnel they are permitted to access CJI via the agency-issued smartphone.

Figure 9 – Authentication Decision for Known Location
Incoming CJI
Access Request

#1
Can request’s physical
originating location be
determined?

No

See Figure 10

Yes

#2
Does request originate from
within a physically secure
location?

No

Yes

#3
Are all required technical
controls implemented at this
location or at controlling
agency?

Advanced Authentication
Required

No

Yes

Advanced Authentication
Not Required

Figure 10 – Authentication Decision for Unknown Location
Incoming CJI
Access Request

#1
Can request’s physical
originating location be
determined?

Yes

See Figure 9

No

#4
Does request originate
from an agency-controlled
user device?

No or Unknown

Yes

#5
Is the agency managed
user device associated with
and located within a
Criminal Justice
Conveyance?

No

#6
Is the user device an
agency-issued and
controlled smartphone or
tablet?

No

Advanced Authentication
Required

Yes

Yes

#7
Does the agency-issued
smartphone or tablet have
CSO-approved compensating
controls implemented?

No

Go To Figure 9
Step #3
Yes

Advanced Authentication
Not Required

Figure 10
5.7 Policy Area 7: Configuration Management
5.7.1 Access Restrictions for Changes
Planned or unplanned changes to the hardware, software, and/or firmware components of the
information system can have significant effects on the overall security of the system. The goal is
to allow only qualified and authorized individuals access to information system components for
purposes of initiating changes, including upgrades, and modifications. Section 5.5, Access
Control, describes agency requirements for control of privileges and restrictions.
5.7.1.1 Least Functionality

The agency shall configure the application, service, or information system to provide only essential
capabilities and shall specifically prohibit and/or restrict the use of specified functions, ports,
protocols, and/or services.
5.7.1.2 Network Diagram

The agency shall ensure that a complete topological drawing depicting the interconnectivity of the
agency network, to criminal justice information, systems and services is maintained in a current
status. See Appendix C for sample network diagrams.
The network topological drawing shall include the following:
1. All communications paths, circuits, and other components used for the interconnection,
beginning with the agency-owned system(s) and traversing through all interconnected
systems to the agency end-point.
2. The logical location of all components (e.g., firewalls, routers, switches, hubs, servers,
encryption devices, and computer workstations). Individual workstations (clients) do not
have to be shown; the number of clients is sufficient.
3. “For Official Use Only” (FOUO) markings.
4. The agency name and date (day, month, and year) drawing was created or updated.
5.7.2 Security of Configuration Documentation
The system configuration documentation often contains sensitive details (e.g. descriptions of
applications, processes, procedures, data structures, authorization processes, data flow, etc.)
Agencies shall protect the system documentation from unauthorized access consistent with the
provisions described in Section 5.5 Access Control.
5.7.3 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.

Figure 11 – A Local Police Department’s Configuration Management Controls
A local police department decided to update their CAD system, and in doing so tracked all
changes made to their infrastructure in a configuration management journal, updated their
network topology documents to include all new components in their architecture, then marked
all documentation as FOUO and stored them securely.

5.8

Policy Area 8: Media Protection

Media protection policy and procedures shall be documented and implemented to ensure that
access to digital and physical media in all forms is restricted to authorized individuals. Procedures
shall be defined for securely handling, transporting and storing media.
5.8.1 Media Storage and Access
The agency shall securely store digital and physical media within physically secure locations or
controlled areas. The agency shall restrict access to digital and physical media to authorized
individuals. If physical and personnel restrictions are not feasible then the data shall be encrypted
per Section 5.10.1.2.
5.8.2 Media Transport
The agency shall protect and control digital and physical media during transport outside of
controlled areas and restrict the activities associated with transport of such media to authorized
personnel.
5.8.2.1 Digital Media during Transport

Controls shall be in place to protect digital media containing CJI while in transport (physically
moved from one location to another) to help prevent compromise of the data. Encryption, as
defined in Section 5.10.1.2 of this Policy, is the optimal control during transport; however, if
encryption of the data isn’t possible then each agency shall institute physical controls to ensure the
security of the data.
5.8.2.2 Physical Media in Transit

The controls and security measures in this document also apply to CJI in physical (printed
documents, printed imagery, etc.) form. Physical media shall be protected at the same level as the
information would be protected in electronic form.
5.8.3 Digital Media Sanitization and Disposal
The agency shall sanitize, that is, overwrite at least three times or degauss digital media prior to
disposal or release for reuse by unauthorized individuals. Inoperable digital media shall be
destroyed (cut up, shredded, etc.). The agency shall maintain written documentation of the steps
taken to sanitize or destroy electronic media. Agencies shall ensure the sanitization or destruction
is witnessed or carried out by authorized personnel.
5.8.4 Disposal of Physical Media
Physical media shall be securely disposed of when no longer required, using formal procedures.
Formal procedures for the secure disposal or destruction of physical media shall minimize the risk
of sensitive information compromise by unauthorized individuals. Physical media shall be
destroyed by shredding or incineration. Agencies shall ensure the disposal or destruction is
witnessed or carried out by authorized personnel.

5.8.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 12 – A Local Police Department’s Media Management Policies
A local police department implemented a replacement CAD system that integrated to their
state’s CSA and was authorized to process CJI. The police department contracted with an offsite media manager to store backups of their data in the contractor’s vaults, but the contractor
was not authorized to process or store CJI. To ensure the confidentially of the police
department’s data while outside its perimeter, they encrypted all data going to the contractor
with an encryption product that is FIPS 140-2 certified. The police department rotated and
reused media through the contractor’s vaults periodically, and when it required destruction, the
police department incinerated the media to irreversibly destroy any data on it.

5.9 Policy Area 9: Physical Protection
Physical protection policy and procedures shall be documented and implemented to ensure CJI
and information system hardware, software, and media are physically protected through access
control measures.
5.9.1 Physically Secure Location
A physically secure location is a facility, a criminal justice conveyance, or an area, a room, or a
group of rooms within a facility with both the physical and personnel security controls sufficient
to protect CJI and associated information systems. The physically secure location is subject to
criminal justice agency management control; SIB control; FBI CJIS Security addendum; or a
combination thereof.
Sections 5.9.1.1 – 5.9.1.8 describe the physical controls required in order to be considered a
physically secure location, while Sections 5.2 and 5.12, respectively, describe the minimum
security awareness training and personnel security controls required for unescorted access to a
physically secure location. Sections 5.5, 5.6.2.2.1, and 5.10 describe the requirements for technical
security controls required to access CJI from within the perimeter of a physically secure location
without AA.
5.9.1.1 Security Perimeter

The perimeter of a physically secure location shall be prominently posted and separated from nonsecure locations by physical controls. Security perimeters shall be defined, controlled and secured
in a manner acceptable to the CSA or SIB.
5.9.1.2 Physical Access Authorizations

The agency shall develop and keep current a list of personnel with authorized access to the
physically secure location (except for those areas within the permanent facility officially
designated as publicly accessible) or shall issue credentials to authorized personnel.
5.9.1.3 Physical Access Control

The agency shall control all physical access points (except for those areas within the facility
officially designated as publicly accessible) and shall verify individual access authorizations
before granting access.
5.9.1.4 Access Control for Transmission Medium

The agency shall control physical access to information system distribution and transmission lines
within the physically secure location.
5.9.1.5 Access Control for Display Medium

The agency shall control physical access to information system devices that display CJI and shall
position information system devices in such a way as to prevent unauthorized individuals from
accessing and viewing CJI.

5.9.1.6 Monitoring Physical Access

The agency shall monitor physical access to the information system to detect and respond to
physical security incidents.
5.9.1.7 Visitor Control

The agency shall control physical access by authenticating visitors before authorizing escorted
access to the physically secure location (except for those areas designated as publicly accessible).
The agency shall escort visitors at all times and monitor visitor activity.
5.9.1.8 Delivery and Removal

The agency shall authorize and control information system-related items entering and exiting the
physically secure location.
5.9.2 Controlled Area
If an agency cannot meet all of the controls required for establishing a physically secure location,
but has an operational need to access or store CJI, the agency shall designate an area, a room, or a
storage container, as a controlled area for the purpose of day-to-day CJI access or storage. The
agency shall, at a minimum:
1. Limit access to the controlled area during CJI processing times to only those personnel
authorized by the agency to access or view CJI.
2. Lock the area, room, or storage container when unattended.
3. Position information system devices and documents containing CJI in such a way as to
prevent unauthorized individuals from access and view.
4. Follow the encryption requirements found in Section 5.10.1.2 for electronic storage (i.e.
data “at rest”) of CJI.
5.9.3 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 13 – A Local Police Department's Physical Protection Measures
A local police department implemented a replacement CAD system that was authorized to
process CJI over an encrypted VPN tunnel to the state’s CSA. The police department established
a physically separated wing within their precinct separated by locked doors, walls, and a
monitored security system within which CJI was processed by criminal justice professionals.
Only those persons with the appropriate authorizations were permitted within this wing unless
accompanied by such a person. Within this secure wing the police department further segregated
the back-office information systems’ infrastructure within a separately controlled area restricted
only to those authorized administrative personnel with a need to enter.

5.10 Policy Area 10: System and Communications Protection and
Information Integrity
Examples of systems and communications safeguards range from boundary and transmission
protection to securing an agency’s virtualized environment. In addition, applications, services, or
information systems must have the capability to ensure system integrity through the detection and
protection against unauthorized changes to software and information. This section details the
policy for protecting systems and communications infrastructures.
Refer to Section 5.13.4 for additional system integrity requirements related to mobile devices used
to access CJI.
5.10.1 Information Flow Enforcement
The network infrastructure shall control the flow of information between interconnected systems.
Information flow control regulates where information is allowed to travel within an information
system and between information systems (as opposed to who is allowed to access the information)
and without explicit regard to subsequent accesses to that information. In other words, controlling
how data moves from one place to the next in a secure manner. Examples of controls that are
better expressed as flow control than access control (see Section 5.5) are:
1. Prevent CJI from being transmitted unencrypted across the public network.
2. Block outside traffic that claims to be from within the agency.
3. Do not pass any web requests to the public network that are not from the internal web
proxy.
Specific examples of flow control enforcement can be found in boundary protection devices (e.g.
proxies, gateways, guards, encrypted tunnels, firewalls, and routers) that employ rule sets or
establish configuration settings that restrict information system services or provide a packet
filtering capability.
5.10.1.1 Boundary Protection

The agency shall:
1. Control access to networks processing CJI.
2. Monitor and control communications at the external boundary of the information system
and at key internal boundaries within the system.
3. Ensure any connections to the Internet, other external networks, or information systems
occur through controlled interfaces (e.g. proxies, gateways, routers, firewalls, encrypted
tunnels). See Section 5.13.4.3 for guidance on personal firewalls.
4. Employ tools and techniques to monitor network events, detect attacks, and provide
identification of unauthorized use.
5. Ensure the operational failure of the boundary protection mechanisms do not result in any
unauthorized release of information outside of the information system boundary (i.e. the
device “fails closed” vs. “fails open”).

6. Allocate publicly accessible information system components (e.g. public Web servers) to
separate sub networks with separate, network interfaces. Publicly accessible information
systems residing on a virtual host shall follow the guidance in Section 5.10.3.2 to achieve
separation.
5.10.1.2 Encryption

Encryption is a form of cryptology that applies a cryptographic operation to provide confidentiality
of (sensitive) information. Decryption is the reversing of the cryptographic operation to convert
the information back into a plaintext (readable) format. There are two main types of encryption:
symmetric encryption and asymmetric encryption (also known as public key encryption). Hybrid
encryption solutions do exist and use both asymmetric encryption for client/server certificate
exchange – session integrity and symmetric encryption for bulk data encryption – data
confidentiality.
5.10.1.2.1 Encryption for CJI in Transit

When CJI is transmitted outside the boundary of the physically secure location, the data shall be
immediately protected via encryption. When encryption is employed, the cryptographic module
used shall be FIPS 140-2 certified and use a symmetric cipher key strength of at least 128 bit
strength to protect CJI.
NOTE: Subsequent versions of approved cryptographic modules that are under current review for
FIPS 140-2 compliancy can be used in the interim until certification is complete.
EXCEPTIONS:
a) See Sections 5.13.1.2.2 and 5.10.2.
b) Encryption shall not be required if the transmission medium meets all of the
following requirements:
i.

The agency owns, operates, manages, or protects the medium.

ii.

Medium terminates within physically secure locations at both ends with no
interconnections between.

iii.

Physical access to the medium is controlled by the agency using the
requirements in Sections 5.9.1 and 5.12.

iv.

Protection includes safeguards (e.g., acoustic, electric, electromagnetic, and
physical) and if feasible countermeasures (e.g., alarms, notifications) to
permit its use for the transmission of unencrypted information through an
area of lesser classification or control.

v.

With prior approval of the CSO.

Examples:


A campus is completely owned and controlled by a criminal justice agency (CJA)
– If line-of-sight between buildings exists where a cable is buried, encryption is not
required.



A multi-story building is completely owned and controlled by a CJA – If floors are
physically secure or cable runs through non-secure areas are protected, encryption
is not required.



A multi-story building is occupied by a mix of CJAs and non-CJAs – If floors are
physically secure or cable runs through the non-secure areas are protected,
encryption is not required.

5.10.1.2.2 Encryption for CJI at Rest

When CJI is at rest (i.e. stored digitally) outside the boundary of the physically secure location,
the data shall be protected via encryption. When encryption is employed, agencies shall either
encrypt CJI in accordance with the standard in Section 5.10.1.2.1 above, or use a symmetric
cipher that is FIPS 197 certified (AES) and at least 256 bit strength.
a) When agencies implement encryption on CJI at rest, the passphrase used to
unlock the cipher shall meet the following requirements:
i.

Be at least 10 characters

ii.

Not be a dictionary word.

iii.

Include at least one (1) upper case letter, one (1) lower case letter, one
(1) number, and one (1) special character.

iv.

Be changed when previously authorized personnel no longer require
access.

b) Multiple files maintained in the same unencrypted folder shall have separate
and distinct passphrases. A single passphrase may be used to encrypt an entire
folder or disk containing multiple files. All audit requirements found in Section
5.4.1 Auditable Events and Content (Information Systems) shall be applied.
NOTE: Commonly available encryption tools often use a key to unlock the cipher to allow
data access; this key is called a passphrase. While similar to a password, a passphrase is not
used for user authentication. Additionally, the passphrase contains stringent character
requirements making it more secure and thus providing a higher level of confidence that the
passphrase will not be compromised.
5.10.1.2.3 Public Key Infrastructure (PKI) Technology

For agencies using public key infrastructure (PKI) technology, the agency shall develop and
implement a certificate policy and certification practice statement for the issuance of public
key certificates used in the information system. Registration to receive a public key certificate
shall:
a) Include authorization by a supervisor or a responsible official.
b) Be accomplished by a secure process that verifies the identity of the certificate
holder.
c) Ensure the certificate is issued to the intended party.

5.10.1.3 Intrusion Detection Tools and Techniques

The agency shall implement network-based and/or host-based intrusion detection tools.
The CSA/SIB shall, in addition:
1. Monitor inbound and outbound communications for unusual or unauthorized activities.
2. Send individual intrusion detection logs to a central logging facility where correlation and
analysis will be accomplished as a system wide intrusion detection effort.
3. Employ automated tools to support near-real-time analysis of events in support of detecting
system-level attacks.
5.10.1.4 Voice over Internet Protocol

Voice over Internet Protocol (VoIP) has been embraced by organizations globally as an addition
to, or replacement for, public switched telephone network (PSTN) and private branch exchange
(PBX) telephone systems. The immediate benefits are lower costs than traditional telephone
services and VoIP can be installed in-line with an organization’s existing Internet Protocol (IP)
services. Among VoIP’s risks that have to be considered carefully are: myriad security concerns,
cost issues associated with new networking hardware requirements, and overarching quality of
service (QoS) factors.
In addition to the security controls described in this document, the following additional controls
shall be implemented when an agency deploys VoIP within a network that contains unencrypted
CJI:
1. Establish usage restrictions and implementation guidance for VoIP technologies.
2. Change the default administrative password on the IP phones and VoIP switches.
3. Utilize Virtual Local Area Network (VLAN) technology to segment VoIP traffic from data
traffic.
Appendix G.2 outlines threats, vulnerabilities, mitigations, and NIST best practices for VoIP.
5.10.1.5 Cloud Computing

Organizations transitioning to a cloud environment are presented unique opportunities and
challenges (e.g., purported cost savings and increased efficiencies versus a loss of control over the
data). Reviewing the cloud computing white paper (Appendix G.3), the cloud assessment located
within the security policy resource center on FBI.gov, NIST Special Publications (800-144, 800145, and 800-146), as well as the cloud provider’s policies and capabilities will enable
organizations to make informed decisions on whether or not the cloud provider can offer service
that maintains compliance with the requirements of the CJIS Security Policy.
The metadata derived from CJI shall not be used by any cloud service provider for any purposes.
The cloud service provider shall be prohibited from scanning any email or data files for the purpose
of building analytics, data mining, advertising, or improving the services provided.
5.10.2 Facsimile Transmission of CJI
CJI transmitted via a single or multi-function device over a standard telephone line is exempt from
encryption requirements. CJI transmitted external to a physically secure location using a facsimile
server, application or service which implements email-like technology, shall meet the encryption
requirements for CJI in transit as defined in Section 5.10.
5.10.3 Partitioning and Virtualization
As resources grow scarce, agencies are increasing the centralization of applications, services, and
system administration. Advanced software now provides the ability to create virtual machines that
allows agencies to reduce the amount of hardware needed. Although the concepts of partitioning
and virtualization have existed for a while, the need for securing the partitions and virtualized
machines has evolved due to the increasing amount of distributed processing and federated
information sources now available across the Internet.
5.10.3.1 Partitioning

The application, service, or information system shall separate user functionality (including user
interface services) from information system management functionality.
The application, service, or information system shall physically or logically separate user interface
services (e.g. public web pages) from information storage and management services (e.g. database
management). Separation may be accomplished through the use of one or more of the following:
1. Different computers.
2. Different central processing units.
3. Different instances of the operating system.
4. Different network addresses.
5. Other methods approved by the FBI CJIS ISO.
5.10.3.2 Virtualization

Virtualization refers to a methodology of dividing the resources of a computer (hardware and
software) into multiple execution environments. Virtualized environments are authorized for
criminal justice and noncriminal justice activities. In addition to the security controls described in
this Policy, the following additional controls shall be implemented in a virtual environment:
1. Isolate the host from the virtual machine. In other words, virtual machine users cannot
access host files, firmware, etc.
2. Maintain audit logs for all virtual machines and hosts and store the logs outside the hosts’
virtual environment.
3. Virtual Machines that are Internet facing (web servers, portal servers, etc.) shall be
physically separate from Virtual Machines (VMs) that process CJI internally or be
separated by a virtual firewall.
4. Drivers that serve critical functions shall be stored within the specific VM they service. In
other words, do not store these drivers within the hypervisor, or host operating system, for
sharing. Each VM is to be treated as an independent system – secured as independently as
possible.
The following additional technical security controls shall be applied in virtual environments where
CJI is comingled with non-CJI:
1. Encrypt CJI when stored in a virtualized environment where CJI is comingled with nonCJI or segregate and store unencrypted CJI within its own secure VM.
2. Encrypt network traffic within the virtual environment.
The following are additional technical security control best practices and should be implemented
wherever feasible:
1. Implement IDS and/or IPS monitoring within the virtual environment.
2. Virtually or physically firewall each VM within the virtual environment to ensure that only
allowed protocols will transact.
3. Segregate the administrative duties for the host.
Appendix G-1 provides some reference and additional background information on virtualization.
5.10.4 System and Information Integrity Policy and Procedures
5.10.4.1 Patch Management

The agency shall identify applications, services, and information systems containing software or
components affected by recently announced software flaws and potential vulnerabilities resulting
from those flaws.
The agency (or the software developer/vendor in the case of software developed and maintained
by a vendor/contractor) shall develop and implement a local policy that ensures prompt installation
of newly released security relevant patches, service packs and hot fixes. Local policies should
include such items as:
1. Testing of appropriate patches before installation.
2. Rollback capabilities when installing patches, updates, etc.
3. Automatic updates without individual user intervention.
4. Centralized patch management.
Patch requirements discovered during security assessments, continuous monitoring or incident
response activities shall also be addressed expeditiously.
5.10.4.2 Malicious Code Protection

The agency shall implement malicious code protection that includes automatic updates for all
systems with Internet access. Agencies with systems not connected to the Internet shall implement
local procedures to ensure malicious code protection is kept current (i.e. most recent update
available).
The agency shall employ virus protection mechanisms to detect and eradicate malicious code (e.g.,
viruses, worms, Trojan horses) at critical points throughout the network and on all workstations,
servers and mobile computing devices on the network. The agency shall ensure malicious code
protection is enabled on all of the aforementioned critical points and information systems and
resident scanning is employed.

5.10.4.3 Spam and Spyware Protection

The agency shall implement spam and spyware protection.
The agency shall:
1. Employ spam protection mechanisms at critical information system entry points (e.g.
firewalls, electronic mail servers, remote-access servers).
2. Employ spyware protection at workstations, servers and mobile computing devices on the
network.
3. Use the spam and spyware protection mechanisms to detect and take appropriate action on
unsolicited messages and spyware/adware, respectively, transported by electronic mail,
electronic mail attachments, Internet accesses, removable media (e.g. diskettes or compact
disks) or other removable media as defined in this Policy.
5.10.4.4 Security Alerts and Advisories

The agency shall:
1. Receive information system security alerts/advisories on a regular basis.
2. Issue alerts/advisories to appropriate personnel.
3. Document the types of actions to be taken in response to security alerts/advisories.
4. Take appropriate actions in response.
5. Employ automated mechanisms to make security alert and advisory information available
throughout the agency as appropriate.
5.10.4.5 Information Input Restrictions

The agency shall restrict the information input to any connection to FBI CJIS services to authorized
personnel only.
Restrictions on personnel authorized to input information to the information system may extend
beyond the typical access controls employed by the system and include limitations based on
specific operational/project responsibilities.
5.10.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.

Figure 14 – System and Communications Protection and Information Integrity Use Cases
Use Case 1 – A Local Police Department’s Information Systems & Communications Protections
A local police department implemented a replacement CAD system within a physically secure
location that was authorized to process CJI using a FIPS 140-2 encrypted VPN tunnel over the

Internet to the state’s CSA. In addition to the policies, physical and personnel controls already
in place, the police department employed firewalls both at their border and at key points within
their network, intrusion detection systems, a patch-management strategy that included automatic
patch updates where possible, virus scanners, spam and spyware detection mechanisms that
update signatures automatically, and subscribed to various security alert mailing lists and
addressed vulnerabilities raised through the alerts as needed.
Use Case 2 – Faxing from a Single/Multi-function Device over a Traditional Telephone Line
A dispatcher from county A runs a NCIC query on an individual. The results are printed and then
sent to an adjoining county using a single/multi-function device with facsimile capability. For
faxing, the device is only connected to a traditional telephone line as is the device at the receiving
county. Encryption of a document containing CJI is not required because the document travels
over a traditional telephone line.
Use Case 3 – Faxing from a Multi-function Device over a Network
A dispatcher from city A runs a NCIC query on an individual. The results are printed and the
dispatcher uses a multi-function copier to fax the file to a city in another state. The dispatcher
enters the fax number of the receiver and sends the document. The document containing CJI is
automatically converted to a digital file and routed to the receiver over the agency network and
the Internet. Because the device uses a network and the Internet for transmitting documents
containing CJI, encryption in transit using FIPS 140-2 certified 128 bit symmetric encryption is
required.

5.11 Policy Area 11: Formal Audits
Formal audits are conducted to ensure compliance with applicable statutes, regulations and
policies.
5.11.1 Audits by the FBI CJIS Division
5.11.1.1 Triennial Compliance Audits by the FBI CJIS Division

The FBI CJIS Division is authorized to conduct audits, once every three (3) years as a minimum,
to assess agency compliance with applicable statutes, regulations and policies. The CJIS Audit
Unit (CAU) shall conduct a triennial audit of each CSA in order to verify compliance with
applicable statutes, regulations and policies. This audit shall include a sample of CJAs and, in
coordination with the SIB, the NCJAs. Audits may be conducted on a more frequent basis if the
audit reveals that an agency has not complied with applicable statutes, regulations and policies.
The FBI CJIS Division shall also have the authority to conduct unannounced security inspections
and scheduled audits of Contractor facilities.
5.11.1.2 Triennial Security Audits by the FBI CJIS Division

The FBI CJIS Division is authorized to conduct security audits of the CSA and SIB networks and
systems, once every three (3) years as a minimum, to assess agency compliance with the CJIS
Security Policy. This audit shall include a sample of CJAs and NCJAs. Audits may be conducted
on a more frequent basis if the audit reveals that an agency has not complied with the CJIS Security
Policy.
5.11.2 Audits by the CSA
Each CSA shall:
1. At a minimum, triennially audit all CJAs and NCJAs which have direct access to the state
system in order to ensure compliance with applicable statutes, regulations and policies.
2. In coordination with the SIB, establish a process to periodically audit all NCJAs, with
access to CJI, in order to ensure compliance with applicable statutes, regulations and
policies.
3. Have the authority to conduct unannounced security inspections and scheduled audits of
Contractor facilities.
4. Have the authority, on behalf of another CSA, to conduct a CSP compliance audit of
contractor facilities and provide the results to the requesting CSA. If a subsequent CSA
requests an audit of the same contractor facility, the CSA may provide the results of the
previous audit unless otherwise notified by the requesting CSA that a new audit be
performed.
Note: This authority does not apply to the audit requirement outlined in the Security and
Management Control Outsourcing Standard for Non-Channeler and Channelers related to
outsourcing noncriminal justice administrative functions.

5.11.3 Special Security Inquiries and Audits
All agencies having access to CJI shall permit an inspection team to conduct an appropriate inquiry
and audit of any alleged security violations. The inspection team shall be appointed by the APB
and shall include at least one representative of the CJIS Division. All results of the inquiry and
audit shall be reported to the APB with appropriate recommendations.
5.11.4 Compliance Subcommittees
The Criminal Justice Information Services (CJIS) Advisory Policy Board (APB) established the
Compliance Evaluation Subcommittee (CES) to evaluate the results of audits conducted by the
CJIS Audit Unit (CAU). The CES makes specific recommendations to the APB concerning
compliance with applicable policies and regulations. The most current information regarding the
CAU audits that are within the purview of the CES and detailed CES sanctions process procedures
are available at CJIS.gov (Law Enforcement Enterprise Portal) CJIS Special Interest Groups CES
Section and CJIS Section of FBI.gov.
The National Crime Prevention and Privacy Compact (Compact) Council at Article VI established
the Compact Council (Council). The Compact Council Sanctions Committee is responsible for
ensuring the use of the Interstate Identification Index System for noncriminal justice purposes
complies with the Compact and with rules, standards, and procedures established by the Compact
Council. As such, the Sanctions Committee reviews the results of audits conducted by the Federal
Bureau of Investigation (FBI) of participants in the FBI’s Criminal Justice Services (CJIS)
Division programs. The Sanctions Committee reviews the audit results and the participant’s
response to determine a course of action necessary to bring the participant into compliance and
make recommendations to the Compact Council or the FBI. Additional information on the
Compact Council Sanctions process is available on the Compact Council’s web-site.
5.11.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 15 – The Audit of a Local Police Department
A local police department implemented a replacement CAD system that integrated to their
state’s CSA and was authorized to process CJI. Shortly after the implementation, their state’s
CSA conducted an audit of their policies, procedures, and systems that process CJI. The police
department supplied all architectural and policy documentation, including detailed network
diagrams, to the auditors in order to assist them in the evaluation. The auditors discovered a
deficiency in the police department’s systems and marked them “out” in this aspect of the FBI
CJIS Security Policy. The police department quickly addressed the deficiency and took
corrective action, notifying the auditors of their actions.

5.12 Policy Area 12: Personnel Security
Having proper security measures against the insider threat is a critical component for the CJIS
Security Policy. This section’s security terms and requirements apply to all personnel who have
access to unencrypted CJI including those individuals with only physical or logical access to
devices that store, process or transmit unencrypted CJI.
5.12.1 Personnel Security Policy and Procedures
5.12.1.1 Minimum Screening Requirements for Individuals Requiring Access to CJI:

1. To verify identification, a state of residency and national fingerprint-based record checks
shall be conducted within 30 days of assignment for all personnel who have direct access
to CJI and those who have direct responsibility to configure and maintain computer systems
and networks with direct access to CJI. However, if the person resides in a different state
than that of the assigned agency, the agency shall conduct state (of the agency) and national
fingerprint-based record checks and execute a NLETS CHRI IQ/FQ/AQ query using
purpose code C, E, or J depending on the circumstances. When appropriate, the screening
shall be consistent with:
(i) 5 CFR 731.106; and/or
(ii) Office of Personnel Management policy, regulations, and guidance; and/or
(iii) agency policy, regulations, and guidance.
(See Appendix J for applicable guidance regarding noncriminal justice agencies
performing adjudication of civil fingerprint submissions.) Federal entities bypassing state
repositories in compliance with federal law may not be required to conduct a state
fingerprint-based record check.
2. All requests for access shall be made as specified by the CSO. The CSO, or their designee,
is authorized to approve access to CJI. All CSO designees shall be from an authorized
criminal justice agency.
3. If a felony conviction of any kind exists, the hiring authority in the Interface Agency shall
deny access to CJI. However, the hiring authority may ask for a review by the CSO in
extenuating circumstances where the severity of the offense and the time that has passed
would support a possible variance.
4. If a record of any other kind exists, access to CJI shall not be granted until the CSO or
his/her designee reviews the matter to determine if access is appropriate.
5. If the person appears to be a fugitive or has an arrest history without conviction, the CSO
or his/her designee shall review the matter to determine if access to CJI is appropriate.
6. If the person is employed by a NCJA, the CSO or his/her designee shall review the matter
to determine if CJI access is appropriate. This same procedure applies if this person is
found to be a fugitive or has an arrest history without conviction.
7. If the person already has access to CJI and is subsequently arrested and or convicted,
continued access to CJI shall be determined by the CSO. This does not implicitly grant
hiring/firing authority with the CSA, only the authority to grant access to CJI. For offenses

other than felonies, the CSO has the latitude to delegate continued access determinations
to his or her designee.
8. If the CSO or his/her designee determines that access to CJI by the person would not be in
the public interest, access shall be denied and the person's appointing authority shall be
notified in writing of the access denial.
9. Support personnel, contractors, and custodial workers with access to physically secure
locations or controlled areas (during CJI processing) shall be subject to a state and national
fingerprint-based record check unless these individuals are escorted by authorized
personnel at all times.
It is recommended individual background re-investigations be conducted every five years unless
Rap Back is implemented.
5.12.1.2 Personnel Screening for Contractors and Vendors

In addition to meeting the requirements in paragraph 5.12.1.1, contractors and vendors shall meet
the following requirements:
1. Prior to granting access to CJI, the CGA on whose behalf the Contractor is retained shall
verify identification via a state of residency and national fingerprint-based record check.
However, if the person resides in a different state than that of the assigned agency, the
agency shall conduct state (of the agency) and national fingerprint-based record checks and
execute a NLETS CHRI IQ/FQ/AQ query using purpose code C, E, or J depending on the
circumstances.
2. If a record of any kind is found, the CGA shall be formally notified and system access shall
be delayed pending review of the criminal history record information. The CGA shall in
turn notify the Contractor-appointed Security Officer.
3. When identification of the applicant with a criminal history has been established by
fingerprint comparison, the CGA or the CJA (if the CGA does not have the authority to
view CHRI) shall review the matter.
4. A Contractor employee found to have a criminal record consisting of felony conviction(s)
shall be disqualified.
5. Applicants shall also be disqualified on the basis of confirmations that arrest warrants are
outstanding for such applicants.
6. The CGA shall maintain a list of personnel who have been authorized access to CJI and
shall, upon request, provide a current copy of the access list to the CSO.
Applicants with a record of misdemeanor offense(s) may be granted access if the CSO determines
the nature or severity of the misdemeanor offense(s) do not warrant disqualification. The CGA
may request the CSO to review a denial of access determination.
5.12.2 Personnel Termination
The agency, upon termination of individual employment, shall immediately terminate access to
CJI.

5.12.3 Personnel Transfer
The agency shall review CJI access authorizations when personnel are reassigned or transferred to
other positions within the agency and initiate appropriate actions such as closing and establishing
accounts and changing system access authorizations.
5.12.4 Personnel Sanctions
The agency shall employ a formal sanctions process for personnel failing to comply with
established information security policies and procedures.
5.12.5 References/Citations/Directives
Appendix I contains all of the references used in this Policy and may contain additional sources
that apply to this section.
Figure 16 – A Local Police Department's Personnel Security Controls
A local police department implemented a replacement CAD system that integrated to their
state’s CSA and was authorized to process CJI. In addition to the physical and technical controls
already in place, the police department implemented a variety of personnel security controls to
reduce the insider threat. The police department used background screening consistent with the
FBI CJIS Security Policy to vet those with unescorted access to areas in which CJI is processed,
including the IT administrators employed by a contractor and all janitorial staff. The police
department established sanctions against any vetted person found to be in violation of stated
policies. The police department re-evaluated each person’s suitability for access to CJI every
five years.

5.13 Policy Area 13: Mobile Devices
This policy area describes considerations and requirements for mobile devices including
smartphones and tablets. Mobile devices are not limited to a single form factor or communications
medium. The requirements in this section augment those in other areas of the Policy to address
the gaps introduced by using mobile devices.
The agency shall: (i) establish usage restrictions and implementation guidance for mobile devices;
and (ii) authorize, monitor, control wireless access to the information system. Wireless
technologies, in the simplest sense, enable one or more devices to communicate without physical
connections—without requiring network or peripheral cabling.
Appendix G provides reference material and additional information on mobile devices.
5.13.1 Wireless Communications Technologies
Examples of wireless communication technologies include, but are not limited to: 802.11, cellular,
Bluetooth, satellite, microwave, and land mobile radio (LMR). Wireless technologies require at
least the minimum security applied to wired technology and, based upon the specific technology
or implementation, wireless technologies may require additional security controls as described
below.
5.13.1.1 802.11 Wireless Protocols

Wired Equivalent Privacy (WEP) and Wi-Fi Protected Access (WPA) cryptographic algorithms,
used by all pre-802.11i protocols, do not meet the requirements for FIPS 140-2 and shall not be
used.
Agencies shall implement the following controls for all agency-managed wireless access points
with access to an agency’s network that processes unencrypted CJI:
1. Perform validation testing to ensure rogue APs (Access Points) do not exist in the
802.11 Wireless Local Area Network (WLAN) and to fully understand the wireless
network security posture.
2. Maintain a complete inventory of all Access Points (APs) and 802.11 wireless devices.
3. Place APs in secured areas to prevent unauthorized physical access and user
manipulation.
4. Test AP range boundaries to determine the precise extent of the wireless coverage and
design the AP wireless coverage to limit the coverage area to only what is needed for
operational purposes.
5. Enable user authentication and encryption mechanisms for the management interface
of the AP.
6. Ensure that all APs have strong administrative passwords and ensure that all passwords
are changed in accordance with Section 5.6.2.1.
7. Ensure the reset function on APs is used only when needed and is only invoked by
authorized personnel. Restore the APs to the latest security settings, when the reset
functions are used, to ensure the factory default settings are not utilized.

8. Change the default service set identifier (SSID) in the APs. Disable the broadcast SSID
feature so that the client SSID must match that of the AP. Validate that the SSID
character string does not contain any agency identifiable information (division,
department, street, etc.) or services.
9. Enable all security features of the wireless product, including the cryptographic
authentication, firewall, and other available privacy features.
10. Ensure that encryption key sizes are at least 128-bits and the default shared keys are
replaced by unique keys.
11. Ensure that the ad hoc mode has been disabled.
12. Disable all nonessential management protocols on the APs.
13. Ensure all management access and authentication occurs via FIPS compliant secure
protocols (e.g. SFTP, HTTPS, SNMP over TLS, etc.). Disable non-FIPS compliant
secure access to the management interface.
14. Enable logging (if supported) and review the logs on a recurring basis per local policy.
At a minimum logs shall be reviewed monthly.
15. Insulate, virtually (e.g. virtual local area network (VLAN) and ACLs) or physically
(e.g. firewalls), the wireless network from the operational wired infrastructure. Limit
access between wireless networks and the wired network to only operational needs.
16. When disposing of access points that will no longer be used by the agency, clear access
point configuration to prevent disclosure of network configuration, keys, passwords,
etc.
5.13.1.2 Cellular Devices

Cellular telephones, smartphones (i.e. Blackberry, iPhones, etc.), tablets, personal digital assistants
(PDA), and “aircards” are examples of cellular handheld devices or devices that are capable of
employing cellular technology. Additionally, cellular handheld devices typically include
Bluetooth, infrared, and other wireless protocols capable of joining infrastructure networks or
creating dynamic ad hoc networks.
Threats to cellular handheld devices stem mainly from their size, portability, and available wireless
interfaces and associated services. Examples of threats to cellular handheld devices include:
1. Loss, theft, or disposal.
2. Unauthorized access.
3. Malware.
4. Spam.
5. Electronic eavesdropping.
6. Electronic tracking (threat to security of data and safety of the criminal justice
professional).
7. Cloning (not as prevalent with later generation cellular technologies).
8. Server-resident data.
5.13.1.2.1 Cellular Service Abroad

Certain internal functions on cellular devices may be modified or compromised by the cellular
carrier during international use as the devices are intended to have certain parameters configured
by the cellular provider which is considered a “trusted” entity by the device.
When devices are authorized to access CJI outside the U.S., agencies shall perform an inspection
to ensure that all controls are in place and functioning properly in accordance with the agency’s
policies prior to and after deployment outside of the U.S.
5.13.1.2.2 Voice Transmissions Over Cellular Devices

Any cellular device used to transmit CJI via voice is exempt from the encryption and authentication
requirements.
5.13.1.3 Bluetooth

Bluetooth is an open standard for short-range radio frequency (RF) communication. Bluetooth is
used primarily to establish wireless personal area networks (WPAN). Bluetooth technology has
been integrated into many types of business and consumer devices, including cell phones, laptops,
automobiles, medical devices, printers, keyboards, mice, headsets, and biometric capture devices.
Bluetooth technology and associated devices are susceptible to general wireless networking threats
(e.g. denial of service [DoS] attacks, eavesdropping, man-in-the-middle [MITM] attacks, message
modification, and resource misappropriation) as well as specific Bluetooth-related attacks that
target known vulnerabilities in Bluetooth implementations and specifications. Organizational
security policy shall be used to dictate the use of Bluetooth and its associated devices based on the
agency’s operational and business processes.
5.13.1.4 Mobile Hotspots

Many mobile devices include the capability to function as a WiFi hotspot that allows other devices
to connect through the device to the internet over the devices cellular network.
When an agency allows mobile devices that are approved to access or store CJI to function as a
Wi-Fi hotspot connecting to the Internet, they shall be configured:
1. Enable encryption on the hotspot
2. Change the hotspot’s default SSID
a. Ensure the hotspot SSID does not identify the device make/model or agency
ownership
3. Create a wireless network password (Pre-shared key)
4. Enable the hotspot’s port filtering/blocking features if present
5. Only allow connections from agency controlled devices
Note: Refer to the requirements in Section 5.10.1.2 encryption for item #1. Refer to the
requirements in Section 5.6.2.2.1 Password for item #3. Only password attributes #1, #2 and #3
are required.
OR

1. Have a MDM solution to provide the same security as identified in items 1 – 5 above.

5.13.2 Mobile Device Management (MDM)
Mobile Device Management (MDM) facilitates the implementation of sound security controls for
mobile devices and allows for centralized oversight of configuration control, application usage,
and device protection and recovery, if so desired by the agency.
Due to the potential for inconsistent network access or monitoring capability on mobile devices,
methods used to monitor and manage the configuration of full featured operating systems may not
function properly on devices with limited feature operating systems. MDM systems and
applications coupled with device specific technical policy can provide a robust method for device
configuration management if properly implemented.
Devices that have had any unauthorized changes made to them (including but not limited to being
rooted or jailbroken) shall not be used to process, store, or transmit CJI data at any time. Agencies
shall implement the following controls when allowing CJI access from devices running a limitedfeature operating system:
1. Ensure that CJI is only transferred between CJI authorized applications and storage areas
of the device.
2. MDM with centralized administration configured and implemented to perform at least
the:
i.
Remote locking of device
ii.
Remote wiping of device
iii. Setting and locking device configuration
iv.
Detection of “rooted” and “jailbroken” devices
v.
Enforcement of folder or disk level encryption
vi.
Application of mandatory policy settings on the device
vii.
Detection of unauthorized configurations
viii. Detection of unauthorized software or applications
ix. Ability to determine the location of agency controlled devices
x. Prevention of unpatched devices from accessing CJI or CJI systems
xi. Automatic device wiping after a specified number of failed access attempts
5.13.3 Wireless Device Risk Mitigations
Organizations shall, at a minimum, ensure that wireless devices:
1. Apply available critical patches and upgrades to the operating system as soon as they
become available for the device and after necessary testing as described in Section
5.10.4.1.
2. Are configured for local device authentication (see Section 5.13.7.1).
3. Use advanced authentication or CSO approved compensating controls as per Section
5.13.7.2.1.
4. Encrypt all CJI resident on the device.
5. Erase cached information, to include authenticators (see Section 5.6.2.1) in
applications, when session is terminated.
6. Employ personal firewalls or run a Mobile Device Management (MDM) system that
facilitates the ability to provide firewall services from the agency level.
7. Employ malicious code protection or run a MDM system that facilitates the ability to
provide anti-malware services from the agency level.
5.13.4 System Integrity
Managing system integrity on limited function mobile operating systems may require methods
and technologies significantly different from traditional full featured operating systems. In many
cases, the requirements of Section 5.10 of the CJIS Security Policy cannot be met with a mobile
device without the installation of a third party MDM, application, or supporting service
infrastructure.
5.13.4.1 Patching/Updates

Based on the varying connection methods for mobile devices, an always on connection cannot be
guaranteed for patching and updating. Devices without always-on cellular connections may not
be reachable for extended periods of time by the MDM or solution either to report status or
initiate patching.
Agencies shall monitor mobile devices to ensure their patch and update state is current.
5.13.4.2 Malicious Code Protection

Appropriately configured MDM software is capable of checking the installed applications on the
device and reporting the software inventory to a central management console in a manner
analogous to traditional virus scan detection of unauthorized software and can provide a high
degree of confidence that only known software or applications are installed on the device.
Agencies that allow smartphones and tablets to access CJI shall have a process to approve the
use of specific software or applications on the devices. Any device natively capable of
performing these functions without a MDM solution is acceptable under this section.
5.13.4.3 Personal Firewall

For the purpose of this policy, a personal firewall is an application that controls network traffic to
and from a user device, permitting or denying communications based on policy. A personal
firewall shall be employed on all mobile devices that have a full-feature operating system (i.e.
laptops or tablets with Windows or Linux/Unix operating systems). At a minimum, the personal
firewall shall perform the following activities:
1. Manage program access to the Internet.
2. Block unsolicited requests to connect to the user device.
3. Filter incoming traffic by IP address or protocol.
4. Filter incoming traffic by destination ports.
5. Maintain an IP traffic log.
Mobile devices with limited feature operating systems (i.e. tablets, smartphones) may not support
a personal firewall. However, these operating systems have a limited number of system services
installed, carefully controlled network access, and to a certain extent, perform functions similar to
a personal firewall on a device with a full feature operating system. Appropriately configured
MDM software is capable of controlling which applications are allowed on the device.
5.13.5 Incident Response
In addition to the requirements in Section 5.3 Incident Response, agencies shall develop additional
or enhanced incident reporting and handling procedures to address mobile device operating
scenarios. Rapid response to mobile device related incidents can significantly mitigate the risks
associated with illicit data access either on the device itself or within online data resources
associated with the device through an application or specialized interface.
Special reporting procedures for mobile devices shall apply in any of the following situations:
1. Loss of device control. For example:
a. Device known to be locked, minimal duration of loss
b. Device lock state unknown, minimal duration of loss
c. Device lock state unknown, extended duration of loss
d. Device known to be unlocked, more than momentary duration of loss
2. Total loss of device
3. Device compromise
4. Device loss or compromise outside the United States
5.13.6 Access Control
Multiple user accounts are not generally supported on limited feature mobile operating systems.
Access control (Section 5.5 Access Control) shall be accomplished by the application that accesses
CJI.
5.13.7 Identification and Authentication
Due to the technical methods used for identification and authentication on many limited feature
mobile operating systems, achieving compliance may require many different components.
5.13.7.1 Local Device Authentication

When mobile devices are authorized for use in accessing CJI, local device authentication shall be
used to unlock the device for use. The authenticator used shall meet the requirements in section
5.6.2.1 Standard Authenticators.
5.13.7.2 Advanced Authentication

When accessing CJI from an authorized mobile device, advanced authentication shall be used by
the authorized user.

5.13.7.2.1 Compensating Controls

CSO approved compensating controls to meet the AA requirement on agency-issued smartphones
and tablets with limited feature operating systems are permitted. Compensating controls are
temporary control measures that are implemented in lieu of the required AA control measures
when an agency cannot meet a requirement due to legitimate technical or business constraints.
Before CSOs consider approval of compensating controls, Mobile Device Management (MDM)
shall be implemented per Section 5.13.2. The compensating controls shall:
1. Meet the intent of the CJIS Security Policy AA requirement
2. Provide a similar level of protection or security as the original AA requirement
3. Not rely upon the existing requirements for AA as compensating controls
Additionally, compensating controls may rely upon other, non-AA, existing requirements as
compensating controls and/or be combined with new controls to create compensating controls.
The proposed compensating controls for AA are a combination of controls that provide acceptable
assurance only the authorized user is authenticating and not an impersonator or (in the case of
agency-issued device used by multiple users) controls that reduce the risk of exposure if
information is accessed by an unauthorized party.
At least two of the following examples of AA compensating controls for agency-issued
smartphones and tablets with limited feature operating systems shall be implemented to qualify
for compensating control consideration:
-

Possession of the agency issued smartphone or tablet as an indication it is the authorized
user
Implemented password protection on the Mobile Device Management application and/or
secure container where the authentication application is stored
Enable remote device locking
Enable remote data deletion
Enable automatic data wipe after predetermined number of failed authentication attempts
Remote device location (GPS) tracking
Require CJIS Security Policy compliant password to access the device
Use of device certificates as per Section 5.13.7.3 Device Certificates

5.13.7.3 Device Certificates

Device certificates are often used to uniquely identify mobile devices using part of a public key
pair on the device in the form of a public key certificate. While there is value to ensuring the device
itself can authenticate to a system supplying CJI, and may provide a critical layer of device
identification or authentication in a larger scheme, a device certificate alone placed on the device
shall not be considered valid proof that the device is being operated by an authorized user.
When certificates or cryptographic keys used to authenticate a mobile device are used in lieu of
compensating controls for advanced authentication, they shall be:
1. Protected against being extracted from the device
2. Configured for remote wipe on demand or self-deletion based on a number of
unsuccessful login or access attempts
3. Configured to use a secure authenticator (i.e. password, PIN) to unlock the key for use

APPENDICES
APPENDIX A TERMS AND DEFINITIONS
Access to Criminal Justice Information — The physical or logical (electronic) ability, right or
privilege to view, modify or make use of Criminal Justice Information.
Administration of Criminal Justice — The detection, apprehension, detention, pretrial release,
post-trial release, prosecution, adjudication, correctional supervision, or rehabilitation of accused
persons or criminal offenders. It also includes criminal identification activities; the collection,
storage, and dissemination of criminal history record information; and criminal justice
employment. In addition, administration of criminal justice includes “crime prevention programs”
to the extent access to criminal history record information is limited to law enforcement agencies
for law enforcement programs (e.g. record checks of individuals who participate in Neighborhood
Watch or “safe house” programs) and the result of such checks will not be disseminated outside
the law enforcement agency.
Agency Controlled Mobile Device — A mobile device that is centrally managed by an agency
for the purpose of securing the device for potential access to CJI. The device can be agency issued
or BYOD (personally owned).
Agency Coordinator (AC) — A staff member of the Contracting Government Agency who
manages the agreement between the Contractor and agency.
Agency Issued Mobile Device — A mobile device that is owned by an agency and issued to an
individual for use. It is centrally managed by the agency for the purpose of securing the device
for potential access to CJI. The device is not BYOD (personally owned).
Agency Liaison (AL) — Coordinator of activities between the criminal justice agency and the
noncriminal justice agency when responsibility for a criminal justice system has been delegated
by a criminal justice agency to a noncriminal justice agency, which has in turn entered into an
agreement with a contractor. The agency liaison shall, inter alia, monitor compliance with system
security requirements. In instances in which the noncriminal justice agency's authority is directly
from the CJIS systems agency, there is no requirement for the appointment of an agency liaison.
Asymmetric Encryption — A type of encryption that uses key pairs for encryption. One key is
used to encrypt a message and another key to decrypt the message. Asymmetric encryption is also
commonly known as public key encryption.
Authorized User/Personnel — An individual, or group of individuals, who have been
appropriately vetted through a national fingerprint-based record check and have been granted
access to CJI.
Authorized Recipient — (1) A criminal justice agency or federal agency authorized to receive
CHRI pursuant to federal statute or executive order; (2) A nongovernmental entity authorized by
federal statute or executive order to receive CHRI for noncriminal justice purposes; or (3) A
government agency authorized by federal statute or executive order, or state statute which has been
approved by the United States Attorney General to receive CHRI for noncriminal justice purposes.

Availability — The degree to which information, a system, subsystem, or equipment is operable
and in a useable state; frequently represented as a proportion of time the element is in a functioning
condition.
Biographic Data — Information collected about individuals associated with a unique case, and
not necessarily connected to identity data. Biographic Data does not provide a history of an
individual, only information related to a unique case.
Biometric Data — When applied to CJI, it is used to identify individuals, and includes the
following types: fingerprints, palm prints, DNA, iris, and facial recognition.
Case / Incident History — All relevant information gathered about an individual, organization,
incident, or combination thereof, arranged so as to serve as an organized record to provide analytic
value for a criminal justice organization. In regards to CJI, it is the information about the history
of criminal incidents.
Certificate Authority (CA) Certificate – Digital certificates required for certificate-based
authentication that are issued to tell the client computers and servers that it can trust other
certificates that are issued by this CA.
Channeler — A FBI approved contractor, who has entered into an agreement with an Authorized
Recipient(s), to receive noncriminal justice applicant fingerprint submissions and collect the
associated fees. The Channeler ensures fingerprint submissions are properly and adequately
completed, electronically forwards fingerprint submissions to the FBI's CJIS Division for national
noncriminal justice criminal history record check, and receives electronic record check results for
dissemination to Authorized Recipients. A Channeler is essentially an "expediter" rather than a
user of criminal history record check results.
Cloud Client – A machine or software application that accesses cloud services over a network
connection, perhaps on behalf of a subscriber.
Cloud Computing – A distributed computing model that permits on-demand network access to a
shared pool of configurable computing resources (i.e., networks, servers, storage, applications, and
services), software, and information.
Cloud Provider – An organization that provides cloud computing services.
Cloud Subscriber – A person or organization that is a customer of a cloud computing service
provider.
CJIS Advisory Policy Board (APB) — The governing organization within the FBI CJIS
Advisory Process composed of representatives from criminal justice and national security agencies
within the United States. The APB reviews policy, technical, and operational issues relative to
CJIS Division programs and makes subsequent recommendations to the Director of the FBI.
CJIS Audit Unit (CAU) — The organization within the FBI CJIS Division responsible to perform
audits of CSAs to verify compliance with the CJIS Security Policy.
CJIS Security Policy — The FBI CJIS Security Policy document as published by the FBI CJIS
ISO; the document containing this glossary.
CJIS Systems Agency (CSA) — A duly authorized state, federal, international, tribal, or territorial
criminal justice agency on the CJIS network providing statewide (or equivalent) service to its
criminal justice users with respect to the CJI from various systems managed by the FBI CJIS
Division. There shall be only one CSA per state or territory. In federal agencies, the CSA may be
the interface or switch to other federal agencies connecting to the FBI CJIS systems.
CJIS Systems Agency Information Security Officer (CSA ISO) — The appointed FBI CJIS
Division personnel responsible to coordinate information security efforts at all CJIS interface
agencies.
CJIS Systems Officer (CSO) — The individual located within the CJIS Systems Agency
responsible for the administration of the CJIS network on behalf of the CJIS Systems Agency.
Compact Council — The entity created by the National Crime Prevention and Privacy Compact
of 1998 that has the authority to promulgate rules and procedures governing the use of the III
system for noncriminal justice purposes.
Compact Officers — The leadership of the Compact Council, oversees the infrastructure
established by the National Crime Prevention and Privacy Compact Act of 1998, which is used by
ratifying states to exchange criminal records for noncriminal justice purposes. Their primary
responsibilities are to promulgate rules and procedures for the effective and appropriate use of the
III system.
Compensating Controls — Compensating controls are temporary control measures implemented
in lieu of the required control measures when an agency cannot meet the AA requirement due to
legitimate technical or business constraints. The compensating controls must:
1. Meet the intent of the CJIS Security Policy AA requirement
2. Provide a similar level of protection or security as the original AA requirement
3. Not rely upon the existing requirements for AA as compensating controls
Additionally, compensating controls may rely upon other, non-AA, existing requirements as
compensating controls and/or be combined with new controls to create compensating controls.
Computer Security Incident Response Capability (CSIRC) — A collection of personnel,
systems, and processes that are used to efficiently and quickly manage a centralized response to
any sort of computer security incident which may occur.
Confidentiality — The concept of ensuring that information is observable only to those who have
been granted authorization to do so.
Contractor — A private business, agency or individual which has entered into an agreement for
the administration of criminal justice or noncriminal justice functions with a Criminal Justice
Agency or a Noncriminal Justice Agency. Also, a private business approved by the FBI CJIS
Division to contract with Noncriminal Justice Agencies to perform noncriminal justice functions
associated with civil fingerprint submission for hiring purposes.
Contracting Government Agency (CGA) — The government agency, whether a Criminal
Justice Agency or a Noncriminal Justice Agency, which enters into an agreement with a private
contractor.
Crime Reports Data — The data collected through the Uniform Crime Reporting program and
reported upon annually by the FBI CJIS division used to analyze the crime statistics for the United
States.

Criminal History Record Information (CHRI) — A subset of CJI. Any notations or other
written or electronic evidence of an arrest, detention, complaint, indictment, information or other
formal criminal charge relating to an identifiable person that includes identifying information
regarding the individual as well as the disposition of any charges.
Criminal Justice Agency (CJA) — The courts, a governmental agency, or any subunit of a
governmental agency which performs the administration of criminal justice pursuant to a statute
or executive order and which allocates a substantial part of its annual budget to the administration
of criminal justice. State and federal Inspectors General Offices are included.
Criminal Justice Agency User Agreement — A terms-of-service agreement that must be signed
prior to accessing CJI. This agreement is required by each CJA and spells out user’s
responsibilities, the forms and methods of acceptable use, penalties for their violation, disclaimers,
and so on.
Criminal Justice Conveyance — A criminal justice conveyance is any enclosed mobile vehicle
used for the purposes of criminal justice activities with the capability to comply, during operational
periods, with the requirements of Section 5.9.1.3.
Criminal Justice Information (CJI) — Criminal Justice Information is the abstract term used to
refer to all of the FBI CJIS provided data necessary for law enforcement agencies to perform their
mission and enforce the laws, including but not limited to: biometric, identity history, person,
organization, property (when accompanied by any personally identifiable information), and
case/incident history data. In addition, CJI refers to the FBI CJIS-provided data necessary for civil
agencies to perform their mission; including, but not limited to data used to make hiring decisions.
The following type of data are exempt from the protection levels required for CJI: transaction
control type numbers (e.g. ORI, NIC, FNU, etc.) when not accompanied by information that
reveals CJI or PII.
Criminal Justice Information Services Division (FBI CJIS or CJIS) — The FBI division
responsible for the collection, warehousing, and timely dissemination of relevant CJI to the FBI
and to qualified law enforcement, criminal justice, civilian, academic, employment, and licensing
agencies.
Data — See Information and CJI.
Decryption – The inverse cryptographic operation used to convert encrypted information back
into a plaintext (readable) format.
Degauss — Neutralize a magnetic field to erase information from a magnetic disk or other storage
device. In the field of information technology, degauss has become synonymous with erasing
information whether or not the medium is magnetic. In the event the device to be degaussed is not
magnetic (e.g. solid state drive, USB storage device), steps other than magnetic degaussing may
be required to render the information irretrievable from the device.
Department of Justice (DoJ) — The Department within the U.S. Government responsible to
enforce the law and defend the interests of the United States according to the law, to ensure public
safety against threats foreign and domestic, to provide federal leadership in preventing and
controlling crime, to seek just punishment for those guilty of unlawful behavior, and to ensure fair
and impartial administration of justice for all Americans.

Digital Media – Any form of electronic media designed to store data in a digital format. This
includes, but is not limited to: memory device in laptops, computers, and mobile devices; and any
removable, transportable electronic media, such as magnetic tape or disk, optical disk, flash drives,
external hard drives, or digital memory card.
Digital Signature – A digital signature consists of three algorithms: (1) A key generation
algorithm that selects a private key uniformly at random from a set of possible private keys. The
algorithm outputs the private key and a corresponding public key. (2) A signing algorithm that,
given a message and a private key, produces a signature. (3) A signature verifying algorithm that,
given a message, public key, and a signature, either accepts or rejects the message’s claim to
authenticity. Two main properties are required. First, a signature generated from a fixed message
and fixed private key should verify the authenticity of that message by using the corresponding
public key. Secondly, it should be computationally infeasible to generate a valid signature for a
party who does not possess the private key.
Direct Access — (1) Having the authority to access systems managed by the FBI CJIS Division,
whether by manual or automated methods, not requiring the assistance of, or intervention by, any
other party or agency (28 CFR, Chapter 1, Part 20). (2) Having the authority to query or update
national databases maintained by the FBI CJIS Division including national queries and updates
automatically or manually generated by the CSA.
Dissemination — The transmission/distribution of CJI to Authorized Recipients within an agency.
Encryption – A form of cryptology that applies a cryptographic operation to provide
confidentiality of (sensitive) information.
Escort – Authorized personnel who accompany a visitor at all times while within a physically
secure location to ensure the protection and integrity of the physically secure location and any
Criminal Justice Information therein. The use of cameras or other electronic means used to
monitor a physically secure location does not constitute an escort.
Facsimile (Fax) – Facsimile is: (a) a document received and printed on a single or multi-function
stand-alone device, (b) a single or multi-function stand-alone device for the express purpose of
transmitting and receiving documents from a like device over a standard telephone line, or (c) a
facsimile server, application, service which implements email-like technology and transfers
documents over a network.
Federal Bureau of Investigation (FBI) — The agency within the DOJ responsible to protect and
defend the United States against terrorist and foreign intelligence threats, to uphold and enforce
the criminal laws of the United States, and to provide leadership and criminal justice services to
federal, state, municipal, and international agencies and partners.
FBI CJIS Information Security Officer (FBI CJIS ISO) — The FBI personnel responsible for
the maintenance and dissemination of the FBI CJIS Security Policy; the liaison between the FBI
and the CSA’s ISOs and other relevant security points-of-contact (POCs); the provider of technical
guidance as to the intent and implementation of technical policy issues; the POC for computer
incident notification which also disseminates security alerts to the CSOs and ISOs.
Federal Information Security Management Act (FISMA) — The Federal Information Security
Management Act of 2002, a US Federal law that established information security standards for the
protection of economic and national security interests of the United States. It requires each federal
agency to develop, document, and implement an agency-wide program to provide information
security for the information and information systems that support the operations and assets of the
agency, including those provided or managed by another agency, contractor, or other source.
For Official Use Only (FOUO) — A caveat applied to unclassified sensitive information that
may be exempt from mandatory release to the public under the Freedom of Information Act
(FOIA), 5 U.S.C 522. In general, information marked FOUO shall not be disclosed to anybody
except Government (Federal, State, tribal, or local) employees or contractors with a need to know.
Full-feature Operating System — Full-feature operating systems are traditional operating
systems used by a standard desktop computer (e.g. Microsoft Windows, Apple OSX/macOS,
LINUX/UNIX, etc.). These operating systems are generally open to user control and configuration
and therefore require configuration management to properly secure, or “harden”, these devices
from malicious network based technical attacks (e.g. malware, spyware, hackers, etc.). These
operating systems require traditional protection applications such as antivirus programs and
personal firewalls.
Guest Operating System — An operating system that has emulated hardware presented to it by
a host operating system. Also referred to as the virtual machine (VM).
Host Operating System — In the context of virtualization, the operating system that interfaces
with the actual physical hardware and arbitrates between it and the guest operating systems. It is
also referred to as a hypervisor.
Hybrid Encryption — A type of encryption where both asymmetric encryption and symmetric
encryption keys are used creating what is referred to as cipher suites. In a hybrid solution the
asymmetric encryption keys are used for client/server certificate exchange to provide session
integrity while the symmetric encryption keys are used for bulk data encryption to provide data
confidentiality.
Hypervisor — See Host Operating System.
Identity History Data — Textual data that corresponds with an individual’s biometric data,
providing a history of criminal and/or civil events for the identified individual.
In-Band – The communication service channel (network connection, email, SMS text, phone call,
etc.) used to obtain an authenticator is the same as the one used for login.
Indirect Access – Having the authority to access systems containing CJI without providing the
user the ability to conduct transactional activities (the capability to query or update) on state and
national systems (e.g. CJIS Systems Agency (CSA), State Identification Bureau (SIB), or national
repositories).
Information — See data and CJI.
Information Exchange Agreement — An agreement that codifies the rules by which two parties
engage in the sharing of information. These agreements typically include language which
establishes some general duty-of-care over the other party’s information, whether and how it can
be further disseminated, penalties for violations, the laws governing the agreement (which
establishes venue), procedures for the handling of shared information at the termination of the
agreement, and so on. This document will ensure consistency with applicable federal laws,
directives, policies, regulations, standards and guidance.

Information Security Officer (ISO) — Typically a member of an organization who has the
responsibility to establish and maintain information security policy, assesses threats and
vulnerabilities, performs risk and control assessments, oversees the governance of security
operations, and establishes information security training and awareness programs. The ISO also
usually interfaces with security operations to manage implementation details and with auditors to
verify compliance to established policies.
Information System — A system of people, data, and processes, whether manual or automated,
established for the purpose of managing information.
Integrated Automated Fingerprint Identification System (IAFIS) — The national fingerprint
and criminal history system maintained by the FBI CJIS Division that provides the law
enforcement community with automated fingerprint search capabilities, latent searching
capability, electronic image storage, and electronic exchange of fingerprints and responses.
Integrity — The perceived consistency of expected outcomes, actions, values, and methods of an
individual or organization. As it relates to data, it is the concept that data is preserved in a
consistent and correct state for its intended use.
Interconnection Security Agreement (ISA) — An agreement much like an Information
Exchange Agreement as mentioned above, but concentrating more on formalizing the technical
and security requirements pertaining to some sort of interface between the parties’ information
systems.
Interface Agency — A legacy term used to describe agencies with direct connections to the
CSA. This term is now used predominantly in a common way to describe any sub-agency of a
CSA or SIB that leverages the CSA or SIB as a conduit to FBI CJIS information.
Internet Protocol (IP) — A protocol used for communicating data across a packet-switched
internetwork using the Internet Protocol Suite, also referred to as TCP/IP. IP is the primary
protocol in the Internet Layer of the Internet Protocol Suite and has the task of delivering
distinguished protocol datagrams (packets) from the source host to the destination host solely
based on their addresses.
Interstate Identification Index (III) — The CJIS service that manages automated submission
and requests for CHRI that is warehoused subsequent to the submission of fingerprint information.
Subsequent requests are directed to the originating State as needed.
Jailbreak (Jailbroken) — The process of attaining privileged control (known as “root access”)
of a device running the Apple iOS operating system that ultimately allows a user the ability to alter
or replace system applications and settings, run specialized applications that require administratorlevel permissions, or perform other operations that are otherwise not allowed.
Laptop Devices – Laptop devices are mobile devices with a full-featured operating system (e.g.
Microsoft Windows, Apple OSX/macOS, LINUX/UNIX, etc.). Laptops are typically intended for
transport via vehicle mount or portfolio-sized carry case, but not on the body. This definition does
not include pocket/handheld devices (e.g. smartphones), or mobile devices that feature a limited
feature operating system (e.g. tablets).
Law Enforcement Enterprise Portal (LEEP) — A secure, Internet-based communications
portal provided by the FBI CJIS Division for use by law enforcement, first responders, criminal
justice professionals, and anti-terrorism and intelligence agencies around the globe. Its primary
purpose is to provide a platform on which various law enforcement agencies can collaborate on
FOUO matters.
Limited-feature Operating System — Limited-feature operating systems are designed
specifically for the mobile environment where battery life and power efficiency are primary design
drivers (e.g. Apple iOS, Android, Windows Mobile, Blackberry OS, etc.). There operating systems
permit limited user control, but are inherently more resistant than a full-feature operating system
to certain types of network based technical attacks due to the limited feature sets. Devices using
these operating systems are required to be managed by a mobile device management solution.
Logical Access – The technical means (e.g., read, create, modify, delete a file, execute a program,
or use an external connection) for an individual or other computer system to utilize CJI or CJIS
applications.
Logical Partitioning – When the host operating system, or hypervisor, allows multiple guest
operating systems to share the same physical resources.
Local Agency Security Officer (LASO) — The primary Information Security contact between a
local law enforcement agency and the CSA under which this agency interfaces with the FBI CJIS
Division. The LASO actively represents their agency in all matters pertaining to Information
Security, disseminates Information Security alerts and other material to their constituents,
maintains Information Security documentation (including system configuration data), assists with
Information Security audits of hardware and procedures, and keeps the CSA informed as to any
Information Security needs and problems.
Management Control Agreement (MCA) — An agreement between parties that wish to share
or pool resources that codifies precisely who has administrative control over, versus overall
management and legal responsibility for, assets covered under the agreement. An MCA must
ensure the CJA’s authority remains with regard to all aspects of Section 3.2.2. The MCA usually
results in the CJA having ultimate authority over the CJI supporting infrastructure administered
by the NCJA.
Mobile Device — Any portable device used to access CJI via a wireless connection (e.g. cellular,
WiFi, Bluetooth, etc.).
Mobile Device Management (MDM) — Centralized administration and control of mobile
devices specifically including, but not limited to, cellular phones, smart phones, and tablets.
Management typically includes the ability to configure device settings and prevent a user from
changing them, remotely locating a device in the event of theft or loss, and remotely locking or
wiping a device. Management can also include over-the-air distribution of applications and
updating installed applications.
Mobile (WiFi) Hotspot — A mobile (WiFi) hotspot is a zone or area associated with a mobile
device (e.g. smartphone, air card) allowing wireless connectivity to the Internet typically through
a cellular connection.
National Crime Information Center (NCIC) — An information system which stores CJI which
can be queried by appropriate Federal, state, and local law enforcement and other criminal justice
agencies.
National Instant Criminal Background Check System (NICS) — A system mandated by the
Brady Handgun Violence Prevention Act of 1993 that is used by Federal Firearms Licensees
(FFLs) to instantly determine via telephone or other electronic means whether the transfer of a
firearm would be in violation of Section 922 (g) or (n) of Title 18, United States Code, or state
law, by evaluating the prospective buyer’s criminal history.
National Institute of Standards and Technology (NIST) — Founded in 1901, NIST is a nonregulatory federal agency within the U.S. Department of Commerce whose mission is to promote
U.S. innovation and industrial competitiveness by advancing measurement science, standards, and
technology in ways that enhance economic and national security.
Noncriminal Justice Agency (NCJA) — A governmental agency, or any subunit thereof, that
provides services primarily for purposes other than the administration of criminal justice.
Examples of services include, but not limited to, employment suitability, licensing determinations,
immigration and naturalization matters, and national security clearances.
NCJA (Government) — A Federal, state, local, or tribal governmental agency or any subunit
thereof whose charter does not include the responsibility to administer criminal justice, but may
have a need to process CJI. An example would be the central IT organization within a state
government that administers equipment on behalf of a state law-enforcement agency.
NCJA (Private) — A private agency or subunit thereof whose charter does not include the
responsibility to administer criminal justice, but may have a need to process CJI. An example
would include a local bank.
NCJA (Public) — A public agency or sub-unit thereof whose charter does not include the
responsibility to administer criminal justice, but may have a need to process CJI. An example
would include a county school board which uses CHRI to assist in employee hiring decisions.
Noncriminal Justice Purpose — The uses of criminal history records for purposes authorized by
federal or state law other than purposes relating to the administration of criminal justice, including
employment suitability, licensing determinations, immigration and naturalization matters, and
national security clearances.
Office of Management and Budget (OMB) — The agency within the Executive Branch of the
Federal government responsible to oversee the preparation of the federal budget, to assist in the
supervision of other Executive Branch agencies, and to oversee and coordinate the Presidential
Administration’s procurement, financial management, information, and regulatory policies.
One-time Password — A disposable, single-use standard authenticator for access CJI. One-time
passwords are: minimum of six (6) randomly generated characters, valid for a single session, and
if not used, expire within a minimum of five (5) minutes after issuance.
Out-of-Band — The communication service channel (network connection, email, SMS text,
phone call, etc.) used to obtain an authenticator is separate from that used for login.
Outsourcing — The process of delegating in-house operations to a third-party. For instance, when
the administration of criminal justice functions (network operations, dispatch functions, system
administration operations, etc.) are performed for the criminal justice agency by a city or county
information technology department or are contracted to be performed by a vendor.
Outsourcing Standard — National Crime Prevention and Privacy Compact Council’s
Outsourcing Standard. The Compact Council’s uniform standards and processes for the interstate
and Federal-State exchange of criminal history records for noncriminal justice purposes.

Partitioning – Managing guest operating system, or virtual machine, access to hardware so that
each guest OS can access its own resources but cannot encroach on the other guest operating
systems resources or any resources not allocated for virtualization use.
Personal Firewall — An application which controls network traffic to and from a computer,
permitting or denying communications based on a security policy.
Personally Identifiable Information (PII) — PII is information which can be used to distinguish
or trace an individual’s identity, such as name, social security number, or biometric records, alone
or when combined with other personal or identifying information which is linked or linkable to a
specific individual, such as date and place of birth, or mother’s maiden name.
Physical Access – The physical ability, right or privilege to view, modify or make use of Criminal
Justice Information (CJI) by means of physical presence within the proximity of computers and
network devices (e.g. the ability to insert a boot disk or other device into the system, make a
physical connection with electronic equipment, etc.).
Physical Media – Physical media refers to media in printed form. This definition includes, but is
not limited to, printed documents, printed imagery, printed facsimile.
Physical Partitioning – When the host operating system, or hypervisor, assigns separate physical
resources to each guest operating systems, or virtual machine.
Physically Secure Location — A facility, a criminal justice conveyance, or an area, a room, or a
group of rooms, within a facility with both the physical and personnel security controls sufficient
to protect CJI and associated information systems.
Pocket/Handheld Mobile Device – Pocket/Handheld mobile devices (e.g. smartphones) are
intended to be carried in a pocket or holster attached to the body and feature an operating system
with limited functionality (e.g., iOS, Android, BlackBerry, etc.). This definition does not include
tablet and laptop devices.
Property Data — Information about vehicles and property associated with a crime.
Rap Back — A NGI service that allows authorized agencies to receive notification of subsequent
criminal activity reported to the FBI committed by persons of interest.
Receive-Only Terminal (ROT) – A device that is configured to accept a limited type of data but
is technically prohibited from forming or transmitting data, browsing or navigating internal or
external networks, or otherwise performing outside the scope of receive only (e.g., a printer, dumb
terminal, etc.).
Repository Manager, or Chief Administrator — The designated manager of the agency having
oversight responsibility for a CSA’s fingerprint identification services. If both state fingerprint
identification services and CJIS systems control are managed within the same state agency, the
repository manager and CSO may be the same person.
Root (Rooting, Rooted) — The process of attaining privileged control (known as “root access”)
of a device running the Android operating system that ultimately allows a user the ability to alter
or replace system applications and settings, run specialized applications that require administratorlevel permissions, or perform other operations that are otherwise not allowed.

Secondary Dissemination — The promulgation of CJI from a releasing agency to an authorized
recipient agency when the recipient agency has not been previously identified in a formal
information exchange agreement.
Security Addendum (SA) — A uniform addendum to an agreement between the government
agency and a private contractor, approved by the Attorney General of the United States, which
specifically authorizes access to criminal history record information, limits the use of the
information to the purposes for which it is provided, ensures the security and confidentiality of the
information consistent with existing regulations and the CJIS Security Policy, provides for
sanctions, and contains such other provisions as the Attorney General may require.
Sensitive But Unclassified (SBU) — Designation of information in the United States federal
government that, though unclassified, often requires strict controls over its distribution. SBU is a
broad category of information that includes material covered by such designations as For Official
Use Only (FOUO), Law Enforcement Sensitive (LES), Sensitive Homeland Security Information,
Security Sensitive Information (SSI), Critical Infrastructure Information (CII), etc. Some
categories of SBU information have authority in statute or regulation (e.g. SSI, CII) while others,
including FOUO, do not. As of May 9, 2008, the more appropriate terminology to use is
Controlled Unclassified Information (CUI).
Server/Client Computer Certificate (device-based) – Digital certificates that are issued to
servers or client computers or devices by a CA and used to prove device identity between server
and/or client computer devices during the authentication process.
Service — The organized system of apparatus, appliances, personnel, etc, that supply some
tangible benefit to the consumers of this service. In the context of CJI, this usually refers to one
of the applications that can be used to process CJI.
Shredder — A device used for shredding documents, often as a security measure to prevent
unapproved persons from reading them. Strip-cut shredders, also known as straight-cut or
spaghetti-cut, slice the paper into long, thin strips but are not considered secure. Cross-cut
shredders provide more security by cutting paper vertically and horizontally into confetti-like
pieces.
Smartphone – See pocket/handheld mobile devices.
Social Engineering — The act of manipulating people into performing actions or divulging
confidential information. While similar to a confidence trick or simple fraud, the term typically
applies to trickery or deception for the purpose of information gathering, fraud, or computer system
access; in most cases the attacker never comes face-to-face with the victim.
Software Patch — A piece of software designed to fix problems with, or update, a computer
program or its supporting data. This includes fixing security vulnerabilities and other bugs and
improving the usability or performance. Though meant to fix problems, poorly designed patches
can sometimes introduce new problems. As such, patches should be installed in a test environment
prior to being installed in a live, operational system. Patches often can be found in multiple
locations but should be retrieved only from sources agreed upon through organizational policy.
State and Federal Agency User Agreement — A written agreement that each CSA or SIB Chief
shall execute with the FBI CJIS Division stating their willingness to demonstrate conformance
with the FBI CJIS Security Policy prior to the establishment of connectivity between
organizations. This agreement includes the standards and sanctions governing use of CJIS
systems, as well as verbiage to allow the FBI to periodically audit the CSA as well as to allow the
FBI to penetration test its own network from the CSA’s interfaces to it.
State Compact Officer — The representative of a state that is party to the National Crime
Prevention and Privacy Compact, and is the chief administrator of the state's criminal history
record repository or a designee of the chief administrator who is a regular full-time employee of
the repository.
State Identification Bureau (SIB) — The state agency with the responsibility for the state’s
fingerprint identification services.
State Identification Bureau (SIB) Chief — The SIB Chief is the designated manager of state’s
SIB. If both state fingerprint identification services and CJIS systems control are managed within
the same state agency, the SIB Chief and CSO may be the same person.
State of Residency – A state of residency is the state in which an individual claims and can provide
documented evidence as proof of being his/her permanent living domicile. CJIS Systems Officers
have the latitude to determine what documentation constitutes acceptable proof of residency.
Symmetric Encryption — A type of encryption where the same key is used to encrypt and decrypt
a message. Symmetric encryption is also known as secret key encryption.
System — Refer to connections to the FBI’s criminal justice information repositories and the
equipment used to establish said connections. In the context of CJI, this usually refers to
applications and all interconnecting infrastructure required to use those applications that process
CJI.
Tablet Devices – Tablet devices are mobile devices with a limited feature operating system (e.g.
iOS, Android, Windows RT, etc.). Tablets typically consist of a touch screen without a
permanently attached keyboard intended for transport via vehicle mount or portfolio-sized carry
case but not on the body. This definition does not include pocket/handheld devices (e.g.
smartphones) or mobile devices with full-featured operating systems (e.g. laptops).
Terminal Agency Coordinator (TAC) — Serves as the point-of-contact at the local agency for
matters relating to CJIS information access. A TAC administers CJIS systems programs within
the local agency and oversees the agency’s compliance with CJIS systems policies.
Wireless Access Point – A wireless access point is a device that logically connects a wireless
client device to an organization’s enterprise network which processes unencrypted CJI.
Wireless (WiFi) Hotspot – A wireless (WiFi) hotspot is a zone or area within a fixed location
allowing wireless connectivity to the Internet typically through a wired connection. Hotspots are
typically available in public areas such as airports, hotels and restaurants.
User Certificate (user-based) – Digital certificates that are unique and issued to individuals by a
CA. Though not always required to do so, these specific certificates are often embedded on smart
cards or other external devices as a means of distribution to specified users. This certificate is used
when individuals need to prove their identity during the authentication process.
Virtual Escort – Authorized personnel who actively monitor a remote maintenance session on
Criminal Justice Information (CJI)-processing systems. The escort must have the ability to end the
session at any time deemed necessary to ensure the protection and integrity of CJI at all times.
Virtual Machine (VM) – See Guest Operating System
Virtualization — Refers to a methodology of dividing the resources of a computer (hardware and
software) into multiple execution environments, by applying one or more concepts or technologies
such as hardware and software partitioning, time-sharing, partial or complete machine simulation
or emulation allowing multiple operating systems, or images, to run concurrently on the same
hardware.
Voice over Internet Protocol (VoIP) — A set of software, hardware, and standards designed to
make it possible to transmit voice over packet switched networks, either an internal Local Area
Network, or across the Internet.

APPENDIX B ACRONYMS
Acronym

Term

AA

Advanced Authentication

AC

Agency Coordinator

ACL

Access Control List

AES

Advanced Encryption Standard

AP

Access Point

APB

Advisory Policy Board

BD-ADDR

Bluetooth-Enabled Wireless Devices and Addresses

BYOD

Bring Your Own Device

CAD

Computer-Assisted Dispatch

CAU

CJIS Audit Unit

CFR

Code of Federal Regulations

CGA

Contracting Government Agency

CHRI

Criminal History Record Information

CJA

Criminal Justice Agency

CJI

Criminal Justice Information

CJIS

Criminal Justice Information Services

ConOps

Concept of Operations

CSA

CJIS Systems Agency

CSIRC

Computer Security Incident Response Capability

CSO

CJIS Systems Officer

DAA

Designated Approving Authority

DoJ

Department of Justice

DoJCERT

DoJ Computer Emergency Response Team

FBI

Federal Bureau of Investigation

FIPS

Federal Information Processing Standards

FISMA

Federal Information Security Management Act

FOIA

Freedom of Information Act

FOUO

For Official Use Only

HTTP

Hypertext Transfer Protocol

IAFIS

Integrated Automated Fingerprint Identification System

IDS

Intrusion Detection System

III

Interstate Identification Index

IP

Internet Protocol

IPS

Intrusion Prevention System

IPSEC

Internet Protocol Security

ISA

Interconnection Security Agreement

ISO

Information Security Officer

IT

Information Technology

LASO

Local Agency Security Officer

LEEP

Law Enforcement Enterprise Portal

LMR

Land Mobile Radio

MAC

Media Access Control

MCA

Management Control Agreement

MDM

Mobile Device Management

MITM

Man-in-the-Middle

MOU

Memorandum of Understanding

NCIC

National Crime Information Center

NCJA

Noncriminal Justice Agency

NICS

National Instant Criminal Background Check System

NIST

National Institute of Standards and Technology

NSA

National Security Agency

OMB

Office of Management and Budget

ORI

Originating Agency Identifier

OTP

One-time Password

PBX

Private Branch Exchange

PDA

Personal Digital Assistant

PII

Personally Identifiable Information

PIN

Personal Identification Number

PKI

Public Key Infrastructure

POC

Point-of-Contact

PSTN

Public Switched Telephone Network

QA

Quality Assurance

QoS

Quality of Service

RF

Radio Frequency

SA

Security Addendum

SCO

State Compact Officer

SIB

State Identification Bureau

SIG

Special Interest Group

SP

Special Publication

SPRC

Security Policy Resource Center

SSID

Service Set Identifier

TAC

Terminal Agency Coordinator

TLS

Transport Layer Security

VLAN

Virtual Local Area Network

VM

Virtual Machine

VoIP

Voice Over Internet Protocol

VPN

Virtual Private Network

WEP

Wired Equivalent Privacy

WLAN

Wireless Local Area Network

WPA

Wi-Fi Protected Access

APPENDIX C NETWORK TOPOLOGY DIAGRAMS
Network diagrams, i.e. topological drawings, are an essential part of solid network security.
Through graphical illustration, a comprehensive network diagram provides the “big picture” –
enabling network managers to quickly ascertain the interconnecting nodes of a network for a
multitude of purposes, including troubleshooting and optimization. Network diagrams are integral
to demonstrating the manner in which each agency ensures criminal justice data is afforded
appropriate technical security protections and is protected during transit and at rest.
The following diagrams, labeled Appendix C.1-A through C.1-D, are examples for agencies to
utilize during the development, maintenance, and update stages of their own network diagrams.
By using these example drawings as a guideline, agencies can form the foundation for ensuring
compliance with Section 5.7.1.2 of the CJIS Security Policy.
The purpose for including the following diagrams in this Policy is to aid agencies in their
understanding of diagram expectations and should not be construed as a mandated method for
network topologies. It should also be noted that agencies are not required to use the identical icons
depicted in the example diagrams and should not construe any depiction of a particular vendor
product as an endorsement of that product by the FBI CJIS Division.
Appendix C.1-A is a conceptual overview of the various types of agencies that can be involved in
handling of CJI, and illustrates several ways in which these interconnections might occur. This
diagram is not intended to demonstrate the level of detail required for any given agency’s
documentation, but it provides the reader with some additional context through which to digest the
following diagrams. Take particular note of the types of network interfaces in use between
agencies, in some cases dedicated circuits with encryption mechanisms, and in other cases VPNs
over the Internet. This diagram attempts to show the level of diversity possible within the law
enforcement community. These diagrams in no way constitute a standard for network engineering,
but rather, for the expected quality of documentation.
The next three topology diagrams, C.1-B through C.1-D, depict conceptual agencies. For C.1-B
through C.1-D, the details identifying specific “moving parts” in the diagrams by manufacturer
and model are omitted, but it is expected that any agencies producing such documentation will
provide diagrams with full manufacturer and model detail for each element of the diagram. Note
that the quantities of clients should be documented in order to assist the auditor in understanding
the scale of assets and information being protected.
Appendix C.1-B depicts a conceptual state law enforcement agency’s network topology and
demonstrates a number of common technologies that are in use throughout the law enforcement
community (some of which are compulsory per CJIS policy, and some of which are optional)
including Mobile Broadband cards, VPNs, Firewalls, Intrusion Detection Devices, VLANs, and
so forth. Note that although most state agencies will likely have highly-available configurations,
the example diagram shown omits these complexities and only shows the “major moving parts”
for clarity but please note the Policy requires the logical location of all components be shown. The
level of detail depicted should provide the reader with a pattern to model future documentation
from, but should not be taken as network engineering guidance.
Appendix C.1-C depicts a conceptual county law enforcement agency. A number of common
technologies are presented merely to reflect the diversity in the community, including proprietary

Packet-over-RF infrastructures and advanced authentication techniques, and to demonstrate the
fact that agencies can act as proxies for other agencies.
Appendix C.1-D depicts a conceptual municipal law enforcement agency, presumably a small one
that lacks any precinct-to-patrol data communications. This represents one of the smallest designs
that could be assembled that, assuming all other details are properly considered, would meet the
criteria for Section 5.7.1.2. This diagram helps to demonstrate the diversity in size that agencies
handling criminal justice data exhibit.

Figure C-1-A Overview: Conceptual Connections Between Various Agencies

Overview: Conceptual Connections Between Various Agencies
State Law Enforcement (L.E.) Agency
State L.E.
Workstation

Web App Hosted By
State Via Private Circuit
CAD
CAD Client
Client

CAD Client w/
TLS Connector

Authentication
Server
State Core
Network

Municipal L.E.
Workstation

Web
Web Browser
Browser

Web Server
w/ TLS

Encryption
Mechanism

Municipal
Core
Network

CAD
System

Extranet
Router

Firewall
+ VPN

Internet
Router

Firewall
Internet
Router

Dedicated Circuit
Extranet
Router

Small Municipal L.E. Agency 1

Internet
CAD Client w/
TLS Connector
Web App Hosted By
State Via VPN

Dedicated Circuit

Large Municipal L.E. Agency 1

Encryption
Mechanism
CAD
CAD Client
Client

Municipal L.E.
Workstation
Municipal
Core
Network

Web
Web Browser
Browser

Internet
Router

Dedicated Circuit
Private
DialUp Pool

Firewall
+ VPN

Encryption
Mechanism

Border
Router

TLS Web App Hosted
By State Via Dial-Up
Encryption
Mechanism

Firewall
+ VPN
FBI / CJIS
Core Network
Extranet
Router

Cabinet Number

HKP

48V

GSP

Extranet
Router

HKP

48V

GSP

Remote

Attention

An CJIS
Information
System

CAD
System

FBI CJIS Division
FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION
TLS CONNECTION

Figure C-1-B Conceptual Topology Diagram for a State Law Enforcement Agency

Conceptual Topology Diagram For A State Law Enforcement Agency
Internet

Dedicated
Circuit To FBI

State WAN

Mobile
BroadBand
Card + Service

Squad Car
Laptop w/
Advanced
Authentication
(A.A.) (275)

Intrusion
Detection
Device

Intranet
Router

CAD
CAD Client
Client

VPN Tunnels Via
Internet To Counties /
Municipalities

Encryption
Mechanism

Router / Firewall / VPN,
FIPS 140-2 Compliant

Ethernet Switch
1

2

3

4

5

6

7

8

9

10

11

13

12

14

15

16

17

18

19

20

21

22

23

Catalyst 2960 SERIES

24

1X

11X

13X

23X

2X

12X

14X

24X

SYST
RPS
MASTR
STAT
DUPLX
SPEED

1

MODE

2

Law
Enforcement
Workstation
VLAN

Web
Servers
VLAN

State L.E.
Workstation
(125)
Other
Department
VLAN

General
Infrastructure
VLAN
A.A.
Authentication
Server

CAD System
with CJIS
Interface +128Bit TLS

Web
Web Browser
Browser

TLS Web
Server

CAD Client
w/ A.A.

Dedicated
Circuits To
Municipalities

Extranet
Router

VLAN
Membership
Through
VPN Via
Internet

FIPS 140-2
VPN Client

Dedicated
Circuits To
Counties

TLS Web
App.

Web
Web Browser
Browser

CAD
CAD Client
Client

Other
Department
Workstation (60)

Police Cruiser VLAN

TLS Web App.

CAD Client
State Law Enforcement Agency

FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION

Figure C-1-C Conceptual Topology Diagram for a County Law Enforcement Agency

Conceptual Topology Diagram For A County Law Enforcement Agency

Internet
Router

Dedicated
Circuits To
Municipalities

Dedicated
Circuit To
State

Internet

Intrusion
Detection
Device

Extranet
Router

VPN Tunnels To
Municipalities Via
Internet

Encryption
Mechanism
Router / Firewall / VPN,
FIPS 140-2 Compliant

Proprietary
Packet / RF
Card + Built-in
FIPS 140-2
Encryption

Packet / RF
Transcievers +
FIPS 140-2
Encryption

Ethernet Switch
1

2

3

4

5

6

7

8

9

10

11

13

12

14

15

16

17

18

19

20

23

Catalyst 2960 SERIES

24

13X

23X

14X

24X

1

2

Other
Department
VLAN

Police Cruiser VLAN
Web
Web Browser
Browser
Web
Web Browser
Browser

CAD Client
w/ A.A.

22

11X

12X

County L.E.
Workstation
(6)

Squad Car
Laptop w/
A.A. (4)

CAD
CAD Client
Client

21

1X

2X

SYST
RPS
MASTR
STAT
DUPLX
SPEED
MODE

Law
Enforcement
Workstation
VLAN

TLS Web App.
Hosted By State
+A.A.

TLS Web App.
Hosted By State

CAD
CAD Client
Client

General
Infrastructure
VLAN
A.A.
Authentication
Server

CAD System
with CJIS
Interface +128Bit TLS

Other
Department
Workstation (10)

CAD Client
County Law Enforcement Agency

FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION

Figure C-1-D Conceptual Topology Diagram for a Municipal Law Enforcement Agency

Conceptual Topology Diagram For A Municipal Law Enforcement Agency
Dedicated
Circuit To
State

Internet

Internet
Router

Extranet
Router

VPN Tunnels Via
Internet To County

Encryption
Mechanism
Router / Firewall / VPN,
FIPS 140-2 Compliant

Intrusion
Detection
Device

Ethernet Switch
1

Law
Enforcement
Workstation
VLAN

2

3

4

5

6

7

8

9

10

11

TLS Web App.
Hosted By State
+ A.A.

14

15

16

17

18

19

20

21

22

23

Catalyst 2960 SERIES

24

11X

13X

23X

12X

14X

24X

1

2

Other
Department
VLAN

Municipal L.E.
Workstation (3)

Web
Web Browser
Browser

13

12

1X

2X

SYST
RPS
MASTR
STAT
DUPLX
SPEED
MODE

Other
Department
Workstation (11)

CAD
CAD Client
Client

CAD Client to
County CAD
System + 128-bit
TLS +A.A.
Municipal Law Enforcement Agency

FIPS 140-2 COMPLIANT ENCRYPTION
STANDARD CONNECTION

APPENDIX D SAMPLE INFORMATION EXCHANGE
AGREEMENTS
D.1 CJIS User Agreement
CRIMINAL JUSTICE INFORMATION SERVICES (CJIS)
SYSTEMS USER AGREEMENT
The FBI CJIS Division provides state-of-the-art identification and information services
to the local, state, tribal, federal, and international criminal justice communities, as well as the
noncriminal justice community, for licensing and employment purposes. These services are
administered and maintained by the FBI CJIS Division and managed in cooperation with the CJIS
Systems Agency (CSA) and its administrator for CJIS data, the CJIS Systems Officer (CSO). The
CJIS Systems include, but are not limited to: the Interstate Identification Index (III); National
Crime Information Center (NCIC); Uniform Crime Reporting (UCR), whether summary or
incident-based reporting to the National Incident-Based Reporting System; Fingerprint
Identification Record System; Law Enforcement National Data Exchange (N-DEx); Law
Enforcement Enterprise Portal; and the National Instant Criminal Background Check System
(NICS).
The FBI CJIS Division provides the following services to its users, as applicable:
1. Operational, technical, and investigative assistance.
2. Telecommunication lines to state, federal, and regulatory interfaces.
3. Legal and legislative review of matters pertaining to all CJIS Systems.
4. Timely information on all aspects of all CJIS Systems and other related programs by
means of operating manuals, code manuals, technical and operational updates, various
newsletters, information letters, frequently asked questions, and other relevant
documents.
5. Training assistance and up-to-date materials provided to each CSO, NICS Point of
Contact (POC), state Compact Officer, State Administrator, Information Security Officer
(ISO), and other appropriate personnel.
6. Ongoing assistance to Systems’ users through meetings and briefings with the CSOs,
State Administrators, Compact Officers, ISOs, and NICS State POCs to discuss
operational and policy issues.
7. Advisory Process through which authorized users have input as to the policies and
procedures governing the operation of CJIS programs.
8. National Crime Prevention and Privacy Compact Administrative Office through which
states and other authorized users may submit issues concerning the noncriminal justice
use of the III System.
9. Annual NICS Users Conference.
10. Audit.
11. Staff research assistance.
PART 1
The purpose behind a designated CSO is to unify responsibility for Systems user
discipline and to ensure adherence to established procedures and policies within each signatory
state/territory/tribal agency and by each federal user. This agreement outlines the responsibilities
of each CSO as they relate to all CJIS Systems and other related CJIS administered programs.
These individuals are ultimately responsible for planning necessary hardware, software, funding,
and training for access to all CJIS Systems.
To ensure continued access as set forth above, the CSA agrees to adhere to all
applicable CJIS policies including, but not limited to, the following:
1. The signatory state/tribal agency will provide fingerprints that meet submission criteria for
all qualifying arrests. In addition, states/tribal agencies will make their records available
for interstate exchange for criminal justice and other authorized purposes unless restricted
by state/tribal law, and, where applicable, continue to move toward participation in the III
and, upon ratification of the National Crime Prevention and Privacy Compact, the National
Fingerprint File.
2. Appropriate and reasonable quality assurance procedures; e.g., hit confirmation, audits for
record timeliness, and validation, must be in place to ensure that only complete, accurate,
and valid information is maintained in the CJIS Systems.
3. Biannual file synchronization of information entered into the III by participating states.
4. Security - Each agency is responsible for appropriate security measures as applicable to
physical security of terminals and telecommunication lines; personnel security to include
background screening requirements; technical security to protect against unauthorized use;
data security to include III use, dissemination, and logging; and security of criminal history

records. Additionally, each CSO must ensure that all agencies establish an information
security structure that provides for an ISO and complies with the CJIS Security Policy.
5. Audit - Each agency shall be responsible for complying with all audit requirements for use
of CJIS Systems. Each CSO is responsible for completing a triennial audit of all agencies
with access to CJIS Systems through the CSO’s lines.
6. Training - Each agency shall be responsible for training requirements, including
compliance with operator training mandates.
7. Integrity of the Systems - Each agency shall be responsible for maintaining the integrity of
the system in accordance with FBI CJIS Division/state/federal/tribal policies to ensure only
authorized terminal access; only authorized transaction submission; and proper handling
and dissemination of CJI. Each agency shall also be responsible for computer security
incident reporting as required by the CJIS Security Policy.
The following documents are incorporated by reference and made part of this
agreement for CSA users:
1. Bylaws for the CJIS Advisory Policy Board and Working Groups.
2. CJIS Security Policy.
3. Interstate Identification Index Operational and Technical Manual, National Fingerprint
File Operations Plan, NCIC 2000 Operating Manual, UCR Handbook-NIBRS Edition,
and National Incident-Based Reporting System Volumes 1, 2, and 4.
4. National Crime Prevention and Privacy Compact, 42 United States Code (U.S.C.)
§14616.
5. NCIC Standards and UCR Standards, as recommended by the CJIS Advisory Policy
Board.
6. The National Fingerprint File Qualification Requirements.
7. Title 28, Code of Federal Regulations, Parts 20 and 25, §50.12, and Chapter IX.
8. Electronic Fingerprint Transmission Specifications.

9. Other relevant documents, to include: NCIC Technical and Operational Updates, CJIS
Information Letters, NICS User Manual, NICS Interface Control Document.
10. Applicable federal, state, and tribal laws and regulations.
PART 2
Additionally, there are authorized federal regulatory recipients and other authorized
users that provide electronic fingerprint submissions through a CJIS Wide Area Network (WAN)
connection (or other approved form of electronic connection) to the CJIS Division that are required
to comply with the following CJIS policies:
1. The authorized user will provide fingerprints that meet submission criteria and apply
appropriate and reasonable quality assurance procedures.
2. Security - Each agency is responsible for appropriate security measures as applicable to
physical security of communication equipment; personnel security to include background
screening requirements; technical security to protect against unauthorized use; and security
of criminal history records.
3. Audit - Each authorized user shall be responsible for complying with all audit requirements
for CJIS Systems. Additionally, each authorized user is subject to a triennial audit by the
CJIS Division Audit staff.
4. Training - Each authorized user receiving criminal history record information shall be
responsible for training requirements, including compliance with proper handling of
criminal history records.
The following documents are incorporated by reference and made part of this
agreement for non-CSA authorized users:
1. CJIS Security Policy.
2. National Crime Prevention and Privacy Compact, 42 U.S.C. §14616.
3. Title 28, Code of Federal Regulations, Parts 20 and 25, § 50.12, and Chapter IX.
4. Other relevant documents, to include CJIS Information Letters.

5. Applicable federal, state, and tribal laws and regulations.
GENERAL PROVISIONS
Funding:
Unless otherwise agreed in writing, each party shall bear its own costs in relation to
this agreement. Expenditures will be subject to federal and state budgetary processes
and availability of funds pursuant to applicable laws and regulations. The parties
expressly acknowledge that this in no way implies that Congress will appropriate funds
for such expenditures.
Termination:
1. All activities of the parties under this agreement will be carried out in accordance to the
above-described provisions.
2. This agreement may be amended or terminated by the mutual written consent of the parties
authorized representatives.
3. Either party may terminate this agreement upon 30-days written notification to the other
party. Such notice will be the subject of immediate consultation by the parties to decide
upon the appropriate course of action. In the event of such termination, the following rules
apply:
a. The parties will continue participation, financial or otherwise, up to the effective
date of termination.
b. Each party will pay the costs it incurs as a result of termination.
c. All information and rights therein received under the provisions of this agreement
prior to the termination will be retained by the parties, subject to the provisions of
this agreement.

ACKNOWLEDGMENT AND CERTIFICATION
As a CSO or CJIS WAN Official (or other CJIS authorized official), I hereby
acknowledge the duties and responsibilities as set out in this agreement. I acknowledge that these
duties and responsibilities have been developed and approved by CJIS Systems users to ensure the
reliability, confidentiality, completeness, and accuracy of all information contained in, or obtained
by means of, the CJIS Systems. I further acknowledge that failure to comply with these duties and
responsibilities may result in the imposition of sanctions against the offending state/agency; other
federal, tribal, state, and local criminal justice users; and approved noncriminal justice users with
System access, whether direct or indirect. The Director of the FBI (or the National Crime
Prevention and Privacy Compact Council), may approve sanctions to include the termination of
CJIS services.
I hereby certify that I am familiar with all applicable documents that are made part of
this agreement and to all applicable federal and state laws and regulations relevant to the receipt
and dissemination of documents provided through the CJIS Systems.
This agreement is a formal expression of the purpose and intent of both parties and is
effective when signed. It may be amended by the deletion or modification of any provision
contained therein, or by the addition of new provisions, after written concurrence of both parties.
The “Acknowledgment and Certification” is being executed by the CSO or CJIS WAN Official
(or other CJIS authorized official) in both an individual and representative capacity.
Accordingly, this agreement will remain in effect after the CSO or CJIS WAN Official (or other
CJIS authorized official) vacates his/her position or until it is affirmatively amended or rescinded
in writing. This agreement does not confer, grant, or authorize any rights, privileges, or
obligations to any third party.

SYSTEMS USER AGREEMENT
Please execute either Part 1 or Part 2
PART 1
____________________________________

Date: ____________

CJIS Systems Officer
______________________________________________________________________________
Printed Name/Title
CONCURRENCE OF CSA HEAD:
____________________________________

Date: ____________

CSA Head
______________________________________________________________________________
Printed Name/Title
PART 2
____________________________________

Date: ____________

CJIS WAN Official (or other CJIS Authorized Official)
______________________________________________________________________________
Printed Name/Title
CONCURRENCE OF CJIS WAN AGENCY HEAD:
____________________________________

Date: ____________

CJIS WAN Agency Head
______________________________________________________________________________
Printed Name/Title

FBI CJIS DIVISION:
____________________________________

Date: ____________

[Name]
Assistant Director
FBI CJIS Division
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt CJIS-5.6.txt strip-pages The FBI Designated Federal Officer should be notified when a CSO or other CJIS
WAN/authorized Official vacates his/her position. The name and telephone number of the
Acting CSO or other CJIS WAN/authorized Official, and when known, the name and telephone
number of the new CSO or other CJIS WAN/authorized Official, should be provided. Revised:
D.2 Management Control Agreement

Management Control Agreement
Pursuant to the CJIS Security Policy, it is agreed that with respect to administration of that
portion of computer systems and network infrastructure interfacing directly or indirectly with the
state network (Network Name) for the interstate exchange of criminal history/criminal justice
information, the (Criminal Justice Agency) shall have the authority, via managed control, to set,
maintain, and enforce:
(1) Priorities.
(2) Standards for the selection, supervision, and termination of personnel access to Criminal
Justice Information (CJI).
(3) Policy governing operation of justice systems, computers, access devices, circuits, hubs,
routers, firewalls, and any other components, including encryption, that comprise and
support a telecommunications network and related criminal justice systems to include but
not limited to criminal history record/criminal justice information, insofar as the
equipment is used to process or transmit criminal justice systems information
guaranteeing the priority, integrity, and availability of service needed by the criminal
justice community.
(4) Restriction of unauthorized personnel from access or use of equipment accessing the
State network.
(5) Compliance with all rules and regulations of the (Criminal Justice Agency) Policies and
CJIS Security Policy in the operation of all information received.
“…management control of the criminal justice function remains solely with the Criminal Justice
Agency.” Section 5.1.1.4
This agreement covers the overall supervision of all (Criminal Justice Agency) systems,
applications, equipment, systems design, programming, and operational procedures associated
with the development, implementation, and maintenance of any (Criminal Justice Agency) system
to include NCIC Programs that may be subsequently designed and/or implemented within the
(Criminal Justice Agency).

__________________
John Smith, CIO
Any State Department of Administration

_____________
Date

__________________
Joan Brown, CIO
(Criminal Justice Agency)

_____________
Date

D.3 Noncriminal Justice Agency Agreement & Memorandum of
Understanding
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE FEDERAL BUREAU OF INVESTIGATION
AND
(Insert Name of Requesting Organization)
FOR
THE ESTABLISHMENT AND ACCOMMODATION OF
THIRD-PARTY CONNECTIVITY TO THE
CRIMINAL JUSTICE INFORMATION SERVICES DIVISION'S WIDE AREA NETWORK

1. PURPOSE: This Memorandum of Understanding (MOU) between the Federal Bureau of
Investigation (FBI) and (insert requesting organization’s name), hereinafter referred to as the
"parties," memorializes each party's responsibilities with regard to establishing connectivity to
records services accessible via the Wide Area Network (WAN) of the FBI's Criminal Justice
Information Services (CJIS) Division.
2. BACKGROUND: The requesting organization, (insert requesting organization’s name),
being approved for access to systems of records accessible via the CJIS WAN, desires connectivity
to the CJIS WAN or via a secure Virtual Private Network (VPN) Connection (Internet) to the CJIS
WAN. The CJIS Division has created a framework for accommodating such requests based on the
type of connection.
In preparing for such non-CJIS-funded connectivity to the CJIS WAN, the parties plan to
acquire, configure, and place needed communications equipment at suitable sites and to make
electronic connections to the appropriate systems of records via the CJIS WAN.
To ensure that there is a clear understanding between the parties regarding their respective
roles in this process, this MOU memorializes each party's responsibilities regarding the
development, operation, and maintenance of third-party connectivity to the CJIS WAN. Unless
otherwise contained in an associated contract, the enclosed terms apply. If there is a conflict
between terms and provisions contained in both the contract and this MOU, the contract will
prevail.
3. AUTHORITY: The FBI is entering into this MOU under the authority provided by Title 28,
United States Code (U.S.C.), Section 534; 42 U.S.C. § 14616; and/or Title 28, Code of Federal
Regulations, Part 906.
4. SCOPE:
a. The CJIS Division agrees to:
i. Provide the requesting organization with a "CJIS WAN Third-Party Connectivity
Package" that will detail connectivity requirements and options compatible with the
CJIS Division's WAN architecture upon receipt of a signed nondisclosure
statement.
ii. Configure the requesting organization’s connection termination equipment suite
at Clarksburg, West Virginia, and prepare it for deployment or shipment under the
CJIS WAN option. In the Secure VPN arrangement only, the third party will
develop, configure, manage, and maintain its network connectivity to its preferred
service provider.
iii. Work with the requesting organization to install the connection termination
equipment suite and verify connectivity.
iv. Perform installation and/or routine maintenance on the requesting organization’s
third-party dedicated CJIS WAN connection termination equipment after
coordinating with the requesting organization’s designated point of contact (POC)
and during a time when the CJIS Division's technical personnel are near the
requesting organization’s site.
v. Perform periodic monitoring and troubleshooting of the requesting
organization’s CJIS WAN connection termination equipment. Software patches
will be maintained on the dedicated CJIS WAN connected network equipment only.
Under the Secure VPN option, no availability or data thru-put rates will be
guaranteed.
vi. Provide 24 hours a day, 7 days a week uninterrupted monitoring from the CJIS
Division’s Network Operations Center.
vii. Provide information regarding potential hardware end-of-life replacement
cycles to the requesting organization for its budgeting purposes.
viii. Maintain third-party dedicated CJIS WAN connection termination equipment
as if in the CJIS Division's operational environment.
ix. Update the appropriate software on the requesting organization’s dedicated
connection termination equipment connected to the CJIS WAN (i.e., Cisco
Internetwork Operating System, SafeNet frame relay encryptor firmware, etc.)
pursuant to the requesting organization's authorized maintenance contracts.
x. Provide a POC and telephone number for MOU-related issues.
b. The (insert requesting organization’s name) agrees to:
i. Coordinate requests for third-party connectivity to the CJIS WAN or the Secure
VPN with the CJIS Division's POC.
ii. Purchase hardware and software that are compatible with the CJIS WAN.
iii. Pay for the telecommunications infrastructure that supports its connection to the
CJIS WAN or Secure VPN.
iv. Maintain telecommunication infrastructure in support of Secure VPN
connectivity.
v. Provide any/all hardware and software replacements and upgrades as mutually
agreed to by the parties.
vi. Pay for all telecommunication requirements related to its connectivity.

vii. Provide required information for dedicated service relating to Data Link
Connection Identifiers, Circuit Identifier, Permanent Virtual Circuit Identifiers,
Local Exchange Carrier Identifier, POC, location, etc., as determined by the parties.
viii. Transport the CJIS WAN connection termination equipment suite to the CJIS
Division for configuration and preparation for deployment under the dedicated
service option.
ix. Provide registered Internet Protocol information to be used by the requesting
organization’s system to the CJIS Division.
x. Provide the CJIS Division with six months advance notice or stated amount of
time for testing activities (i.e., disaster recovery exercises).
xi. Provide the CJIS Division with applicable equipment maintenance contract
numbers and level of service verifications needed to perform software upgrades on
connection termination equipment.
xii. Provide the CJIS Division with applicable software upgrade and patch images
(or information allowing the CJIS Division to access such images).
xiii. Transport only official, authorized traffic over the Secure VPN.
xiv. Provide a POC and telephone number for MOU-related issues.
5. FUNDING: There are no reimbursable expenses associated with this level of support. Each
party will fund its own activities unless otherwise agreed to in writing. This MOU is not an
obligation or commitment of funds, nor a basis for transfer of funds, but rather is a basic statement
of understanding between the parties hereto of the nature of the relationship for the connectivity
efforts. Unless otherwise agreed to in writing, each party shall bear its own costs in relation to this
MOU. Expenditures by each party will be subject to its budgetary processes and to the availability
of funds and resources pursuant to applicable laws, regulations, and policies. The parties expressly
acknowledge that the above language in no way implies that Congress will appropriate funds for
such expenditures.
6. SETTLEMENT OF DISPUTES: Disagreements between the parties arising under or relating
to this MOU will be resolved only by consultation between the parties and will not be referred to
any other person or entity for settlement.

7. SECURITY: It is the intent of the parties that the actions carried out under this MOU will be
conducted at the unclassified level. No classified information will be provided or generated under
this MOU.
8. AMENDMENT, TERMINATION, ENTRY INTO FORCE, AND DURATION:
a. All activities of the parties under this MOU will be carried out in accordance with the
above - described provisions.
b. This MOU may be amended or terminated by the mutual written consent of the parties'
authorized representatives.
c. Either party may terminate this MOU upon 30-days written notification to the other
party. Such notice will be the subject of immediate consultation by the parties to decide
upon the appropriate course of action. In the event of such termination, the following rules
apply:
i. The parties will continue participation, financial or otherwise, up to the effective
date of the termination.
ii. Each party will pay the costs it incurs as a result of the termination.
iii. All information and rights therein received under the provisions of this MOU
prior to the termination will be retained by the parties, subject to the provisions of
this MOU.
9. FORCE AND EFFECT: This MOU, which consists of nine numbered sections, will enter into
effect upon signature of the parties and will remain in effect until terminated. The parties should
review the contents of this MOU annually to determine whether there is a need for the deletion,
addition, or amendment of any provision. This MOU is not intended, and should not be construed,
to create any right or benefit, substantive or procedural, enforceable at law or otherwise by any
third party against the parties, their parent agencies, the United States, or the officers, employees,
agents, or other associated personnel thereof.
The foregoing represents the understandings reached between the parties.

FOR THE FEDERAL BUREAU OF INVESTIGATION

________________________________

___________

[Name]

Date

Assistant Director
Criminal Justice Information Services Division

FOR THE (insert requesting organization name)

________________________________

___________

Date

D.4 Interagency Connection Agreement
CRIMINAL JUSTICE INFORMATION SERVICES (CJIS)
Wide Area Network (WAN) USER AGREEMENT
BY INTERIM REMOTE LATENT USERS
The responsibility of the FBI CJIS Division is to provide state-of-the-art
identification and information services to the local, state, federal, and international criminal justice
communities, as well as the civil community for licensing and employment purposes. The data
provided by the information systems administered and maintained by the FBI CJIS Division are
routed to and managed in cooperation with the designated interface agency official. This
information includes, but is not limited to, the Interstate Identification Index (III), National Crime
Information Center (NCIC), Uniform Crime Reporting (UCR)/National Incident-Based Reporting
System (NIBRS), and the Integrated Automated Fingerprint Identification System (IAFIS)
programs.
In order to fulfill this responsibility, the FBI CJIS Division provides the following
services to its users:


Operational, technical, and investigative assistance;



Telecommunications lines to local, state, federal and authorized interfaces;



Legal and legislative review of matters pertaining to IAFIS, CJIS WAN
and other related services;



Timely information on all aspects of IAFIS, CJIS WAN, and other related
programs by means of technical and operational updates, various
newsletters, and other relative documents;



Shared management through the CJIS Advisory Process and the Compact
Council;



Training assistance and up-to-date materials provided to each designated
agency official, and;



Audit.

The concept behind a designated interface agency official is to unify responsibility
for system user discipline and ensure adherence to system procedures and policies within each
interface agency. These individuals are ultimately responsible for planning necessary hardware,
software, funding, training, and the administration of policy and procedures including security and
integrity for complete access to CJIS related systems and CJIS WAN related data services by
authorized agencies.
The following documents and procedures are incorporated by reference and made
part of this agreement:


CJIS Security Policy;



Title 28, Code of Federal Regulations, Part 20;



Computer Incident Response Capability (CIRC);



Applicable federal and state laws and regulations.

To ensure continued access as set forth above, the designated interface agency agrees to adhere to
all CJIS policies, including, but not limited to, the following:
1. The signatory criminal agency will provide fingerprints for all qualifying arrests
either via electronic submission or fingerprint card that meet submission
criteria. In addition, the agency will make their records available for interstate
exchange for criminal justice and other authorized purposes.
2. The signatory civil agency with legislative authority will provide all qualifying
fingerprints via electronic submission or fingerprint card that meet submission
criteria.
3. Appropriate and reasonable quality assurance procedures must be in place to
ensure that only complete, accurate, and valid information is maintained in the
system.
4. Security - Each agency is responsible for appropriate security measures as
applicable to physical security of terminals and telecommunications lines;
Interim Distributed Imaging System (IDIS) equipment shall remain stand-alone
devices and be used only for authorized purposes; personnel security to meet
background screening requirements; technical security to protect against
unauthorized use; data security, dissemination, and logging for audit purposes;
and actual security of criminal history records. Additionally, each agency must
establish an information security structure that provides for an Information
Security Officer (ISO) or a security point of contact.
5. Audit - Each agency shall be responsible for complying with the appropriate audit
requirements.
6. Training - Each agency shall be responsible for training requirements, including
compliance with training mandates.
7. Integrity of the system shall be in accordance with FBI CJIS Division and
interface agency policies. Computer incident reporting shall be implemented.
Until states are able to provide remote latent connectivity to their respective latent
communities via a state WAN connection, the CJIS Division may provide direct connectivity to
IAFIS via a dial-up connection or through the Combined DNA Index System (CODIS) and/or
National Integrated Ballistics Information Network (NIBIN) connections. When a state
implements a latent management system and is able to provide intrastate connectivity and
subsequent forwarding to IAFIS, this agreement may be terminated. Such termination notice will
be provided in writing by either the FBI or the state CJIS Systems Agency.
It is the responsibility of the local remote latent user to develop or acquire an IAFIS
compatible workstation. These workstations may use the software provided by the FBI or develop
their own software, provided it is IAFIS compliant.
The CJIS Division will provide the approved modem and encryptors required for
each dial-up connection to IAFIS. The CJIS Communication Technologies Unit will configure
and test the encryptors before they are provided to the user. Users requesting remote latent
connectivity through an existing CODIS and/or NIBIN connection must receive verification from
the FBI that there are a sufficient number of Ethernet ports on the router to accommodate the
request.
If at any time search limits are imposed by the CJIS Division, these individual
agency connections will be counted toward the total state allotment.

ACKNOWLEDGMENT AND CERTIFICATION
As a CJIS WAN interface agency official serving in the CJIS system, I hereby
acknowledge the duties and responsibilities as set out in this agreement. I acknowledge that these
duties and responsibilities have been developed and approved by CJIS system users in order to
ensure the reliability, confidentiality, completeness, and accuracy of all information contained in
or obtained by means of the CJIS system. I further acknowledge that a failure to comply with
these duties and responsibilities may subject our agency to various sanctions adopted by the CJIS
Advisory Policy Board and approved by the Director of the FBI. These sanctions may include the
termination of CJIS service.
As the designated CJIS WAN interface agency official serving in the CJIS system,
I hereby certify that I am familiar with the contents of the Title 28, Code of Federal Regulations,
Part 20; CJIS Security Policy; Computer Incident Response Capability; and applicable federal or
state laws and regulations applied to IAFIS and CJIS WAN Programs for the dissemination of
criminal history records for criminal and noncriminal justice purposes.
*___________________________________ ______________________________
Signature

CJIS WAN Agency Official

Print or Type

Date

CONCURRENCE OF FEDERAL/REGULATORY AGENCY HEAD OR STATE
CJIS SYSTEMS OFFICER (CSO):
*____________________________________
Signature
*____________________________________
Title

______________________________
Print or Type
__________
Date

State CSO

FBI CJIS DIVISION:
____________________________________
Signature – [Name]
Assistant Director

__________

Title

Date

CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt CJIS-5.6.txt strip-pages If there is a change in the CJIS WAN interface agency official, the FBI Designated Federal
Employee must be notified in writing 30 days prior to the change.
5/27/2004 UA modification reflects change in CTO title to CSO.

APPENDIX E SECURITY FORUMS AND ORGANIZATIONAL
ENTITIES
Online Security Forums / Organizational Entities
AntiOnline
Black Hat
CIO.com
CSO Online
CyberSpeak Podcast
FBI Criminal Justice Information Services Division (CJIS)
Forrester Security Forum
Forum of Incident Response and Security Teams (FIRST)
Information Security Forum (ISF)
Information Systems Audit and Control Association (ISACA)
Information Systems Security Association (ISSA)
Infosyssec
International Organization for Standardization (ISO)
International Information Systems Security Certification Consortium, Inc. (ISC) 2
Metasploit
Microsoft Developer Network (MSDN) Information Security
National Institute of Standards and Technology (NIST)
Open Web Application Security Project (OWASP)
SANS (SysAdmin, Audit, Network, Security) Institute
SC Magazine
Schneier.com
Security Focus
The Register
US Computer Emergency Response Team (CERT)
US DoJ Computer Crime and Intellectual Property Section (CCIPS)

APPENDIX F

SAMPLE FORMS

This appendix contains sample forms.

F.1 Security Incident Response Form
FBI CJIS DIVISION
INFORMATION SECURITY OFFICER (ISO)
SECURITY INCIDENT REPORTING FORM

NAME OF PERSON REPORTING THE INCIDENT: ______________________________
DATE OF REPORT: ____________________________ (mm/dd/yyyy)
DATE OF INCIDENT: __________________________ (mm/dd/yyyy)
POINT(S) OF CONTACT (Include Phone/Extension/Email): _________________________
___________________________________________________________________________
LOCATION(S) OF INCIDENT: ________________________________________________
INCIDENT DESCRIPTION: ___________________________________________________
___________________________________________________________________________
SYSTEM(S) AFFECTED: _____________________________________________________
___________________________________________________________________________
SYSTEM(S) AFFECTED (e.g. CAD, RMS, file server, etc.): ____________
___________________________________________________________________________
METHOD OF DETECTION: ___________________________________________________
ACTIONS TAKEN/RESOLUTION: _____________________________________________
___________________________________________________________________________
___________________________________________________________________________
Copies To:
George White

John C. Weatherly

(FBI CJIS Division ISO)

(FBI CJIS CSIRC POC)

1000 Custer Hollow Road

1000 Custer Hollow Road/Module D-2

Clarksburg, WV 26306-0102

Clarksburg, WV 26306-0102

(304) 625-5849

(304) 625-3660

[email protected]

[email protected]

APPENDIX G BEST PRACTICES
G.1 Virtualization
Virtualization
This appendix documents security considerations for implementing and operating virtual
environments that process, store, and/or transmit Criminal Justice Information.
The FBI CJIS ISO has fielded several inquiries from various states requesting guidance on
implementing virtual environments within their data centers. With the proliferation of virtual
environments across industry in general there is a realistic expectation that FBI CJIS Auditors will
encounter virtual environments during the upcoming year. Criminal Justice Agencies (CJAs) and
Noncriminal Justice Agencies (NCJAs) alike need to understand and appreciate the foundation of
security protection measures required for virtual environments.
From Microsoft’s Introduction to Windows Server 2008
http://www.microsoft.com/windowsserver2008/en/us/hyperv.aspx:
“Server virtualization, also known as hardware virtualization, is a hot topic in the
IT world because of the potential for serious economic benefits. Server
virtualization enables multiple operating systems to run on a single physical
machine as virtual machines (VMs). With server virtualization, you can consolidate
workloads across multiple underutilized server machines onto a smaller number of
machines. Fewer physical machines can lead to reduced costs through lower
hardware, energy, and management overhead, plus the creation of a more dynamic
IT infrastructure.”
From a trade publication, kernelthread.com
http://www.kernelthread.com/publications/virtualization/:
“Virtualization is a framework or methodology of dividing the resources of a
computer into multiple execution environments, by applying one or more concepts
or technologies such as hardware and software partitioning, time-sharing, partial
or complete machine simulation, emulation, quality of service, and many others.”
From an Open Source Software developer
http://www.kallasoft.com/pc-hardware-virtualization-basics/:
“Virtualization refers to virtualizing hardware in software, allowing multiple
operating systems, or images, to run concurrently on the same hardware. There are
two main types of virtualization software:

 “Type-1 Hypervisor, which runs ‘bare-metal’ (on top of the hardware)
 “Type-2 Hypervisor which requires a separate application to run within an
operating system

“Type1 hypervisors usually offer the best in efficiency, while Type-2 hypervisors
allow for greater support of hardware that can be provided by the operating system.
For the developer, power user, and small business IT professionals, virtualization
offers the same basic idea of collapsing multiple physical boxes into one. For
instance, a small business can run a web server and an Exchange server without
the need for two boxes. Developers and power users can use the ability to contain
different development environments without the need to modify their main
operating system. Big businesses can also benefit from virtualization by allowing
software maintenance to be run and tested on a separate image on hardware
without having to take down the main production system.”
Industry leaders and niche developers are bringing more products to market every day. The
following article excerpts, all posted during September 2008, on www.virtualization.com are
examples of industry offerings.
“Microsoft and Novell partnered together for joint virtualization solution.
Microsoft and Novell are announcing the availability of a joint virtualization
solution optimized for customers running mixed-source environments. The joint
offering includes SUSE Linux Enterprise Server configured and tested as an
optimized guest operating system running on Windows Sever 2008 Hyper-V, and is
fully support by both companies’ channel partners. The offering provides
customers with the first complete, fully supported and optimized virtualization
solution to span Windows and Linux environments.”
“Sun Microsystems today account the availability of Sun xVM Server software and
Sun xVM Ops Center 2.0, key components in its strategy. Sun also announced the
addition of comprehensive services and support for Sun xVM Server software and
xVM Ops Center 2.0 to its virtualization suite of services. Additionally, Sun
launched xVMserver.org, a new open source community, where developers can
download the first source code bundle for SunxVM Server software and contribute
to the direction and development of the product.”
“NetEx, specialist in high-speed data transport over TCP, today announced Vistual
HyperIP bandwidth optimization solutions for VMware environments that deliver
a threefold to tenfold increase in data replication performance. Virtual HyperIP is
a software-based Data Transport Optimizer that operates on the VMware ESX
server and boosts the performance of storage replication applications from vendors
such as EMC, NetApp, Symantec, IBM, Data Domain, and FalconStor. Virtual
HyperIP mitigates TCP performance issues that are common when moving data
over wide –area network (WAN) connections because of bandwidth restrictions,
latency due to distance and/or router hop counts, packet loss and network errors.
Like the company’s award-winning appliance-based HyperIP, Virtual HyperIP
eliminates these issues with an innovative software design developed specifically
to accelerate traffic over an IP based network.”
From several sources, particularly:
http://www.windowsecurity.com/articles/security-virutalization.html
http://csrc.nist.gov/publications/drafts/6--=64rev2/draft-sp800-64-Revision2.pdf
Virtualization provides several benefits:


Make better use of under-utilized servers by consolidating to fewer machines saving on
hardware, environmental costs, management, and administration of the server
infrastructure.



Legacy applications unable to run on newer hardware and/or operating systems can be
loaded into a virtual environment – replicating the legacy environment.



Provides for isolated portions of a server where trusted and untrusted applications can be
ran simultaneously – enabling hot standbys for failover.



Enables existing operating systems to run on shared memory multiprocessors.



System migration, backup, and recovery are easier and more manageable.

Virtualization also introduces several vulnerabilities:


Host Dependent.



If the host machine has a problem then all the VMs could potentially terminate.



Compromise of the host makes it possible to take down the client servers hosted on the
primary host machine.



If the virtual network is compromised then the client is also compromised.



Client share and host share can be exploited on both instances. Potentially this can lead to
files being copied to the share that fill up the drive.

These vulnerabilities can be mitigated by the following factors:


Apply “least privilege” technique to reduce the attack surface area of the virtual
environment and access to the physical environment.



Configuration and patch management of the virtual machine and host, i.e. Keep operating
systems and application patches up to date on both virtual machines and hosts.



Install the minimum applications needed on host machines.



Practice isolation from host and virtual machine.



Install and keep updated antivirus on virtual machines and the host.



Segregation of administrative duties for host and versions.



Audit logging as well as exporting and storing the logs outside the virtual environment.



Encrypting network traffic between the virtual machine and host IDS and IPS monitoring.



Firewall each virtual machine from each other and ensure that only allowed protocols will
transact.

G.2 Voice over Internet Protocol

Voice over Internet Protocol (VoIP)

Attribution:
The following information has been extracted from NIST Special Publication 800-58, Security
Considerations for Voice over IP Systems.
Definitions:
Voice over Internet Protocol (VoIP) – A set of software, hardware, and standards designed to make
it possible to transmit voice over packet switched networks, either an internal Local Area Network,
or across the Internet.
Internet Protocol (IP) - A protocol used for communicating data across a packet-switched
internetwork using the Internet Protocol Suite, also referred to as TCP/IP. IP is the primary
protocol in the Internet Layer of the Internet Protocol Suite and has the task of delivering
distinguished protocol datagrams (packets) from the source host to the destination host solely
based on their addresses.
Summary:
Voice over Internet Protocol (VoIP) has been embraced by organizations globally as an
addition to, or replacement for, public switched telephone network (PSTN) and private branch
exchange (PBX) telephone systems. The immediate benefits are alluring since the typical cost
to operate VoIP is less than traditional telephone services and VoIP can be installed in-line
with an organization’s existing Internet Protocol services. Unfortunately, installing a VoIP
network is not a simple “plug-and-play” procedure. There are myriad security concerns, cost
issues with new networking hardware requirements, and overarching quality of service (QoS)
factors that have to be considered carefully.
What are some of the advantages of VoIP?
a. Cost – a VoIP system is usually cheaper to operate than an equivalent office telephone
system with a Private Branch Exchange and conventional telephone service.
b. Integration with other services – innovative services are emerging that allow customers
to combine web access with telephone features through a single PC or terminal. For
example, a sales representative could discuss products with a customer using the
company’s web site. In addition, the VoIP system may be integrated with video across
the Internet, providing a teleconferencing facility.
What are some of the disadvantages of VoIP?
a. Startup cost – although VoIP can be expected to save money in the long run, the
initial installation can be complex and expensive. In addition, a single standard has
not yet emerged for many aspects of VoIP, so an organization must plan to support
more than one standard, or expect to make relatively frequent changes as the VoIP
field develops.
b. Security – the flexibility of VoIP comes at a price: added complexity in securing
voice and data. Because VoIP systems are connected to the data network, and share
many of the same hardware and software components, there are more ways for
intruders to attack a VoIP system than a conventional voice telephone system or
PBX.
VoIP Risks, Threats, and Vulnerabilities
This section details some of the potential threats and vulnerabilities in a VoIP environment,
including vulnerabilities of both VoIP phones and switches. Threat discussion is included
because the varieties of threats faced by an organization determine the priorities in securing
its communications equipment. Not all threats are present in all organizations. A
commercial firm may be concerned primarily with toll fraud, while a government agency
may need to prevent disclosure of sensitive information because of privacy or national
security concerns. Information security risks can be broadly categorized into the following
three types: confidentiality, integrity, and availability, (which can be remembered with the
mnemonic “CIA”). Additional risks relevant to switches are fraud and risk of physical
damage to the switch, physical network, or telephone extensions.
Packet networks depend for their successful operation on a large number of configurable
parameters: IP and MAC (physical) addresses of voice terminals, addresses of routers and
firewalls, and VoIP specific software such as Call Managers and other programs used to
place and route calls. Many of these network parameters are established dynamically every
time a network component is restarted, or when a VoIP telephone is restarted or added to
the network. Because there are so many places in a network with dynamically configurable
parameters, intruders have a wide array of potentially vulnerable points to attack.
Vulnerabilities described in this section are generic and may not apply to all systems, but
investigations by NIST and other organizations have found these vulnerabilities in a
number of VoIP systems. In addition, this list is not exhaustive; systems may have security
weaknesses that are not included in the list. For each potential vulnerability, a
recommendation is included to eliminate or reduce the risk of compromise.
Confidentiality and Privacy

Confidentiality refers to the need to keep information secure and private. For home
computer users, this category includes confidential memoranda, financial information, and
security information such as passwords. In a telecommunications switch, eavesdropping
on conversations is an obvious concern, but the confidentiality of other information on the
switch must be protected to defend against toll fraud, voice and data interception, and
denial of service attacks. Network IP addresses, operating system type, telephone extension
to IP address mappings, and communication protocols are all examples of information that,
while not critical as individual pieces of data, can make an attacker’s job easier
With conventional telephones, eavesdropping usually requires either physical access to tap
a line, or penetration of a switch. Attempting physical access increases the intruder’s risk
of being discovered, and conventional PBXs have fewer points of access than VoIP
systems. With VoIP, opportunities for eavesdroppers increase dramatically, because of the
many nodes in a packet network.
Switch Default Password Vulnerability
It is common for switches to have a default login/password set, e.g., admin/admin, or root
/root. This vulnerability also allows for wiretapping conversations on the network with port
mirroring or bridging. An attacker with access to the switch administrative interface can
mirror all packets on one port to another, allowing the indirect and unnoticeable
interception of all communications. Failing to change default passwords is one of the most
common errors made by inexperienced users.
REMEDIATION: If possible, remote access to the graphical user interface should be
disabled to prevent the interception of plaintext administration sessions. Some devices
provide the option of a direct USB connection in addition to remote access through a web
browser interface. Disabling port mirroring on the switch should also be considered.
Classical Wiretap Vulnerability
Attaching a packet capture tool or protocol analyzer to the VoIP network segment makes
it easy to intercept voice traffic.
REMEDIATION: A good physical security policy for the deployment environment is a
general first step to maintaining confidentiality. Disabling the hubs on IP Phones as well
as developing an alarm system for notifying the administrator when an IP Phone has been
disconnected will allow for the possible detection of this kind of attack.
ARP Cache Poisoning and ARP Floods
Because many systems have little authentication, an intruder may be able to log onto a
computer on the VoIP network segment, and then send ARP commands corrupting ARP
caches on sender(s) of desired traffic, then activate IP. An ARP flood attack on the switch
could render the network vulnerable to conversation eavesdropping. Broadcasting ARP
replies blind is sufficient to corrupt many ARP caches. Corrupting the ARP cache makes
it possible to re-route traffic to intercept voice and data traffic.
REMEDIATION: Use authentication mechanisms wherever possible and limit physical
access to the VoIP network segment.
Web Server interfaces
Both VoIP switches and voice terminals are likely to have a web server interface for remote
or local administration. An attacker may be able to sniff plaintext HTTP packets to gain
confidential information. This would require access to the local network on which the
server resides.

REMEDIATION: If possible, do not use an HTTP server. If it is necessary to use a web
server for remote administration, use the more secure HTTPS (HTTP over SSL or TLS)
protocol.
IP Phone Netmask Vulnerability
A similar effect of the ARP Cache Vulnerability can be achieved by assigning a subnet
mask and router address to the phone crafted to cause most or all of the packets it transmits
to be sent to an attacker’s MAC address. Again, standard IP forwarding makes the intrusion
all but undetectable.
REMEDIATION: A firewall filtering mechanism can reduce the probability of this attack.
Remote access to IP phones is a severe risk.
Extension to IP Address Mapping Vulnerability
Discovering the IP address corresponding to any extension requires only calling that
extension and getting an answer. A protocol analyzer or packet capture tool attached to
the hub on the dialing instrument will see packets directly from the target instrument once
the call is answered. Knowing the IP address of a particular extension is not a
compromise in itself, but makes it easier to accomplish other attacks. For example, if the
attacker is able to sniff packets on the local network used by the switch, it will be easy to
pick out packets sent and received by a target phone. Without knowledge of the IP
address of the target phone, the attacker’s job may be much more difficult to accomplish
and require much longer, possibly resulting in the attack being discovered.
REMEDIATION: Disabling the hub on the IP Phone will prevent this kind of attack.
However, it is a rather simple task to turn the hub back on.
Integrity Issues
Integrity of information means that information remains unaltered by unauthorized users.
For example, most users want to ensure that bank account numbers cannot be changed by
anyone else, or that passwords are changed only by the user or an authorized security
administrator. Telecommunication switches must protect the integrity of their system data
and configuration. Because of the richness of feature sets available on switches, an attacker
who can compromise the system configuration can accomplish nearly any other goal. For
example, an ordinary extension could be re-assigned into a pool of phones that supervisors
can listen in on or record conversations for quality control purposes. Damaging or deleting
information about the IP network used by a VoIP switch results in an immediate denial of
service.
The security system itself provides the capabilities for system abuse and misuse. That is,
compromise of the security system not only allows system abuse but also allows the
elimination of all traceability and the insertion of trapdoors for intruders to use on their
next visit. For this reason, the security system must be carefully protected. Integrity threats
include any in which system functions or data may be corrupted, either accidentally or as
a result of malicious actions. Misuse may involve legitimate users (i.e. insiders performing
unauthorized operations) or intruders.

A legitimate user may perform an incorrect, or unauthorized, operations function (e.g., by
mistake or out of malice) and may cause deleterious modification, destruction, deletion, or
disclosure of switch software and data. This threat may be caused by several factors
including the possibility that the level of access permission granted to the user is higher
than what the user needs to remain functional.
Intrusion - An intruder may masquerade as a legitimate user and access an operations port of
the switch. There are a number of serious intrusion threats. For example, the intruder may use
the permission level of the legitimate user and perform damaging operations functions such as:



Disclosing confidential data



Causing service deterioration by modifying the switch software



Crashing the switch



Removing all traces of the intrusion (e.g., modifying the security log) so that it
may not be readily detected

Insecure state - At certain times the switch may be vulnerable due to the fact that it is not
in a secure state. For example:


After a system restart, the old security features may have been reset to insecure
settings, and new features may not yet be activated. (For example, all old
passwords may have reverted to the default system-password, even though new
passwords are not yet assigned.) The same may happen at the time of a disaster
recovery.



At the time of installation the switch may be vulnerable until the default security
features have been replaced.

DHCP Server Insertion Attack
It is often possible to change the configuration of a target phone by exploiting the DHCP
response race when the IP phone boots. As soon as the IP phone requests a DHCP response,
a rogue DHCP server can initiate a response with data fields containing false information.
This attack allows for possible man in the middle attacks on the IP-media gateway, and IP
Phones. Many methods exist with the potential to reboot the phone remotely, e.g. “social
engineering”, ping flood, MAC spoofing (probably SNMP hooks, etc.).
REMEDIATION: If possible, use static IP addresses for the IP Phones. This will remove
the necessity of using a DHCP server. Further, using a state based intrusion detection
system can filter out DHCP server packets from IP Phone ports, allowing this traffic only
from the legitimate server.
TFTP Server Insertion Attack
It is possible to change the configuration of a target phone by exploiting the TFTP
response race when the IP phone is resetting. A rogue TFTP server can supply spurious

information before the legitimate server is able to respond to a request. This attack allows
an attacker to change the configuration of an IP Phone.
REMEDIATION: Using a state based intrusion detection system can filter out DHCP
server packets from IP Phone ports, allowing such traffic only from the legitimate server.
Organizations looking to deploy VoIP systems should look for IP Phone instruments that
can download signed binary files.
Availability and Denial of Service
Availability refers to the notion that information and services be available for use when
needed. Availability is the most obvious risk for a switch. Attacks exploiting vulnerabilities
in the switch software or protocols may lead to deterioration or even denial of service or
functionality of the switch. For example: if unauthorized access can be established to any
branch of the communication channel (such as a CCS link or a TCP/IP link), it may be
possible to flood the link with bogus messages causing severe deterioration (possibly
denial) of service. A voice over IP system may have additional vulnerabilities with Internet
connections. Because intrusion detection systems fail to intercept a significant percentage
of Internet based attacks, attackers may be able to bring down VoIP systems by exploiting
weaknesses in Internet protocols and services.
Any network may be vulnerable to denial of service attacks, simply by overloading the
capacity of the system. With VoIP the problem may be especially severe, because of its
sensitivity to packet loss or delay.
CPU Resource Consumption Attack without any account information.
An attacker with remote terminal access to the server may be able to force a system
restart (shutdown all/restart all) by providing the maximum number of characters for the
login and password buffers multiple times in succession. Additionally, IP Phones may
reboot as a result of this attack.
In addition to producing a system outage, the restart may not restore uncommitted
changes or, in some cases, may restore default passwords, which would introduce
intrusion vulnerabilities.
REMEDIATION: The deployment of a firewall disallowing connections from
unnecessary or unknown network entities is the first step to overcoming this problem.
However, there is still the opportunity for an attacker to spoof his MAC and IP address,
circumventing the firewall protection.
Default Password Vulnerability
It is common for switches to have a default login/password set, e.g., admin/admin, or root
/root. Similarly, VoIP telephones often have default keypad sequences that can be used to
unlock and modify network information

This vulnerability would allow an attacker to control the topology of the network remotely,
allowing for not only complete denial of service to the network, but also a port mirroring
attack to the attacker’s location, giving the ability to intercept any other conversations
taking place over the same switch. Further, the switch may have a web server interface,
providing an attacker with the ability to disrupt the network without advance knowledge
of switch operations and commands. In most systems, telephones download their
configuration data on startup using TFTP or similar protocols. The configuration specifies
the IP addresses for Call Manager nodes, so an attacker could substitute another IP address
pointing to a call manager that would allow eavesdropping or traffic analysis.
REMEDIATION: Changing the default password is crucial. Moreover, the graphical user
interface should be disabled to prevent the interception of plaintext administration sessions.
Exploitable software flaws
Like other types of software, VoIP systems have been found to have vulnerabilities due
to buffer overflows and improper packet header handling. These flaws typically occur
because the software is not validating critical information properly. For example, a short
integer may be used as a table index without checking whether the parameter passed to
the function exceeds 32,767, resulting in invalid memory accesses or crashing of the
system.
Exploitable software flaws typically result in two types of vulnerabilities: denial of
service or revelation of critical system parameters. Denial of service can often be
implemented remotely, by passing packets with specially constructed headers that cause
the software to fail. In some cases the system can be crashed, producing a memory dump
in which an intruder can find IP addresses of critical system nodes, passwords, or other
security-relevant information. In addition, buffer overflows that allow the introduction of
malicious code have been found in VoIP software, as in other applications.
REMEDIATION: These problems require action from the software vendor, and
distribution of patches to administrators. Intruders monitor announcements of
vulnerabilities, knowing that many organizations require days or weeks to update their
software. Regular checking for software updates and patches is essential to reducing these
vulnerabilities. Automated patch handling can assist in reducing the window of
opportunity for intruders to exploit known software vulnerabilities.
Account Lockout Vulnerability
An attacker will be able to provide several incorrect login attempts at the telnet prompt
until the account becomes locked out. (This problem is common to most passwordprotected systems, because it prevents attackers from repeating login attempts until the
correct password is found by trying all possible combinations.)
The account is unable to connect to the machine for the set lockout time.
REMEDIATION: If remote access is not available, this problem can be solved with
physical access control.
NIST Recommendations.

Because of the integration of voice and data in a single network, establishing a secure VoIP
and data network is a complex process that requires greater effort than that required for
data-only networks. In particular, start with these general guidelines, recognizing that
practical considerations, such as cost or legal requirements, may require adjustments for
the organization:
1. Develop appropriate network architecture.


Separate voice and data on logically different networks if feasible. Different
subnets with separate RFC 1918 address blocks should be used for voice and data
traffic, with separate DHCP servers for each, to ease the incorporation of intrusion
detection and VoIP firewall protection at the voice gateway, which interfaces with
the PSTN, disallow H.323, SIP, or other VoIP protocols from the data network.
Use strong authentication and access control on the voice gateway system, as with
any other critical network component. Strong authentication of clients towards a
gateway often presents difficulties, particularly in key management. Here, access
control mechanisms and policy enforcement may help.



A mechanism to allow VoIP traffic through firewalls is required. There are a
variety of protocol dependent and independent solutions, including application
level gateways (ALGs) for VoIP protocols, Session Border Controllers, or other
standards-based solutions when they mature.



Stateful packet filters can track the state of connections, denying packets that are
not part of a properly originated call. (This may not be practical when multimedia
protocol inherent security or lower layer security is applied, e.g., H.235 Annex D
for integrity provision or TLS to protect SIP signaling.)



Use IPsec or Secure Shell (SSH) for all remote management and auditing access.
If practical, avoid using remote management at all and do IP PBX access from a
physically secure system.



If performance is a problem, use encryption at the router or other gateway, not the
individual endpoints, to provide for IPsec tunneling. Since some VoIP endpoints
are not computationally powerful enough to perform encryption, placing this
burden at a central point ensures all VoIP traffic emanating from the enterprise
network has been encrypted. Newer IP phones are able to provide Advanced
Encryption System (AES) encryption at reasonable cost. Note that Federal
Information Processing Standard (FIPS) 140-2, Security Requirements for
Cryptographic Modules, is applicable to all Federal agencies that use
cryptographic-based security systems to protect sensitive information in computer
and telecommunication systems (including voice systems) as defined in Section
5131 of the Information Technology Management Reform Act of 1996, Public
Law 104-106.

2. Ensure that the organization has examined and can acceptably manage and mitigate the risks to
their information, system operations, and continuity of essential operations when deploying VoIP
systems.
VoIP can provide more flexible service at lower cost, but there are significant tradeoffs
that must be considered. VoIP systems can be expected to be more vulnerable than
conventional telephone systems, in part because they are tied in to the data network,
resulting in additional security weaknesses and avenues of attack (see VoIP Risks, Threats,
and Vulnerabilities section for more detailed discussion of vulnerabilities of VoIP and their
relation to data network vulnerabilities).
Confidentiality and privacy may be at greater risk in VoIP systems unless strong controls
are implemented and maintained. An additional concern is the relative instability of VoIP
technology compared with established telephony systems. Today, VoIP systems are still
maturing and dominant standards have not emerged. This instability is compounded by
VoIP’s reliance on packet networks as a transport medium. The public switched telephone
network is ultra-reliable. Internet service is generally much less reliable, and VoIP cannot
function without Internet connections, except in the case of large corporate or other users
who may operate a private network. Essential telephone services, unless carefully planned,
deployed, and maintained, will be at greater risk if based on VoIP.
3. Special consideration should be given to E-911 emergency services communications, because
E-911 automatic location service is not available with VoIP in some cases.
Unlike traditional telephone connections, which are tied to a physical location, VoIP’s
packet switched technology allows a particular number to be anywhere. This is convenient
for users, because calls can be automatically forwarded to their locations. But the tradeoff
is that this flexibility severely complicates the provision of E-911 service, which normally
provides the caller’s location to the 911 dispatch office. Although most VoIP vendors have
workable solutions for E-911 service, government regulators and vendors are still working
out standards and procedures for 911 services in a VoIP environment. Agencies must
carefully evaluate E-911 issues in planning for VoIP deployment.
4. Agencies should be aware that physical controls are especially important in a VoIP environment
and deploy them accordingly.
Unless the VoIP network is encrypted, anyone with physical access to the office LAN could
potentially connect network monitoring tools and tap into telephone conversations.
Although conventional telephone lines can also be monitored when physical access is
obtained, in most offices there are many more points to connect with a LAN without
arousing suspicion. Even if encryption is used, physical access to VoIP servers and
gateways may allow an attacker to do traffic analysis (i.e., determine which parties are
communicating). Agencies therefore should ensure that adequate physical security is in
place to restrict access to VoIP network components. Physical securities measures,
including barriers, locks, access control systems, and guards, are the first line of defense.
Agencies must make sure that the proper physical countermeasures are in place to mitigate
some of the biggest risks such as insertion of sniffers or other network monitoring devices.
Otherwise, practically speaking this means that installation of a sniffer could result in not
just data but all voice communications being intercepted.

5. VoIP-ready firewalls and other appropriate protection mechanisms should be employed.
Agencies must enable, use, and routinely test the security features that are included in VoIP
systems.
Because of the inherent vulnerabilities (e.g. susceptibility to packet sniffing) when
operating telephony across a packet network, VoIP systems incorporate an array of security
features and protocols. Organization security policy should ensure that these features are
used. In particular, firewalls designed for VoIP protocols are an essential component of a
secure VoIP system.
6. If practical, “softphone” systems, which implement VoIP using an ordinary PC with a headset
and special software, should not be used where security or privacy are a concern.
Worms, viruses, and other malicious software are extraordinarily common on PCs
connected to the internet, and very difficult to defend against. Well-known vulnerabilities
in web browsers make it possible for attackers to download malicious software without a
user’s knowledge, even if the user does nothing more than visit a compromised web site.
Malicious software attached to email messages can also be installed without the user’s
knowledge, in some cases even if the user does not open the attachment. These
vulnerabilities result in unacceptably high risks in the use of “softphones”, for most
applications. In addition, because PCs are necessarily on the data network, using a
softphone system conflicts with the need to separate voice and data networks to the greatest
extent practical.
7. If mobile units are to be integrated with the VoIP system, use products implementing WiFi
Protected Access (WPA), rather than 802.11 Wired Equivalent Privacy (WEP).
The security features of 802.11 WEP provide little or no protection because WEP can be
cracked with publicly available software. The more recent WiFi Protected Access (WPA),
a snapshot of the ongoing 802.11i standard, offers significant improvements in security,
and can aid the integration of wireless technology with VoIP. NIST strongly recommends
that the WPA (or WEP if WPA is unavailable) security features be used as part of an overall
defense-in-depth strategy. Despite their weaknesses, the 802.11 security mechanisms can
provide a degree of protection against unauthorized disclosure, unauthorized network
access, or other active probing attacks. However, the Federal Information Processing
Standard (FIPS) 140-2, Security Requirements for Cryptographic Modules, is mandatory
and binding for Federal agencies that have determined that certain information must be
protected via cryptographic means. As currently defined, neither WEP nor WPA meets the
FIPS 140-2 standard. In these cases, it will be necessary to employ higher level
cryptographic protocols and applications such as secure shell (SSH), Transport Level
Security (TLS) or Internet Protocol Security (IPsec) with FIPS 140-2 validated
cryptographic modules and associated algorithms to protect information, regardless of
whether the nonvalidated data link security protocols are used.
8. Carefully review statutory requirements regarding privacy and record retention with competent
legal advisors.
Although legal issues regarding VoIP are beyond the scope of this document, readers
should be aware that laws and rulings governing interception or monitoring of VoIP lines,
and retention of call records, may be different from those for conventional telephone

systems. Agencies should review these issues with their legal advisors. See Section 2.5 for
more on these issues.

G.3 Cloud Computing

Cloud Computing
Purpose:
This paper is provided to define and describe cloud computing, discuss CJIS Security Policy
(CSP) compliance, detail security and privacy, and provide general recommendations.
Attribution:





NIST SP 800-144, Guidelines on Security and Privacy in Public Cloud Computing (Dec.
2011)
NIST SP 800-145, the NIST Definition of Cloud Computing (Sept. 2011)
NIST SP 800-146, Cloud Computing Synopsis and Recommendations (May 2011)
CJIS Security Policy, Version 5.0

Definitions and Terms:
Cloud computing – A distributed computing model that permits on-demand network access to a
shared pool of configurable computing resources (e.g., networks, servers, storage, applications,
and services), software, and information.
Cloud subscriber – A person or organization that is a customer of a cloud
Cloud client – A machine or software application that accesses a cloud over a network connection,
perhaps on behalf of a subscriber
Cloud provider – An organization that provides cloud services
Summary:
With many law enforcement agencies looking for ways to attain greater efficiency while grappling
with reduced budgets, the idea of cloud computing to maintain data and applications is a viable
business solution. But the unique security and legal characteristics of law enforcement agencies
means any migration to cloud services may be challenging. Anytime the security of information
and transactions must be maintained, as it must be with access to the FBI’s CJIS systems and the
protection of Criminal Justice Information (CJI), security and policy compliance concerns are
bound to arise.

Cloud computing has become a popular and sometimes contentious topic of discussion for both
the private and public sectors. This is in part because of the difficulty in describing cloud
computing in general terms, because it is not a single kind of system. The “cloud” spans a spectrum
of underlying technologies, configuration possibilities, service and deployment models. Cloud
computing offers the ability to conveniently rent access to fully featured applications, software
development and deployment environments, and computing infrastructure assets - such as
network-accessible data storage and processing from a cloud service provider.
One of the benefits of cloud computing is the ability to outsource many of the technical functions
agencies may not want to perform for various reasons. Ultimately, the move to cloud computing
is a business and security risk decision in which the following relevant factors are given proper
consideration:






readiness of existing applications for cloud deployment
transition costs
life-cycle costs
maturity of service orientation in existing infrastructure
security and privacy requirements – federal, state, and local

Achieving CJIS Security Policy Compliance:
The question that is often asked is, “Can an Agency be compliant with the CJIS Security Policy
and also cloud compute?”
Because the CJIS Security Policy is device and architecture independent (per CSP Section 2.2),
the answer is yes, and this can be accomplished— assuming the vendor of the cloud technology is
able to meet the existing requirements of the CJIS Security Policy.
There are security challenges that must be addressed if CJI is to be sent into or through, stored
within, or accessed from the cloud.
Admittedly, the existing CJIS Security Policy requirements may be difficult for some cloudcomputing vendors due to the sheer numbers and the geographic disbursement of their personnel;
however, the requirements aren’t new to vendors serving the criminal justice community and many
vendors have been successfully meeting the Policy requirements for years. Even so, they are the
minimum security requirements which will provide an acceptable level of assurance that law
enforcement and personally identifiable information (PII) will be protected when shared with other
law enforcement agencies across the nation.

General CJIS Security Policy Applicability Questions
Before tackling these challenges, the cloud subscriber should first be aware of what security and
legal requirements they are subject to prior to entering into any agreement with a cloud provider.
Asking the following general questions will help frame the process of determining compliance
with the existing requirements of the CJIS Security Policy.


Will access to Criminal Justice Information (CJI) within a cloud environment fall within
the category of remote access? (5.5.6 Remote Access)



Will advanced authentication (AA) be required for access to CJI within a cloud
environment? (5.6.2.2 Advanced Authentication, 5.6.2.2.1 Advanced Authentication
Policy and Rationale)



Does/do any cloud service provider’s datacenter(s) used in the transmission or storage of
CJI meet all the requirements of a physically secure location? (5.9.1 Physically Secure
Location)



Are the encryption requirements being met? (5.10.1.2 Encryption)
o Who will be providing the encryption as required in the CJIS Security Policy
(client or cloud service provider)? Note: individuals with access to the keys can
decrypt the stored files and therefore have access to unencrypted CJI.
o Is the data encrypted while at rest and in transit?



What are the cloud service provider’s incident response procedures? (5.3 Policy Area 3:
Incident Response)
o Will the cloud subscriber be notified of any incident?
o If CJI is compromised, what are the notification and response procedures?



Is the cloud service provider a private contractor/vendor?
o If so, they are subject to the same screening and agreement requirements as any
other private contractors hired to handle CJI? (5.1.1.5 Private Contractor User
Agreements and CJIS Security Addendum; 5.12.1.2 Personnel Screening for
Contractors and Vendors)



Will the cloud service provider allow the CSA and FBI to conduct compliance and
security audits? Note: Cloud facilities such as datacenters in which CJI will be stored or
processed should be audited as would any other datacenter housing and processing CJI.
(5.11.1 Audits by the FBI CJIS Division; 5.11.2 Audits by the CSA)



How will event and content logging be handled? (5.4 Policy Area 4, Auditing and
Accountability)
o Will the cloud service provider handle the events and content logging required by
the CJIS Security Policy and provide that upon request?
o What are the cloud service provider’s responsibilities with regard to media
protection and destruction? (5.8 Policy Area 8: Media Protection)

Ultimately, the goal is to remain committed to using technology in its information sharing
processes, but not at the sacrifice of the security of the information with which it has been
entrusted. As stated in the CJIS Security Policy, device and architecture independence permits the
use of cloud computing, but the security requirements do not change.
Cloud Utilization Scenarios
1. Encrypted CJI in a Cloud Environment–Key Management Control, Security Awareness

Training, and Personnel Controls
Prior to permitting CJI to be stored or traverse through a cloud environment, the agency
should ensure proper encryption key management control procedures are implemented to
determine who has access and control over the encryption keys. Proper key management
control is vital to CJI security as those individuals (agency or cloud employees) with
access to the keys can decrypt the stored files, and therefore, have unescorted access to
unencrypted CJI. This means all those individuals must be subjected to security
awareness training (CJIS Security Policy section 5.2) and must meet personnel security
(CJIS Security Policy Section 5.12) requirements as individuals with unescorted access to
unencrypted CJI.
Note: As a best security practice, the CJIS ISO Program does not recommend allowing
the cloud service provider access to the encryption keys used to protect CJI. However, it
may not always be reasonable to expect the agency, criminal justice or noncriminal
justice, to accomplish this task.
a. Scenario 1–Agency Stores CJI in a Cloud:

A CJA stores encrypted CJI (Backup files and drives) in a cloud service provider’s
environment. To access CJI, the agency will extract the CJI from the cloud to its local
machine, and then decrypt the CJI. The CJI is processed, re-encrypted, and then reuploaded to the cloud environment for storage. In this scenario, the agency always
encrypts the CJI prior to placing it in the cloud and only authorized users of the
agency have access to the encryption keys. Since the agency maintains the encryption
keys, the cloud service provider employees would not need to undergo fingerprintbased background checks, nor have security awareness training. These requirements
are negated, because only authorized personnel with access to the keys have the
ability to view this CJI in an unencrypted form.
b. Scenario 2–Agency Accesses CJI While in a Cloud:

A CJA stores CJI (files and drives) in a cloud service provider’s environment, but as
part of daily operations authorized users will remotely access the encrypted CJI in the
cloud. The user will decrypt the CJI while it is in the cloud’s virtual environment,
process the data, and then re-encrypt the data prior to ending the remote session. The
agency maintains the keys and the cloud service provider does not have access to the
encryption keys. However, since the CJI is decrypted within the cloud’s virtual
environment, any administrative personnel employed by the cloud provider having
the ability to access the virtual environment must be identified and subjected to
security awareness training and personnel security controls as described in the CJIS
Security Policy.
c. Scenario 3–CJI Impact from a Cloud Datacenter Critical Systems Crash–Core Dump2

Recovery:
A CJA utilizes a cloud service provider (IaaS or PaaS) to store CJI and remotely
accesses the environment to process CJI. During normal operation, the cloud provider
experiences systems outages within the datacenter in which CJI is processed and
stored. The cloud provider’s administrators need to repair the systems and restore
service using data from a core dump to return to normal operations. The cloud service
provider as part of the Service Level Agreement (SLA) with the CJA has been
authorized to maintain the encryption keys in order respond to such an event. The
cloud administrators with such access have underwent fingerprint-based background
checks and security awareness training. This allows the cloud administrators to
decrypt CJI so that it is written to the core dump files for restoration following the
system outage. CJI, however, is encrypted at all times except when part of the core
dump files. As part of the SLA, the cloud service provider has agreed to treat the core
dump files as CJI to ensure all protection are in place in compliance with the CJIS
Security Policy.
Note: Writing encrypted data to a core dump corrupts the data and makes it unusable
because the key no longer decrypts the data. This is problematic when attempting to
recover encrypted data written to a core dump. The CJA could have ensured the
cloud provider exclude encrypted data (CJI) from the core dump, but chose against it

The Cloud Model Explained:
Cloud computing is a model for enabling ubiquitous, convenient, on-demand network access to a
shared pool of configurable computing resources (e.g., networks, servers, storage, applications,
and services) that can be rapidly provisioned and released with minimal management effort or
service provider interaction.

Core Dump - A file of a computer’s documented memory of when a program or computer crashed.
The file consists of the recorded status of the working memory at an explicit time, usually close to
when the system crashed or when the program ended atypically as it presents the risk that the
system failure would ensure the loss of the encrypted data.
2

The cloud model as defined by NIST consists of five essential characteristics, offers the option of
three service models, and may be deployed via any of four deployment models as shown in
Figure 1 below:

Figure 1 - Visual Depiction of the NIST Cloud Computing Definition

Essential Characteristics:
On-demand self-service
A consumer can unilaterally provision computing capabilities, such as server time and
network storage, as needed automatically without requiring human interaction with each
service provider.
Broad network access
Capabilities are available over the network and accessed through standard mechanisms
that promote use by heterogeneous thin or thick client platforms (e.g., mobile phones,
tablets, laptops, and workstations).
Resource pooling
The provider’s computing resources are pooled to serve multiple consumers using a
multi-tenant model, with different physical and virtual resources dynamically assigned
and reassigned according to consumer demand. There is a sense of location independence
in which the customer generally has no control or knowledge over the exact location of
the provided resources but may be able to specify location at a higher level of abstraction

(e.g., country, state, or datacenter). Examples of resources include storage, processing,
memory, and network bandwidth.
Rapid elasticity
Capabilities can be elastically provisioned and released, in some cases automatically, to
scale rapidly outward and inward commensurate with demand. To the consumer, the
capabilities available for provisioning often appear to be unlimited and can be
appropriated in any quantity at any time.

Measured service
Cloud systems automatically control and optimize resource use by leveraging a metering
capability* at some level of abstraction appropriate to the type of service (e.g., storage,
processing, bandwidth, and active user accounts). Resource usage can be monitored,
controlled, and reported, providing transparency for both the provider and consumer of
the utilized service.
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt CJIS-5.6.txt strip-pages Typically this is done on a pay-per-use or charge-per-use basis.
Deployment Models:
Private cloud
The cloud infrastructure is provisioned for exclusive use by a single organization
comprising multiple consumers (e.g., business units). It may be owned, managed, and
operated by the organization, a third party, or some combination of them, and it may exist
on or off premises.
Community cloud
The cloud infrastructure is provisioned for exclusive use by a specific community of
consumers from organizations that have shared concerns (e.g., mission, security
requirements, policy, and compliance considerations). It may be owned, managed, and
operated by one or more of the organizations in the community, a third party, or some
combination of them, and it may exist on or off premises.
Public cloud
The cloud infrastructure is provisioned for open use by the general public. It may be
owned, managed, and operated by a business, academic, or government organization, or
some combination of them. It exists on the premises of the cloud provider.
Hybrid cloud
The cloud infrastructure is a composition of two or more distinct cloud infrastructures
(private, community, or public) that remain unique entities, but are bound together by
standardized or proprietary technology that enables data and application portability (e.g.,
cloud bursting for load balancing between clouds).

Service Models:
Software as a Service (SaaS)
This model provides the consumer the capability to use the provider’s applications
running on a cloud infrastructure*.
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt CJIS-5.6.txt strip-pages A cloud infrastructure is the collection of hardware and software that enables
the five essential characteristics of cloud computing. The cloud infrastructure can
be viewed as containing both a physical layer and an abstraction layer. The
physical layer consists of the hardware resources that are necessary to support
the cloud services being provided, and typically includes server, storage and
network components. The abstraction layer consists of the software deployed
across the physical layer, which manifests the essential cloud characteristics.
Conceptually the abstraction layer sits above the physical layer.
The SaaS service model is often referred to as “Software deployed as a hosted service
and accessed over the Internet.”
The applications are accessible from various client devices through either a thin client
interface, such as a web browser (e.g., web-based email), or a program interface.
When using the SaaS service model it should be understood that the consumer does not
manage or control the underlying cloud infrastructure including network, servers,
operating systems, storage, or even individual application capabilities, with the possible
exception of limited user-specific application configuration settings.
Platform as a Service (PaaS)
This model provides the consumer the capability to deploy consumer-created or acquired
applications* created using programming languages, libraries, services, and tools
supported by the provider onto the cloud infrastructure.
CJIS-5.5-20160601.pdf CJIS-5.5-20160601.txt CJIS-5.5.txt CJIS-5.6-20170605.pdf CJIS-5.6-20170605.txt CJIS-5.6.txt strip-pages This capability does not necessarily preclude the use of compatible
programming languages, libraries, services, and tools from other sources.
When using the PaaS service model the consumer may have control over the deployed
applications and possibly configuration settings for the application-hosting environment,
but does not manage or control the underlying cloud infrastructure including network,
servers, operating systems, or storage.
Infrastructure as a Service (IaaS)
This model provides the consumer the capability to provision processing, storage,
networks, and other fundamental computing resources where the consumer is able to
deploy and run arbitrary software, including operating systems and applications.
When using the IaaS service model the consumer may have control over operating
systems, storage, and deployed applications; and possibly limited control of select

networking components (e.g., host firewalls), but does not manage or control the
underlying cloud infrastructure.
Key Security and Privacy Issues:
Although the emergence of cloud computing is a recent development, insights into critical aspects
of security can be gleaned from reported experiences of early adopters and also from researchers
analyzing and experimenting with available cloud provider platforms and associated technologies.
The sections below highlight privacy and security-related issues that are believed to have longterm significance for public cloud computing and, in many cases, for other cloud computing
service models.
Because cloud computing has grown out of an amalgamation of technologies, including service
oriented architecture, virtualization, Web 2.0, and utility computing, many of the privacy and
security issues involved can be viewed as known problems cast in a new setting. The importance
of their combined effect in this setting, however, should not be discounted. Public cloud computing
does represent a thought-provoking paradigm shift from conventional norms to an open
organizational infrastructure—at the extreme, displacing applications from one organization’s
infrastructure to the infrastructure of another organization, where the applications of potential
adversaries may also operate.
Governance
Governance implies control and oversight by the organization over policies, procedures, and
standards for application development and information technology service acquisition, as well as
the design, implementation, testing, use, and monitoring of deployed or engaged services. With
the wide availability of cloud computing services, lack of organizational controls over employees
engaging such services arbitrarily can be a source of problems. While cloud computing simplifies
platform acquisition, it doesn't alleviate the need for governance; instead, it has the opposite effect,
amplifying that need.
Dealing with cloud services requires attention to the roles and responsibilities involved between
the organization and cloud provider, particularly with respect to managing risks and ensuring
organizational requirements are met. Ensuring systems are secure and risk is managed is
challenging in any environment and even more daunting with cloud computing. Audit mechanisms
and tools should be in place to determine how data is stored, protected, and used, to validate
services, and to verify policy enforcement. A risk management program should also be in place
that is flexible enough to deal with the continuously evolving and shifting risk landscape.

Compliance
Compliance refers to an organization’s responsibility to operate in agreement with established
laws, regulations, standards, and specifications. Various types of security and privacy laws and
regulations exist within different countries at the national, state, and local levels, making
compliance a potentially complicated issue for cloud computing.
Law and Regulations
Cloud providers are becoming more sensitive to legal and regulatory concerns, and may be
willing to commit to store and process data in specific jurisdictions and apply required
safeguards for security and privacy. However, the degree to which they will accept liability
in their service agreements, for exposure of content under their control, remains to be seen.
Even so, organizations are ultimately accountable for the security and privacy of data held
by a cloud provider on their behalf.
Data Location
One of the most common compliance issues facing an organization is data location. A
characteristic of many cloud computing services is that data is stored redundantly in
multiple physical locations and detailed information about the location of an organization’s
data is unavailable or not disclosed to the service consumer. This situation makes it difficult
to ascertain whether sufficient safeguards are in place and whether legal and regulatory
compliance requirements are being met. External audits and security certifications can
alleviate this issue to some extent, but they are not a panacea.
When information crosses borders, the governing legal, privacy, and regulatory regimes
can be ambiguous and raise a variety of concerns. Consequently, constraints on the transborder flow of sensitive data, as well as the requirements on the protection afforded the
data, have become the subject of national and regional privacy and security laws and
regulations.
Electronic Discovery
The capabilities and processes of a cloud provider, such as the form in which data is
maintained and the electronic discovery-related tools available, affect the ability of the
organization to meet its obligations in a cost effective, timely, and compliant manner. A
cloud provider’s archival capabilities may not preserve the original metadata as expected,
causing spoliation (i.e., the intentional, reckless, or negligent destruction, loss, material
alteration, or obstruction of evidence that is relevant to litigation), which could negatively
impact litigation.

Trust
Under the cloud computing paradigm, an organization relinquishes direct control over many
aspects of security and privacy, and in doing so, confers a high level of trust onto the cloud
provider. At the same time, federal agencies have a responsibility to protect information and
information systems commensurate with the risk and magnitude of the harm resulting from
unauthorized access, use, disclosure, disruption, modification, or destruction, regardless of
whether the information is collected or maintained by or on behalf of the agency; or whether the
information systems are used or operated by an agency or by a contractor of an agency or other
organization on behalf of an agency
Insider Access
Data processed or stored outside the physical confines of an organization, its firewall, and
other security controls bring with it an inherent level of risk. The insider security threat is
a well-known issue for most organizations. Incidents may involve various types of fraud,
sabotage of information resources, and theft of sensitive information.
Data Ownership
The organization’s ownership rights over the data must be firmly established in the service
contract to enable a basis for trust and privacy of data. The continuing controversy over
privacy and data ownership rights for social networking users illustrates the impact that
ambiguous terms can have on the parties involved.
Ideally, the contract should state clearly that the organization retains exclusive ownership
over all its data; that the cloud provider acquires no rights or licenses through the
agreement, including intellectual property rights or licenses, to use the organization’s data
for its own purposes; and that the cloud provider does not acquire and may not claim any
interest in the data due to security. For these provisions to work as intended, the terms of
data ownership must not be subject to unilateral amendment by the cloud provider.
Visibility
Continuous monitoring of information security requires maintaining ongoing awareness of
security controls, vulnerabilities, and threats to support risk management decisions.
Transition to public cloud services entails a transfer of responsibility to the cloud provider
for securing portions of the system on which the organization’s data and applications
operate.

Ancillary Data
While the focus of attention in cloud computing is mainly on protecting application data,
cloud providers also hold significant details about the accounts of cloud consumers that
could be compromised and used in subsequent attacks.
Risk Management
Assessing and managing risk in systems that use cloud services can be a challenge. With
cloud-based services, some subsystems or subsystem components fall outside of the direct
control of a client organization. Many organizations are more comfortable with risk when
they have greater control over the processes and equipment involved. Establishing a level
of trust about a cloud service is dependent on the degree of control an organization is able
to exert on the provider to provision the security controls necessary to protect the
organization’s data and applications, and also the evidence provided about the
effectiveness of those controls. Ultimately, if the level of trust in the service falls below
expectations and the organization is unable to employ compensating controls, it must either
reject the service or accept a greater degree of risk.
Architecture
The architecture of the software and hardware used to deliver cloud services can vary significantly
among public cloud providers for any specific service model. It is important to understand the
technologies the cloud provider uses to provision services and the implications the technical
controls involved have on security and privacy of the system throughout its lifecycle. With such
information, the underlying system architecture of a cloud can be decomposed and mapped to a
framework of security and privacy controls that can be used to assess and manage risk.
Identity and Access Management
Data sensitivity and privacy of information have become increasingly an area of concern for
organizations. The identity proofing and authentication aspects of identity management entail the
use, maintenance, and protection of PII collected from users. Preventing unauthorized access to
information resources in the cloud is also a major consideration. One recurring issue is that the
organizational identification and authentication framework may not naturally extend into a public
cloud and extending or changing the existing framework to support cloud services may prove
difficult.
Software Isolation
High degrees of multi-tenancy over large numbers of platforms are needed for cloud computing to
achieve the envisioned flexibility of on-demand provisioning of reliable services and the cost
benefits and efficiencies due to economies of scale. Regardless of the service model and multitenant software architecture used, the computations of different consumers must be able to be
carried out in isolation from one another, mainly through the use of logical separation mechanisms.
Data Protection
Data stored in a public cloud typically resides in a shared environment collocated with data from
other customers. Organizations placing sensitive and regulated data into a public cloud, therefore,
must account for the means by which access to the data is controlled and the data is kept secure.
Similar concerns exist for data migrated within or between clouds.
Value Concentration
Having data collocated with that of an organization with a high threat profile could also
lead to a denial of service, as an unintended casualty from an attack targeted against that
organization. Similarly, side effects from a physical attack against a high profile
organization’s cloud-based resources are also a possibility. For example, over the years,
facilities of the Internal Revenue Service have attracted their share of attention from wouldbe attackers.
Data Isolation
Database environments used in cloud computing can vary significantly. Accordingly,
various types of multi-tenant arrangements exist for databases. Each arrangement pools
resources differently, offering different degrees of isolation and resource efficiency.
Regardless of implementation decision, data must be secured while at rest, in transit, and
in use, and access to the data must be controlled.
Data Sanitization
The data sanitization practices that a cloud provider implements have obvious implications
for security. Sanitization involves the expunging of data from storage media by
overwriting, degaussing, or other means, or the destruction of the media itself, to prevent
unauthorized disclosure of information. Data sanitization also applies to backup copies
made for recovery and restoration of service and residual data remaining upon termination
of service.
In a public cloud computing environment, data from one consumer is physically collocated
(e.g., in an IaaS data store) or commingled (e.g., in a SaaS database) with the data of other
consumers, which can complicate matters. Service agreements should stipulate sufficient
measures that are taken to ensure data sanitization is performed appropriately throughout
the system lifecycle.

Encryption
Client end-to-end encryption (e.g. encryption/decryption occurs on the law enforcement
controlled client prior to data entering the cloud and decryption occurs only on the client
device after encrypted data is removed from the cloud service) with cryptographic keys
managed solely by law enforcement would prevent exposure of sensitive data.


May cause significant cloud service functionality limitations on available service types
made available for sensitive data. This may also increase expenses to cover key items,
such as key management and client software. Additionally, a number of specific SLA or
contract clauses may be necessary for the implementation of client end-to end
encryption.

Use of cloud services without end-to-end encryption implemented by the client is another
option that would require cloud service provider participation in the encryption of data.


This would require at least some cloud provider personnel to undergo personnel
background screening and training.



Specialized Service Level Agreements (SLA) and/or contractual clauses would be
necessary to identify those personnel that may have access to unencrypted, sensitive
data.



Conducting the analysis and gaining approval of particular cloud service
implementations not utilizing end-to-end encryption for sensitive law enforcement data
may be costly and time consuming due to the high degree of technical complexity.

Availability
In simple terms, availability is the extent to which an organization’s full set of computational
resources is accessible and usable. Denial of service attacks, equipment outages, and natural
disasters are all threats to availability. The concern is that most downtime is unplanned and can
impact the mission of the organization. Some examples of unplanned service interruptions that
cause concerns are:




Temporary Outages
Prolonged and Permanent Outages
Denial of Service

Incident Response
The complexity of a cloud service can obscure recognition and analysis of incidents. Revising an
organization’s incident response plan to address differences between the organizational computing
environment and a cloud computing environment is an important, but easy-to-overlook
prerequisite to transitioning applications and data.
Data Availability
The availability of relevant data from event monitoring is essential for timely detection of
security incidents. Cloud consumers are often confronted with extremely limited
capabilities for detection of incidents in public cloud environments. The situation varies
among cloud service models and cloud providers. For example, PaaS providers typically
do not make event logs available to consumers, who are then left mainly with event data
from self-deployed applications (e.g., via application logging). Similarly, SaaS consumers
are completely dependent upon the cloud provider to provide event data such as activity
logging, while IaaS consumers control more of the information stack and have access to
associated event sources.
Incident Analysis and Resolution
An analysis to confirm the occurrence of an incident or determine the method of exploit
needs to be performed quickly and with sufficient detail of documentation and care to
ensure that traceability and integrity is maintained for subsequent use, if needed (e.g., a
forensic copy of incident data for legal proceedings). Issues faced by cloud consumers
when performing incident analysis include lack of detailed information about the
architecture of the cloud relevant to an incident, lack of information about relevant event
and data sources held by the cloud provider, ill-defined or vague incident handling
responsibilities stipulated for the cloud provider, and limited capabilities for gathering and
preserving pertinent data sources as evidence. Understanding and negotiating the
provisions and procedures for incident response should be done before entering into a
service contract, rather than as an afterthought.
General Recommendations:
A number of significant security and privacy issues were covered in the previous subsections.
Table 1 summarizes those issues and related recommendations for organizations to follow when
planning, reviewing, negotiating, or initiating a public cloud service outsourcing arrangement.

Table 1: Security and Privacy Issue Areas and Recommendations
Areas
Recommendations
 Extend organizational practices pertaining to the policies, procedures,
and standards used for application development and service provisioning
in the cloud, as well as the design, implementation, testing, use, and
Governance
monitoring of deployed or engaged services.
 Put in place audit mechanisms and tools to ensure organizational
practices are followed throughout the system lifecycle.
 Understand the various types of laws and regulations that impose
security and privacy obligations on the organization and potentially
impact cloud computing initiatives, particularly those involving data
location, privacy and security controls, records management, and
electronic discovery requirements.
Compliance
 Review and assess the cloud provider’s offerings with respect to the
organizational requirements to be met and ensure that the contract terms
adequately meet the requirements.
 Ensure that the cloud provider’s electronic discovery capabilities and
processes do not compromise the privacy or security of data and
applications.
 Ensure that service arrangements have sufficient means to allow
visibility into the security and privacy controls and processes employed
by the cloud provider, and their performance over time.
 Establish clear, exclusive ownership rights over data.
Trust
 Institute a risk management program that is flexible enough to adapt to
the constantly evolving and shifting risk landscape for the lifecycle of
the system.
 Continuously monitor the security state of the information system to
support on-going risk management decisions.
 Understand the underlying technologies that the cloud provider uses to
provision services, including the implications that the technical controls
Architecture
involved have on the security and privacy of the system, over the full
system lifecycle and across all system components.
 Ensure that adequate safeguards are in place to secure authentication,
Identity and
authorization, and other identity and access management functions, and
Access
are suitable for the organization.
Management
 Understand virtualization and other logical isolation techniques that the
Software
cloud provider employs in its multi-tenant software architecture, and
Isolation
assess the risks involved for the organization.
 Evaluate the suitability of the cloud provider’s data management
solutions for the organizational data concerned and the ability to control
Data
access to data, to secure data while at rest, in transit, and in use, and to
Protection
sanitize data.





Availability





Incident
Response



Take into consideration the risk of collating organizational data with that
of other organizations whose threat profiles are high or whose data
collectively represent significant concentrated value.
Fully understand and weigh the risks involved in cryptographic key
management with the facilities available in the cloud environment and
the processes established by the cloud provider.
Understand the contract provisions and procedures for availability, data
backup and recovery, and disaster recovery, and ensure that they meet
the organization’s continuity and contingency planning requirements.
Ensure that during an intermediate or prolonged disruption or a serious
disaster, critical operations can be immediately resumed, and that all
operations can be eventually reinstituted in a timely and organized
manner.
Understand the contract provisions and procedures for incident response
and ensure that they meet the requirements of the organization.
Ensure that the cloud provider has a transparent response process in
place and sufficient mechanisms to share information during and after an
incident.
Ensure that the organization can respond to incidents in a coordinated
fashion with the cloud provider in accordance with their respective roles
and responsibilities for the computing environment.

G.4 Mobile Appendix

Mobile Appendix
Introduction
Mobile devices present a unique security challenge with regard to the correct application of CJIS
Security Policy requirements. This appendix is intended to provide best practices based on industry
standards and on methods to achieve policy compliance in mobile device employment scenarios.
The technical methods used to achieve compliance with CJIS Security Policy will typically be
different within the mobile environment than those used in fixed locations. Many of the security
features and capabilities inherited by endpoint devices from the fixed environment are either not
present or present in a different form in the mobile environment. Additionally, the basic
technologies used in some types of mobile devices may adequately fulfill some of the CJIS
Security Policy requirements which would require additional software or added features in a
traditional fixed computing environment. Due to the complexity and rapid evolvement of the
mobile environment, this Appendix will remain as device and vendor agnostic as practical,
however certain key requirements for specific mobile operating systems will be identified for the
major mobile operating systems (e.g. Apple iOS, Android) as the underlying technologies are
fundamentally different and offer different levels of built-in compliance to CJIS Security Policy.
Sections within this appendix will provide recommendations regarding priorities and level of effort
versus value of applying certain security controls in the mobile environment. These
recommendations do not supersede or modify the requirements listed in the CJIS Security Policy,
and are intended to describe the effect of inherent security functions and inherent device limitations
in many mobile platforms that impact the application of policy elements in the mobile
environment.
Mobile Device Risk Scenarios
There are multiple risk scenarios that may apply to mobile devices depending on the category of
device (e.g. Laptop, Tablet, and ‘Pocket sized’ devices such as smartphones) and the methods of
device connectivity (e.g. cellular service, WiFi + Cellular, WiFi only). Device category and
method of connection define the technology types within the device which inherently affects the
total level of compliance with CJIS Security Policy that can be obtained by the mobile device.
It is advisable for acquiring agencies to review the mobile device guidance in this Appendix prior
to completing selection and acquisition of particular devices. Both the device category and
connectivity methods installed and configured on the device will impact the overall risk scenario
associated with the device and may significantly affect the effective cost to bring use of the device
in compliance with the CJIS Security Policy. For instance, inclusion of cellular radios with the
ability to remotely control a device significantly changes the risk scenario by allowing remote
tracking, file deletion, and device management which could provide a higher level of CJIS Security
Policy compliance than a WiFi only device that does not guarantee the ability to remotely manage
the device. However, inclusion of cellular technology may significantly increase the initial device
costs and incur ongoing subscription costs. Appropriate choices based on the intended use of the
device along with the types and methods of Criminal Justice Information (CJI) data to be accessed
could greatly reduce agency cost and enhance security.
Device Categories
This appendix defines risk levels for three categories of devices. Prior to reading individual
sections of this Appendix, the agency should identify which device categories will apply to their
employment scenario. If multiple categories of devices are employed, individual technical
configurations and local policy will likely need to be defined for each category of device based on
the risk inherent in the technical characteristics associated with each device category.
Laptop devices
The laptop device category includes mobile devices in a larger format that are transported either
in a vehicle mount or a carrying case and include a monitor with attached keyboard. This includes
all traditional laptop computers that utilize a ‘traditional’, full featured operating system (e.g.
Windows or a Linux variant). Also included in this category are ‘tablet’ type full featured
computers running a traditional full featured operating system but without an attached keyboard.
The main defining factor is the use of a full featured operating system and a form factor too large
to be carried in a pocket. In general, devices of this type connect via WiFi only, but may include
an internal cellular access card in some cases.
The risks associated with this device type are similar to a standard desktop computer at the
technical level, but are increased due to the potential to connect directly to the internet without the
benefit of organizational network security layers (e.g. network firewall, IDS/IPS, network
monitoring devices). There is also an increased risk of intentional device theft from vehicles or
unsecure locations as these devices are too large to be carried on the authorized user’s body. There
may be increased risk from the limited technical ability to wipe or track a lost/stolen device
depending on the particular technical means used for remote device connectivity (e.g. cellular or
WiFi).
In general, the technical configurations for compliance with most of the CJIS Security Policy that
is accomplished via the operating system (e.g. auditing, access control, etc) will remain consistent
with normal fixed location computing systems for laptop devices, but some functions may operate
in an unexpected manner due to lack of constant connectivity. Thorough testing of applied security
policy elements within the expected mobile environments will help ensure the applied policy
configurations remain effective and appropriate when applied to mobile laptop devices.
NOTE: Some newer devices running multi-function operating systems (e.g. Windows 8 or similar
multi-mode operating systems) may exhibit technical features associated with both laptop and
tablet device categories based on their current operating mode which may be reconfigured by the
user on demand. If this is the case, it will be necessary to assess and configure multiple operating
modes to be compliant with CJIS Security Policy on the device, or restrict the operating mode to
one category of operation.
Tablet devices
The tablet device category includes larger format devices transported via vehicle mount or
portfolio sized carry case that typically consist of a touch screen without attached keyboard. These
devices utilize a limited feature operating system (e.g. Apple iOS, Google Android, Windows
mobile) that is inherently more resistant than a traditional operating system to certain types of
network based technical attacks due to the limited feature sets. Additionally, limited functionality
operating systems are designed specifically for the mobile environment where battery life and
power efficiency are primary design drivers. This inherently limits the types of services that can
function effectively on the devices (e.g. traditional real-time anti-virus software) as the base
operating system may not be designed to allow installed applications enhanced execution priority
in the background and or the ability to examine the contents or communications associated within
another application. However, this same design methodology significantly limits the vectors
available for malware transmission and the device or application data actually accessible to
malware if a device becomes infected.
Tablet devices will have different risks associated depending on the installed and configured
methods for network access (e.g. ‘always on cellular’ vs. WiFi only). Physical risks associated
with this category are similar to the laptop category for enhanced likelihood of intentional theft or
device hijacking while unattended, while the technical risks are similar to the pocket device
category.
Pocket devices/Handheld devices
The pocket/handheld device category is technically similar or identical to the tablet category and
is primarily differentiated by device form factor. Pocket/handheld devices are characterized as
having a limited functionality operating system and a small form factor intended for carry in a
pocket or ‘holster’ attached to the body. The bulk of this category will be cellular ‘smartphones’
with integrated cellular data connectivity, however devices intended to be worn or carried on the
body (e.g. portable fingerprint devices) may also be included in this category if they operate using
a limited functionality operating system. Custom or specialty devices may meet the form factor
distinction for this category, but operate using a full feature operating system. In rare cases of this
nature the employing agency should apply security guidance and principles in this appendix for
both the laptop and pocket device categories.
Risks associated with this category are a reduced threat of theft to a stored devices (e.g. device left
unattended in a vehicle) since these devices are typically carried continuously by the authorized
user, but include a greater risk of temporary or permanent loss of control due to the device being
misplaced by the authorized user.
Due to the installation of a limited functionality operating system, the technical threat to these
devices via a network based attack is significantly lower than the laptop category, however, the
threat of unauthorized access at the device level may be higher if the device is lost due to technical
limits on multi-factor authentication to the operating system itself and practical limits to device
passwords due to screen/software keyboard limitations.
NOTE: Data accessible on pocket or tablet devices simply through the entry of a single device PIN
or password should not be considered secure due to the likelihood of enhanced password guessing
based on fingerprints/smudges on the device touch screen. Any data stored on devices of these
types should be protected within a separate secure container using Advanced Authentication.
Device Connectivity
There are three main categories of device connectivity that are associated with varying risk levels
and threats to the devices. The Three categories are: Cellular Network Only (always on), WiFi
Only (includes ‘on demand’ cellular), and Cellular (always on) + WiFi network. The risks
associated with connectivity categories are general risks and may apply differently to any
particular device at different points in its usage or lifecycle. Particular device configurations either
through the operating system or a third-party mobile device management (MDM) system may be

able to significantly control and define which particular connectivity risks may be associated with
a particular device.
Cellular Network Only (always on)
Cellular network connectivity is characterized by ‘always on’ network connection through the
device internal radio to a cellular network provider. There is a reasonable assurance that devices
with ‘always on’ cellular can be tracked, managed, or wiped remotely if lost or stolen. This will
significantly reduce risks associated with loss of the device and attempted illicit access to the
device. One important consideration for this risk category is characterization of the device as
‘always on’ or ‘on demand’. In effect the difference is typically a configuration setting, which in
some cases may be changeable by the user. In particular most cellular smart phones contain
‘airplane’ mode settings that disable all internal radios allowing a user authenticated to the device
operating system via password or personal identification number (PIN) to disable the cellular
system. Access to this functionality may be disabled through the use of some MDM systems which
would necessitate a complete power down of the device while carried on aircraft. Additionally,
someone illicitly obtaining a device with properly configured password requirements and screen
lock timeouts would be unlikely to guess the device password before the device was reported stolen
in order for them to disable the cellular connection and prevent tracking or a remote wipe of the
device.
Cellular networks do not allow for the same level of exposure of individual devices to random
access from the internet. This significantly reduces the potential network based attack vectors that
might reach a cellular connected device. The risk scenario in most cases from a network based
attack would be similar to a device protected behind rudimentary network defenses (e.g. standard
firewall but NOT advanced intrusion detection/prevention) Cellular device communications
cannot typically be accessed by other ‘eavesdropping’ devices physically close to them without
significant specialized equipment and can be considered well protected against network attacks
below the nation/state level of technical capability by the hosting technical infrastructure and
technology inherent in the device. However, network based attacks that utilize connections
initiated by the user device may still succeed over the cellular infrastructure. For this reason, the
technical protections inherent in the cellular infrastructure provide limited protection against
user/device initiated actions (e.g. web surfing on a cellular connected web browser). Therefore,
the protections provided by always on cellular connections are primarily in the ability to remotely
access the mobile device for tracking or data deletion in case of device loss or compromise, which
combined with a limited functionality device operating system, the protections are generally
equivalent to a ‘personal firewall’ if properly configured and supported by a well-designed
organizational infrastructure. However, that equivalency does not apply to full featured operating
systems connected through cellular infrastructure.
NOTE: It should be noted that a technically capable, intentional, thief knowingly obtaining an
‘always on’ cellular device for the purpose of data theft can physically disable the radio by utilizing
a Faraday cage or similar external electromagnetic shield device while attempting to guess the
device password. While technically possible these methods require specialized equipment and high
technical expertise and would be very unlikely to be employed except for specifically targeted
attacks. When always on cellular connectivity is combined with a robust incident reporting process
and user training for rapid response to device loss or theft, the associated risks can be minimized.
WiFi only (includes ‘on-demand’ cellular)
WiFi only devices do not include cellular radios or include cellular radio that must be manually
activated or ‘connected’ to the cellular network. They connect to the network or internet through
WiFi ‘hotspots’ or external access points or manually to cellular networks. Some MDM or device
configurations may be able to limit the types and specific WiFi access points the device can
connect to, which may change the risk scenario of the device to a similar risk scenario as the
Cellular Network Only scenario. However, if mobile devices are permitted (through technical and
or policy decisions) to connect to any WiFi access point designated by the device user, the overall
device risk scenario is high and the device may be accessible to a large number of potential network
based attack vectors. Unrestricted WiFi access is not recommended on any agency owned device,
but must be assumed to exist on any personally owned device authorized to access CJI. Significant
compensating controls may be needed to ensure devices accessing CJI over ‘public’ WiFi access
points are not susceptible to communications network eavesdropping, credential hijacking or any
of the various potential man-in-the-middle attacks possible through access point spoofing. The
communications security risks can be significantly mitigated by mandatory device configurations
(e.g. MDM based policy) that only allow devices to connect to cryptographically verified agency
controlled WiFi access points.
WiFi only or devices with ‘on-demand’ cellular access (e.g. user or event driven cellular access
initiated from the device and not from a centralized management location) are significantly more
at risk from data loss subsequent to device loss or theft as there is no guarantee the tracking or
remote wipe can be initiated once the device is out of agency control. This can be mitigated by
utilizing tracking/anti-theft products that require a periodic network connection to authorize access
and perform automated device locking (‘bricking’) or remote wipe if network connections are not
made within a specified period. Software of this nature is generally available for full featured
laptops but may not be available for limited feature mobile operating systems.
Cellular (always on) + WiFi Network
This is a hybrid scenario that has become typical with most ‘smartphones’. These devices contain
both the always on cellular connection, but may also be configured to access local WiFi networks
for enhanced bandwidth. In considering devices with these technical characteristics, the theft/loss
risks are similar to the cellular only scenario (due to tracking and remote access through the cellular
connection), while the data and network based risks must be considered to be similar to the WiFi
scenario unless the capability of the device to connect to WiFi networks is limited by technology
or policy to agency owned WiFi Access Points configured in accordance with the CJIS Security
Policy. Careful consideration must be made to the particular configurations, management systems,
and human oriented operational policies based on the particular technical capabilities and
configurations of these types of devices.
Incident Handling (CJIS Security Policy Section 5.3)
Additional or enhanced incident reporting and handing procedures will need to be developed to
cover mobile device operating scenarios. Various exploits and methods to compromise mobile
devices require either specialized equipment or lengthy operations to implement. Rapid response
to mobile device related incidents can significantly mitigate the risks associated with illicit data
access either on the device itself or within online data resources associated with the device through
an application or specialized interface. However, parallel or special incident handling procedures
with associated equipment or systems may need to be put in place to properly respond to incidents
involving mobile devices. This section lists three areas where enhanced incident handling and
response processes may need to be implemented to ensure mobile device compliance to the
incident handling policy in Section 5.3.
If personally owned devices are utilized within the environment in a Bring Your Own device
(BYOD) scenario, specialized and costly incident handling procedures and processes may need to
be developed to support compliance for those devices. The costs associated with enhanced incident
handling procedures may need to be incorporated in the cost and risk based analysis to allow
personally owned devices in the BYOD scenario, as the technical methods and risk to achieve
compliance under BYOD scenarios may exceed any cost savings potentially achieved through
BYOD.
Loss of device Control
Mobile device users should be trained and provided with explicit user actions in case positive
control of a mobile device is lost for any period of time. Loss of positive control means the device
is in the physical control of non-CJIS authorized individual or the device is left unattended in an
unsecure location (e.g. counter of the coffee shop). Even if the device is recovered quickly there
is significant risk that either the device settings could be tampered with or data on the device could
be illicitly accessed. The level of detail and particular scenarios identified in the agency incident
response plan should be consistent with the presence of persistent CJI on the device or the technical
means used to access CJI from the device (e.g. ask the question: “Is it reasonable to assume CJI
could be accessed”) as well as the degree of device configuration control exercised by the user
from the device main login. At a minimum, special incident handling procedures should be
developed for the following scenarios:





Device known to be locked, control loss of minimal duration
Device lock state unknown at time of control loss, duration of loss minimal
Device lock state unknown at time of control loss, duration of loss extended
Device known to be unlocked at time of control loss, duration of loss more than
momentary.

NOTE: Organizations should define appropriate time value criteria based on the operational
environment for the above scenarios. For instance, a ‘momentary’ loss of control might be
considered a matter of seconds in a situation where no one could reasonably have accessed the
device, while ‘minimal’ durations might include a few minutes of time and ‘extended’ periods
would be any time longer than a few minutes.
Other scenarios should be addressed as appropriate to the intended device employment, with
explicit user and organizational actions identified based on the device technologies and any
organizational management capabilities.
Total Loss of device
Incident response scenarios for the total loss of the device should be developed based on the
methods/storage of CJI on the device, the lock state of the device at time of loss (known locked,
known unlocked, or unknown), and the technical methods available for remote tracking or wiping
of the device. It is critical to implement incident handling procedures quickly in this case. Remote
wipe functions can be implemented for always on cellular devices with a high potential for success
that may include positive confirmation from the device that the wipe was completed. However, for
WiFi only and on demand cellular devices, incident handling procedures that lock the device out
of accessing CJI may be necessary, while there would be no guarantee that any CJI stored on the
device could not eventually be accessed. For this reason, CJI should not generally be stored directly
on WiFi only or on-demand cellular devices unless an extremely robust anti-tamper system is in
place on the device itself.
Potential device Compromise (software/application)
Incident response scenarios for potential device compromise through intentional or unintentional
user action should be developed to ensure compliance with policy. This includes rooting,
jailbreaking or malicious application installation on the device during a loss of device control
scenario or inappropriate user action in the installation of applications to the device (compromise
can occur from either intentional threat agent actions or accidental user actions). Triggers for this
incident handling process may be driven from either user notification or electronic detection of
device tampering from an audit or MDM compliance check.
Audit and Accountability (CJIS Security Policy Section 5.4)
The ability to implement some Audit and Accountability functions specified in the CJIS Security
Policy on mobile devices with limited function operating systems (e.g. Android, Apple iOS) is not
natively included within the operating system. Either additional device management systems,
enterprise mobility management (EMM) or MDM, or auditing from systems accessed by the
mobile device with be necessary to ensure appropriate levels of auditing exist.
Auditable Events (reference 5.4.1)
Some of the specific audit requirements in the CJIS Security Policy may not be technically relevant
to the mobile operating system due to its internal functioning. To achieve compliance with the
CJIS Security Policy it will be necessary in most cases to utilize some form of MDM or EMM
system. Additional auditable events that compensate for the technical limitations of limited
function mobile operating systems may be available through the use of MDM systems (e.g.
association of event with global positioning system (GPS) location of the device). Specific
auditable events of interest in the mobile environment will depend on the intended device usage,
compartmentalization of data on the device, and options available with the specific technologies
employed. For instance, item 2 in Section 5.4.1.1 indicates an auditable event includes attempts to
modify elements of user account modification. Due to the limited internal functions of mobile
operating systems, this event type is not relevant to the operating system itself as they are generally
provisioned with only a single non-modifiable user account on the device. To achieve compliance
in a scenario where CJI is stored or accessed from a secure application on the device, auditing of
access to the secure application either through application design, or third party MDM capability
may provide an acceptable compensating control. For compliance with the policy each auditable
event and event content must be compared to the particular technologies and applications
employed to determine if adequate compensating controls are being met for audit items that either
do not apply to mobile technologies or cannot be implemented within the technology itself.
Alternative and compensating controls that provide detailed audit of access to CJI either on the
mobile device itself or through a controlled application to a central server may provide equivalent
auditing capability to the events specified in the policy. However, multiple auditing systems may
be required to replicate the auditing provided at the operating system level by a full function
operating system. Therefore, the overall auditing design should take into account retrieval and

consolidation of events or audit data from multiple auditing systems as appropriate to comply with
policy.
Audit Event Collection
Mobile devices without an ‘always-on’ cellular connection may pose technical challenges to
ensure any audit records collected and stored on the mobile device itself can be retrieved for review
and analysis per the CJIS Security Policy. Alternatively systems which explicitly require a network
connection to a central server to access data or decrypt on-device storage may provide acc