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CJIS-Security & Control

CJIS Audit Preparation Checklist for Archiving Programs

20 December 2023By Bilal Ahmed
CJISAudit PreparationArchivesCompliancePublic SafetyChecklistCJI Security

Introduction

Agencies managing Criminal Justice Information (CJI) must undergo regular audits to demonstrate compliance with the CJIS Security Policy. Archiving programs are a key focus area, as they involve long-term storage, retention, and access to sensitive data. Preparing for these audits requires structured documentation, technical readiness, and operational discipline. This blog provides a CJIS audit preparation checklist tailored for archiving programs.

CJIS Audit Preparation Checklist

1. Policies & Documentation

  • Maintain updated policies for classification, retention, and deletion of CJI.
  • Ensure incident response and disaster recovery plans reference archives.
  • Document chain-of-custody processes for digital evidence.

2. Access Controls

  • Enforce MFA for all archive access, including remote and privileged users.
  • Apply least-privilege principles with role-based access control (RBAC).
  • Document procedures for granting, modifying, and revoking access.

3. Encryption & Key Management

  • Verify encryption in transit and at rest using FIPS-validated algorithms.
  • Ensure proper key custody with KMS, BYOK, or HSMs.
  • Maintain logs of key rotation and retirement.

4. Logging & Audit Trails

  • Ensure all archive interactions are logged (search, export, deletion, modification).
  • Store logs in immutable, tamper-proof storage.
  • Retain logs for the duration required by CJIS.

5. Retention & Deletion

  • Align retention schedules with state/federal mandates.
  • Demonstrate defensible deletion practices after retention expiration.
  • Document exceptions (e.g., legal hold overrides).

6. Incident Response

  • Maintain a breach response plan aligned with CJIS notification requirements.
  • Conduct tabletop exercises simulating archive-related incidents.
  • Preserve logs and evidence during incident handling.

7. Personnel & Training

  • Verify background checks for staff with archive access.
  • Provide ongoing CJIS-focused security awareness training.
  • Document attendance and testing for compliance records.

8. Vendor & Contractual Compliance

  • Review MSAs to confirm vendor CJIS obligations.
  • Ensure vendors undergo CJIS-compliant personnel screening.
  • Validate vendor audit readiness and reporting processes.

9. Testing & Validation

  • Conduct internal mock audits prior to CJIS reviews.
  • Validate DR/BCP plans with RTO/RPO testing.
  • Rehash archived evidence periodically to prove data integrity.

Best Practices

  • Centralize Documentation: Keep policies, logs, and audit evidence accessible in one system.
  • Automate Reporting: Generate compliance reports directly from archive platforms.
  • Regular Reviews: Update policies annually or after regulatory changes.
  • Cross-Agency Collaboration: Coordinate with partner agencies to align on audit practices.

Conclusion

Preparing for a CJIS audit is about more than passing a compliance check—it’s about ensuring the security, integrity, and availability of CJI archives. By following this checklist, agencies can demonstrate readiness, strengthen compliance posture, and build public trust in their handling of sensitive criminal justice data.