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CJIS-Security & Control

FIPS-Validated Encryption and Key Custody for CJI Archives

21 September 2025By Bilal Ahmed
FIPSEncryptionKey ManagementCJIArchivesCJISComplianceData Security

Introduction

When archiving Criminal Justice Information (CJI), agencies and vendors must implement the highest levels of security. The CJIS Security Policy requires the use of FIPS-validated encryption to safeguard sensitive data, along with robust key management practices to maintain custody and control. This blog explores how FIPS encryption and key custody practices apply to CJI archives.

What is FIPS-Validated Encryption?

  • FIPS (Federal Information Processing Standards): Cryptographic modules validated by NIST (e.g., FIPS 140-2, FIPS 140-3).
  • Requirement: All CJI stored or transmitted must use FIPS-validated algorithms for confidentiality and integrity.
  • Examples: AES-256 for encryption, SHA-256 for hashing, RSA/ECC for key exchange.

Key Benefits:

  • Meets CJIS compliance requirements.
  • Protects data against advanced threats.
  • Provides defensibility in audits and investigations.

Key Custody in CJI Archives

Encryption is only as strong as its key management. Improper custody of keys creates risk even if FIPS algorithms are used.

Core Principles:

  1. Key Segregation: Keep encryption keys separate from archived data.
  2. Custody Controls: Use Hardware Security Modules (HSMs) or cloud KMS systems.
  3. BYOK/Customer-Managed Keys: Agencies may retain control of their own keys rather than relying solely on vendors.
  4. Rotation & Expiry: Keys must be rotated periodically and retired securely.
  5. Access Restrictions: Limit key access to authorized personnel only, with multi-factor authentication.

Mapping to CJIS Security Policy

  • Section 5.10 (Cryptographic Controls): Requires encryption in transit and at rest using FIPS-validated modules.
  • Section 5.6 (Key Management): Stipulates key generation, storage, distribution, and destruction protocols.
  • Audit Readiness: Agencies must document key custody processes and demonstrate compliance in audits.

Best Practices for CJI Archives

  1. Use FIPS-Validated Modules: Ensure all cryptographic libraries are NIST-validated.
  2. Deploy HSMs or Cloud KMS: Securely generate, store, and rotate keys.
  3. Enable BYOK Options: Allow agencies to maintain control of encryption keys.
  4. Automate Key Rotation: Enforce time-based or usage-based key rotation.
  5. Log and Audit Key Access: Maintain immutable logs of all key usage events.
  6. Test Compliance Regularly: Validate encryption and custody practices through penetration tests and audits.

Conclusion

For CJI archives, FIPS-validated encryption and strong key custody are not optional — they are mandatory pillars of compliance and trust. By aligning encryption practices with CJIS Security Policy and enforcing strict key management, agencies can protect sensitive criminal justice data while ensuring defensibility and audit readiness.