Introduction
When archives contain Criminal Justice Information (CJI), the stakes for incident response and breach notification are extremely high. The CJIS Security Policy outlines requirements that agencies must follow to detect, respond to, and report breaches promptly and defensibly. This blog examines how incident response (IR) and breach notification processes must be adapted to CJIS environments to protect sensitive data and maintain compliance.
Why Alignment with CJIS Matters
- Regulatory Mandate: CJIS requires agencies and vendors to follow strict timelines and processes for breach notification.
- Data Sensitivity: CJI includes criminal records, biometrics, and investigative data that must be safeguarded.
- Public Trust: Quick and transparent response prevents reputational damage.
- Audit Defensibility: Agencies must demonstrate documented IR and notification workflows during audits.
Incident Response Essentials under CJIS
1. Preparation
- Maintain documented incident response policies tailored for archives.
- Train archive admins and IT staff on CJIS-specific breach scenarios.
- Integrate monitoring and SIEM tools for early detection.
2. Detection
- Monitor audit logs for anomalies (suspicious logins, mass exports, failed access attempts).
- Use automated alerting to flag high-risk events immediately.
- Conduct regular penetration testing to identify gaps.
3. Containment
- Isolate compromised accounts, systems, or tenants quickly.
- Enforce least-privilege access to minimize exposure.
- Preserve evidence integrity using chain-of-custody documentation.
4. Eradication & Recovery
- Remove malicious actors and patch vulnerabilities.
- Validate archive integrity through fixity checks and hash validation.
- Resume operations only after compliance validation.
Breach Notification Aligned to CJIS
CJIS requires agencies to:
- Notify the CJIS Systems Officer (CSO) and designated authorities promptly.
- Document the scope, impact, and timeline of the breach.
- Provide forensic evidence and corrective measures.
- Maintain immutable records of the incident for audit and review.
Best Practices:
- Define clear timelines for internal and external notifications.
- Automate escalation workflows tied to detection systems.
- Establish communication protocols with partner agencies.
- Include breach scenarios in tabletop exercises.
Best Practices for CJIS-Aligned IR
- Embed CJIS Requirements in IR Plans: Map each step to CJIS Security Policy controls.
- Continuous Training: Provide recurring training for IT, records, and legal staff.
- Mock Breach Drills: Simulate archive breach scenarios regularly.
- Vendor Obligations: Ensure MSAs include breach notification timelines and responsibilities.
- Audit Readiness: Maintain detailed logs and incident documentation for review.
Conclusion
Incident response and breach notification aligned to CJIS ensure that archives containing CJI remain secure, compliant, and defensible. By preparing comprehensive IR plans, enforcing rapid breach notification, and documenting all actions, agencies can safeguard sensitive data while maintaining public trust and audit readiness.