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CJIS-Security & Control

Vendor Management and MSAs under CJIS: Roles and Obligations

21 September 2025By Bilal Ahmed
CJISVendor ManagementMaster Service AgreementsCompliancePublic SafetyCJI Security

Introduction

Agencies handling Criminal Justice Information (CJI) often rely on third-party vendors to provide archiving, cloud, or security services. Under the CJIS Security Policy, these vendors are subject to strict compliance requirements. Managing vendors effectively — and defining obligations through Master Service Agreements (MSAs) — ensures agencies remain compliant, defensible, and secure. This blog explores vendor management practices and the roles and obligations defined in MSAs under CJIS.

Vendor Roles under CJIS

Vendors providing services that involve access to or processing of CJI must:

  • Comply with CJIS Security Policy: Adhere to all relevant controls, including encryption, access, and audit requirements.
  • Undergo Background Checks: Vendor employees with access to CJI must complete security vetting.
  • Support Audits: Vendors must cooperate with compliance audits conducted by agencies or regulators.
  • Secure Infrastructure: Vendors must ensure their systems (on-premise or cloud) are CJIS-compliant.
  • Document Responsibilities: Clearly define how CJI will be stored, processed, and protected.

Master Service Agreements (MSAs) under CJIS

An MSA is the binding contract between the agency and the vendor, defining roles, responsibilities, and accountability. For CJIS compliance, MSAs should include:

1. Security Requirements

  • Explicit adherence to CJIS Security Policy controls.
  • Use of FIPS-validated encryption for CJI.
  • Requirements for MFA, RBAC, and least-privilege access.

2. Data Ownership & Custody

  • Agencies retain ownership of all CJI.
  • Vendors act only as custodians, with no rights beyond service delivery.
  • Clear exit clauses defining how data will be returned or destroyed at contract end.

3. Audit & Compliance

  • Vendor obligations to provide audit trails and logs on request.
  • Agreement to participate in CJIS audits and provide compliance evidence.
  • Defined timelines for breach reporting.

4. Personnel & Background Screening

  • Requirement that vendor personnel with CJI access undergo CJIS-compliant background checks.
  • Immediate revocation of access upon termination or role change.

5. Incident Response

  • Vendors must support agency IR plans.
  • Breach notification requirements aligned with CJIS timelines.
  • Preservation of logs and evidence for investigations.

6. Termination & Portability

  • Defined procedures for secure return, transfer, or destruction of CJI.
  • Provisions to avoid vendor lock-in and ensure defensible portability.

Best Practices for Vendor Management

  1. Due Diligence: Evaluate vendors for CJIS compliance before onboarding.
  2. Contractual Alignment: Ensure MSAs map directly to CJIS Security Policy requirements.
  3. Ongoing Oversight: Regularly review vendor compliance, logs, and reports.
  4. Audit Collaboration: Conduct joint audits with vendors for readiness.
  5. Exit Planning: Plan for secure, defensible offboarding of vendors at contract end.

Conclusion

Vendor management and MSAs are critical to ensuring CJIS compliance when third parties handle CJI. By defining roles, responsibilities, and obligations in MSAs — and maintaining continuous oversight — agencies can build strong partnerships that uphold compliance, security, and public trust.