Moving from an on-premises Exchange server to Microsoft Office 365 (O365) can have numerous benefits. Microsoft promotes its cloud productivity suite to yield better collaboration, increased productivity and a reduced cost of ownership. Many state and local government agencies eager for those benefits are making a move to the cloud with O365. According to Microsoft, approximately 5.2 million people use Microsoft Cloud for Government services including Azure Government, Office 365 Government, and Dynamics CRM Online Government, an impressive figure. However some government agencies need to access the FBI’s Criminal Justice Information Systems (CJIS) database to fulfill their mission. These agencies must achieve Office 365 CJIS compliance for security rules that restrict their ability to use O365 to exchange CJIS information, or CJI for short. This information must be protected in motion and at rest whenever it is outside a secure CJIS datacenter. Specific rules and the entire FBI CJIS Security Policy are posted here.
According to its website, Microsoft will sign a CJIS Security Addendum for Office 365 CJIS compliance in states where they have established CJIS Information Agreements. At this time there are 26 states where Microsoft has a signed CJIS Security Addendum – the most recent being with Missouri (February 2017). States that don’t have CJIS approval for O365 as of March 2017 include Alabama, Connecticut, Florida, Idaho, Indiana, Iowa, Louisiana, Maine, Maryland, Mississippi, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, North Dakota, Ohio, Oklahoma, Rhode Island, South Dakota, Vermont, West Virginia, Wisconsin and Wyoming.
While these states are not prohibited from using cloud services, they must be able to demonstrate Office 365 CJIS compliance if using those services. For them to use O365 to transmit CJI and PII (Personally Identifiable Information), the following CJIS security policy sections must be addressed.
“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 126.96.36.199.
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.
188.8.131.52 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 184.108.40.206 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.”
When an agency moves from an on premise secure Exchange server to O365, emails containing CJI must be protected – and that is commonly done through encryption. While O365 does contain an email encryption capability, that encryption occurs after the O365 cloud receives the unencrypted data. For those 24 states without a Microsoft CJIS Security Addendum, this is a violation of CJIS security policy. To achieve Office 365 CJIS compliance, the email must be encrypted before it arrives in the O365 cloud, and must remain encrypted until it is received or retrieved by the intended recipient.
One solution to this issue is to employ a third party email encryption solution designed to enhance the security of O365 and address the CJIS security policy issues. Such solutions offer more depth in encryption features and capabilities and integrate well with the Office 365 suite of applications. To achieve this end-to-end encryption requirement, the email can be encrypted at the Outlook client using an encryption plug-in, and routed through O365 to the recipient, or to an email encryption platform in a CJIS compliant datacenter to await recipient retrieval. In this way – O365 can be adopted, while maintaining CJIS compliance for PII and CJI. You can learn more about securing email in Office 365 here.
Office 365 is a great tool and can offer state and local agencies many benefits – and with proper implementation can meet the stringent requirements for CJIS security.