Cellular Devices - Compensating Controls, v1.1

Defines conformance and assessment criteria for verifying that an organization employs compensating controls to meet advanced authentication requirements.
If an assessment step references organization-defined elements (E.g. <organization-defined personnel or roles>, <organization-defined frequency>, etc.), corresponding citations/excerpts must be provided to confirm that the organization has established and documented these values and that they apply as referenced in the conformance criteria.

Similarly, if a "Selection" among multiple options (e.g. [Selection (one or more): as needed; ]) is specified, evidence must be provided to establish that the option(s) implemented by the organization have been defined and documented.

The assessment step shall not be marked as satisfied without this evidence.

Assessment Step

1
Cellular Devices - Compensating Controls (CellularDevices-CompensatingControls)
Does the organization use CSO approved compensating controls to meet Advanced Authentication requirements? See conformance criteria for details on what qualifies.
Artifact
A1
Provide evidence (e.g. organizational policies, procedures, compliance/assessment reports, etc.) that support the assessor's response to this assessment step.
If conformance criteria reference organization-defined elements (e.g. <organization-defined personnel or roles>, <organization-defined frequency>, etc.), these values must be defined and documented by the organization.

Similarly, if the criteria specify a "Selection" among multiple options (e.g. [Selection (one or more): as needed; ]), the option(s) implemented by the organization must also be defined and documented.

Conformance Criteria (1)

C1
CSO approved compensating controls to meet the AA requirement on agency-issued smartphones and tablets with limited feature operating systems are permitted. Compensating controls are temporary control measures that are implemented in lieu of the required AA control measures when an agency cannot meet a requirement due to legitimate technical or business constraints. Before CSOs consider approval of compensating controls, Mobile Device Management (MDM) shall be implemented per Section 5.13.2. The compensating controls shall:
  1. Meet the intent of the CJIS Security Policy AA requirement
  2. Provide a similar level of protection or security as the original AA requirement
  3. Not rely upon the existing requirements for AA as compensating controls
  4. Expire upon the CSO approved date or when a compliant AA solution is implemented.

Additionally, compensating controls may rely upon other, non-AA, existing requirements as compensating controls and/or be combined with new controls to create compensating controls.

The compensating controls for AA are a combination of controls providing acceptable assurance only the authorized user is authenticating and not an impersonator or (in the case of agency-issued device used by multiple users) controls that reduce the risk of exposure if information is accessed by an unauthorized party.

The following minimum controls shall be implemented as part of the CSO approved compensating controls:
  • Possession and registration of an agency issued smartphone or tablet as an indication it is the authorized user
  • Use of device certificates per Section 5.13.7.3 Device Certificates
  • Implemented CJIS Security Policy compliant standard authenticator protection on the secure location where CJI is stored
Citation
CJIS-SP-V5.8
Section 5.13.7.2.1