CRIMINAL HISTORY RECORD INFORMATION (CHRI)
The Board of Education's (Board) intent of this policy is to ensure the protection of the Criminal Justice Information (CJI) and its subset of Criminal History Record Information (CHRI) until the information is purged or destroyed in accordance with applicable record retention rules.
This policy applies to any electronic or physical media containing FBI CJI while being stored, accessed or physically moved from a secure location within the District. This policy applies to any authorized person who accesses, stores, and/or transports electronic or physical media.
Criminal Justice Information (CJI) and Criminal History Record Information (CHRI)
CJI refers to all of the FBI CJIS provided data necessary for law enforcement and civil agencies to perform their missions including, but not limited to biometric, identity history, biographic, property, and case/incident history data.
CHRI, is a subset of CJI and for the purposes of this document is considered interchangeable. Due to its comparatively sensitive nature, additional controls are required for the access, use and dissemination of CHRI. In addition to the dissemination restrictions outlined below, Title 28, Part 20, Code of Federal Regulations (CFR), defines CHRI and provides the regulatory guidance for dissemination of CHRI.
Proper Access, Use, and Dissemination of CHRI
Information obtained from the Interstate Identification Index (III) is considered CHRI. Rules governing the access, use, and dissemination of CHRI are found in Title 28, Part 20, CFR. The III shall be accessed only for an authorized purpose. Further, CHRI shall only be used for an authorized purpose consistent with the purpose for which III was accessed. Dissemination to another agency is authorized if (a) the other agency is an Authorized Recipient of such information and is being serviced by the accessing agency, or (b) the other agency is performing noncriminal justice administrative functions on behalf of the authorized recipient and the outsourcing of said functions has been approved by appropriate CJIS Systems Agency (CSA) or State Identification Bureau (SIB) officials with applicable agreements in place.
Personnel Security Screening
Access to CJI and/or CHRI is restricted to authorized personnel. Authorized personnel is defined as an individual, or group of individuals, who have completed security awareness training and have been granted access to CJI data.
Security Awareness Training
Basic security awareness training is required within six months of initial assignment, and biennially thereafter, for all personnel with access to said confidential information.
All CJI and CHRI information shall be securely stored. The District will maintain a current list of authorized personnel. Authorized personnel will take necessary steps to prevent and protect the District from physical, logical and electronic breaches.
Controls shall be in place to protect electronic and physical media containing CJI while at rest, stored, or actively being accessed. "Electronic media" includes memory devices in laptops and computers (hard drives) and any removable, transportable digital memory media, such as magnetic tape or disk, backup medium, optical disk, flash drives, external hard drives, or digital memory card. "Physical media" includes printed documents and imagery that contain CJI.
The District shall securely store electronic and physical media within physically secure locations. The District restricts access to electronic and physical media to authorized individuals. If physical and personnel restrictions are not feasible then the data shall be encrypted per Section 220.127.116.11. When no longer usable, information and related processing items shall be properly disposed of to ensure confidentiality.
Media Sanitization and Disposal
When no longer usable, hard drives, diskettes, tape cartridges, CDs, ribbons, hard copies, print-outs, and other similar items used to process, store and/or transmit FBI CJI shall be properly disposed of in accordance with measures established by Litchfield Public Schools.
Physical media (print-outs and other physical media) shall be disposed of by one of the following methods:
1)shredding using Litchfield Public Schools issued shredders.
2)placed in locked shredding bins for a private contractor to come on-site and shred, witnessed by Litchfield Public Schools personnel throughout the entire process.
Electronic media (hard-drives, tape cartridge, CDs, printer ribbons, flash drives, printer and copier
Hard-drives, etc.) shall be disposed of by one of the Litchfield Public Schools methods:
1)Overwriting (at least 3 times) - an effective method of clearing data from magnetic media. As the name implies, overwriting uses a program to write (1s, 0s, or a combination of both) onto the location of the media where the file to be sanitized is located.
2)Degaussing - a method to magnetically erase data from magnetic media. Two types of degaussing exist: strong magnets and electric degausses. Note that common magnets (e.g., those used to hang a picture on a wall) are fairly weak and cannot effectively degauss magnetic media.
3)Destruction – a method of destroying magnetic media. As the name implies, destruction of magnetic media is to physically dismantle by methods of crushing, disassembling, etc., ensuring that the platters have been physically destroyed so that no data can be pulled.
IT systems that have been used to process, store, or transmit FBI CJI and/or sensitive and classified information shall not be released from Litchfield Public School's control until the equipment has been sanitized and all stored information has been cleared using one of the above methods.
The District shall manage information system accounts, including establishing, activating, modifying, reviewing, disabling, and removing accounts. The District shall validate information systems accounts at least annually and shall document the validation process.
All accounts shall be reviewed at least annually by the designated CJIS point of contact (POC) or his/her designee to ensure that access and account privileges commensurate with job functions, need-to-know, and employment status on systems that contain Criminal Justice Information. The POC may also conduct periodic reviews.
Reporting Information Security Events
The District shall promptly report incident information to appropriate authorities to include the state CSA or SIB's Information Security Officer (ISO). Information security events and weaknesses associated with information systems shall be communicated in a manner allowing timely corrective action to be taken. Formal event reporting and escalation procedures shall be in place. Wherever feasible, the agency shall employ automated mechanisms to assist in the reporting of security incidents. All employees, contractors and third party users shall be made aware of the procedures for reporting the different types of event and weakness that might have an impact on the security of agency assets and are required to report any information security events and weaknesses as quickly as possible to the designated point of contact.
Policy Violation/Misuse Notification
Violation of any of the requirements contained in the CJIS Security Policy or Title 28, Part 20, CFR, by any person can result in significant disciplinary action, up to and including loss of access privileges, civil and criminal prosecution and/or termination.
Likewise, violation of any of the requirements contained in the CJIS Security Policy or Title 28, Part 20, CFR, by any visitor can result in similar disciplinary action against the sponsoring employee, and can also result in termination of services with any associated consulting organization or prosecution in the case of criminal activity.
(cf. 4112.5/4212.5 – Security Check/Fingerprinting)
(cf. 4112.51/4212.51 – Employment/Reference Checks)
Legal Reference: Conn. Gen. Stat. § 1-221d – Criminal history records checks of school personnel. Fingerprinting. Termination or dismissal. (as amended by PA 16-67)
Conn. Gen. Stat. § 29-17a – Criminal history checks. Procedure. Fees
PA 16-67 An Act Concerning the Disclosure of Certain Education Personnel Records.
Criminal Justice Information Services (CJIS) Security Policy, Version 5.4, U.S. Department of Justice, Federal Bureau of Investigation, Criminal Justice Information Services Division, October 6, 2015.
CJIS Security Policy
Title 28 C.F.R. Part 20
Litchfield Board of Education
Policy Adopted: 9/6/2017
Policy Revised: 10/3/2018