Most CJIS gaps don’t come from a lack of policy. They come from a lack of data-level enforcement.
That’s because CJIS has quietly shifted from a perimeter and system-focused model to a data-centric one. Assessors aren’t just asking whether controls exist; they’re asking whether CJI is identified, protected based on sensitivity, restricted to authorized users, auditable, and disposed of when no longer required. CJIS Security Policy v6 makes that expectation clearer than ever: assessors are looking for evidence that agencies and partners can identify where CJI exists, restrict access based on sensitivity, monitor activity, and manage retention and disposal. Not just document intent. The policy language has caught up to reality: modern CJIS compliance is a data governance problem, not a system checklist.
In this context, Microsoft Purview provides the data discovery, classification, protection, and auditing controls, while tools like Microsoft Compliance Manager are used to map CJIS requirements to those controls and track implementation status over time.
Let’s walk through how those requirements map to real-world data controls.
CJIS Compliance Is a Data Visibility Problem First
CJI no longer lives in a single system. It moves through email, file shares, Teams, cloud workloads, endpoints, and third-party integrations. Without visibility into where CJI exists and how it’s handled, even well-documented CJIS programs struggle to demonstrate consistent enforcement.
CJIS implicitly expects agencies to:
- Know where CJI resides
- Apply protections based on sensitivity
- Control how it's accessed, shared, and retained
These expectations are threaded through Information Exchange Agreements, Data Handling, Media Protection, and Oversight sections. During CJIS assessments, we consistently see agencies treating documented policy as synonymous with control, rather than focusing on verifiable, technical enforcement. These gaps often surface when teams are asked to prove how CJI is protected in practice rather than simply described intent.
Before any CJIS control can work, discovery and classification must come first.
Establishing the Foundation: Discovery and Classification at Scale
Every CJIS control downstream (access restriction, auditing, retention, incident response) depends on accurate identification of CJI.
Modern data governance platforms address this by:
- Scanning data across email, collaboration platforms, endpoints, and cloud services
- Using sensitive information types (built-in and custom) to detect CJIS-related data elements
- Applying labels that persist with the data, regardless of where it moves
In Microsoft 365 environments, Purview can support this requirement by enabling centralized discovery across email, collaboration tools, endpoints, and cloud workloads. Classification isn’t a one-time exercise. It’s continuous, which matters when assessors ask how you know new CJI isn’t slipping outside policy boundaries.
This approach directly supports the CJIS expectation that agencies understand their CJI footprint and apply protections consistently, not just at system boundaries.
Enforcing Least Privilege at the Data Layer and Preventing Accidental Disclosure
CJIS has always emphasized restricted access to authorized users. The problem is that identity-based controls alone aren’t enough anymore.
Once CJI is shared, copied, or moved into collaboration tools, identity-only access controls tend to overexpose data...often unintentionally. In practice, the real CJIS risk we most often see isn’t malicious insiders, but accidental sharing and excessive access once CJI enters collaboration and productivity tools.
Data-aware controls change that equation.
By using sensitivity labels tied to CJI classification, security teams can:
- Restrict access and sharing based on data sensitivity, not just user role
- Prevent external sharing of labeled CJI by default
- Apply encryption and usage restrictions automatically
- Provide clear user cues and guardrails without blocking legitimate work
In Purview-enabled environments, these controls integrate with Entra ID, so identity context and data sensitivity work together. That alignment supports least privilege in practice (not just in documentation) while reducing the operational burden of manual access reviews.
CJIS assessors look for exactly this kind of enforcement evidence, especially in Access Control and Identification & Authentication domains.
Least privilege doesn’t stop at access. CJIS also expects agencies to prevent unauthorized disclosure of CJI after access is granted, particularly through email, collaboration tools, and file sharing, where most real-world exposure occurs.
Data loss prevention controls help close that gap. When CJI is labeled, DLP policies can monitor and restrict how it’s shared across email, Teams, file storage, endpoints, and cloud applications. That allows agencies to prevent risky actions — such as external sharing or transmission to unauthorized recipients — before they become incidents.
Just as important, these controls introduce guardrails instead of friction. Policy tips and alerts provide users with real-time feedback at the moment of action, reinforcing CJIS handling expectations without blocking legitimate work. From an assessor’s perspective, this demonstrates active enforcement of information protection and transmission requirements rather than simple reliance on policy language or user training.
Accountability: Proving What Happened, When, and Who Was Involved
When CJIS issues arise, agencies are expected to answer three questions quickly and defensibly:
- Who accessed the data?
- What actions were taken?
- Was it handled according to policy?
This is where many teams struggle because logs are fragmented, incomplete, or hard to correlate.
CJIS audit and accountability requirements aren’t about raw log volume. They’re about usable evidence. Evidence that can be produced quickly, explained clearly, and defended under review.
Modern governance platforms help by:
- Centralizing audit logs for access, sharing, labeling, and data movement
- Correlating events across users, devices, and services
- Supporting investigations into suspected misuse or policy violations
- Retaining audit data in line with CJIS and state requirements
Instead of assembling evidence reactively, teams can demonstrate ongoing monitoring and enforcement; an approach we’ve seen significantly reduce audit disruption and findings (and one we’ve written about before).
That same accountability foundation is critical when CJIS-related incidents occur. Beyond knowing what happened, agencies must be able to preserve evidence, support investigation, and meet reporting expectations without delay.
Modern data governance platforms support this by enabling targeted content search, eDiscovery, and legal hold capabilities tied directly to labeled CJI. When an incident is suspected, teams can quickly identify relevant data, preserve it in place, and prevent alteration or deletion while investigations and post-incident reviews are underway.
Because audit logs, classification context, and retention policies are already aligned, incident response becomes an extension of normal operations rather than a separate, manual process. From an assessor’s perspective, this demonstrates that accountability and incident response are operationalized together, not handled ad hoc after the fact.
Retention, Disposal, and the Risk of Keeping Too Much
One of the most underestimated CJIS risks is over-retention.
CJIS is explicit: if you retain CJI, you must protect it, and when it’s no longer required, you must dispose of it securely. Holding onto data “just in case” increases legal exposure, breach impact, and audit risk without providing operational value.
Manual retention processes don’t scale in modern environments. They also create inconsistencies (exactly what assessors flag).
To meet CJIS retention and disposal expectations consistently, agencies need policy driven enforcement. Tools like Purview allow teams to:
- Define retention labels aligned to CJIS, state, and records requirements
- Automatically retain or delete data based on regulatory and business rules
- Apply consistent disposal controls across email, files, and collaboration platforms
- Reduce reliance on manual cleanup efforts
This doesn’t just improve compliance. It meaningfully reduces risk by shrinking the CJI footprint over time. Something many agencies know they should do but struggle to operationalize.
Continuous Readiness: Turning CJIS Into an Ongoing Practice
CJIS assessments aren’t designed to be once-every-three-years fire drills. They assume ongoing oversight, monitoring, and enforcement.
The agencies that fare best don’t prepare for audits. They operate in a state of readiness.
Centralized governance platforms support this by:
- Providing dashboards that show control coverage and enforcement status
- Surfacing gaps early, before they become findings
- Enabling repeatable evidence collection instead of one-off efforts
Many teams pair this approach with Microsoft Compliance Manager to track CJIS-related requirements, map them to technical and procedural controls, and maintain visibility into implementation health over time. That combination helps reduce last-minute scrambling and supports more defensible, repeatable assessments.
This is the difference between passing a CJIS audit and running a CJIS-aligned security program.
Conclusion: Tools Enable CJIS Compliance, But They Don’t Ensure It
No single platform ensures CJIS compliance. While we use the example of Microsoft Purview throughout the article to show how agencies can address CJIS data requirements, Purview is ultimately an enabling platform that supports technical enforcement and evidence collection. CJIS still depends on:
- Clear ownership of policies and controls
- Proper configuration and ongoing tuning
- Continuous monitoring and review
- Disciplined operational practices
What tools like Purview do well is remove friction. They reduce manual effort, close visibility gaps, and make enforcement observable. That frees security teams to focus on judgment, oversight, and improvement; the human work CJIS ultimately depends on.
Agencies that succeed with CJIS treat data, controls, and accountability as a single system. Not during audits. Every day.
If you want help operationalizing CJIS requirements across modern data environments (with or without Microsoft Purview), reach out to our CJIS compliance services experts, who can help build programs that are enforceable, defensible, and sustainable.
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