Updated June 1, 2023

Outsourcing Agreement and FBI 

Permission Aid

Outsourcing Agreement and FBI Permission Aid

The intent of this job aid is to assist the Tribe/TGRA in the steps necessary to document and submit the 

request for permission to execute an outsourcing agreement with a contractor1 for the performance of 

noncriminal justice administrative functions2

. For instance, if a Tribe/TGRA would like to engage a 

contractor to develop or maintain a computer system for the Tribe/TGRA that contains FBI CHRI3 from 

the NIGC, the Tribe/TGRA shall receive written permission from the FBI Compact Officer before executing 

the contract.

Defining Contractor Functions and Access to CHRI Applicability

1. Identify if a contractor will have access to CHRI4. Specifically, describe in the space below each 

contractor function allowing them access to CHRI. In doing so, refer to the proposed contract for 

services to determine whether access to CHRI will occur. CHRI access includes the ability to view 

CHRI or the general use or handling or storage of CHRI, or a combination thereof.

2. If the contractor will not have access to CHRI, do not request written permission from the FBI 

Compact Officer and stop here. Please contact cau@nigc.gov for additional assistance if needed to 

determine if contractor functions involve access to CHRI.

1 Contractor means a government agency, a private business, non-profit organization or individual who has entered into a contract or agreement

with the TGRA.

2 Noncriminal Justice Administrative Functions mean routine functions relating to the processing of CHRI, including but not limited to the following: 

1. Making fitness determinations/recommendations; 2. Obtaining missing dispositions; 3. Disseminating CHRI, as authorized by Federal statute,

Federal Executive Order, or State statute approved by the United States Attorney General; 4 Undertaking other authorized activities relating to the

general handling, use, and storage of CHRI.

3 CHRI means information collected by criminal justice agencies on individuals consisting of identifiable descriptions and notations of arrests, 

detentions, indictments, or other formal criminal charges, and any disposition arising therefrom, including acquittal, sentencing, correctional 

supervision, or release. But, CHRI does not include identification information such as fingerprint records, if such information does not indicate 

involvement of the individual with the criminal justice system.

4 Access to CHRI means to view or make use of CHRI obtained from the III System.
Updated June 1, 2023

Outsourcing Agreement and FBI 

Permission Aid

3. If the contractor will have access to CHRI, use the proposed outsourcing agreement to assist 

in the composition of a request letter to the FBI Compact officer. Template letters are found 

at CJIS Resource Materials | National Indian Gaming Commission (nigc.gov). Review Step 1 to 

aid in listing the contractor functions in the letter that involve access to CHRI. 

4. Compare the request letter and the proposed contract. Ensure the contractor functions that 

involve access to CHRI in the outsourcing agreement mirror the request letter5

.

5. Send only the request letter to the FBI Compact Officer, Chasity S. Anderson, at 

csanderson@fbi.gov and iso@nigc.gov or mail to:

Mrs. Chasity S. Anderson Compact Officer

FBI Module D3 1000 Custer Hollow Road

Clarksburg, WV 26306

Sample Language of Contractor Functions and Contractor Access to CHRI

Instructions: Please review these examples to assist in the evaluation of contractor access to CHRI 

and as guidance for language in the outsourcing request letter. 

These are only examples and should not be copied verbatim in a request letter to the FBI Compact 

Officer.

Example 1:

Tribal IT will maintain and manage the Tribe/TGRA owned computer systems that store FBI CHRI

from the NIGC. The contractor access to CHRI is incidental, but necessary, as it relates to general 

handling and storage of CHRI on the computer system. Tribal IT will administer user accounts and 

privileges for the network, servers and computers where Tribe/TGRA authorized personnel make 

use of and store CHRI.

Example 2:

Casino IT staff will maintain and manage a computer system for the Tribe/TGRA. The Tribe/TGRA 

computer system receives and stores FBI CHRI from the NIGC. The access to CHRI is incidental, but 

necessary, as it relates to general handling and storage of CHRI on the computer system. The 

Tribe/TGRA owns the computer system and Casino IT staff administer user accounts and privileges

for the system.

Example 3:

The live scan contractor will maintain and upgrade software, maintain hardware, troubleshoot the

computer system and live scan device owned by the Tribe/TGRA. The computer system resides in 

the Tribe/TGRA facility in a physically secure location. The contractor access to CHRI is incidental,

but necessary, as it relates to general handling and storage of CHRI on the computer system.

Tribe/TGRA staff administer user accounts and privileges for the system and will work directly with 

the contractor personnel.

5 For NIGC CAU assistance, email the draft request letter and proposed outsourcing agreement to cau@nigc.gov for NIGC staff review. NIGC staff 

will review the request letter for clarity and consistency with the proposed outsourcing agreement before the TGRA sends the request letter to the 

FBI Compact Officer.
Updated June 1, 2023

Outsourcing Agreement and FBI 

Permission Aid

Example 4:

The licensing software vendor (the contractor) will store electronic licensing files that contain 

CHRI, and maintain and upgrade software. The files are stored in a cloud environment. The

contractor access to CHRI is incidental, but necessary, as it relates to general handling and storage 

of CHRI on the computer system and in the cloud environment.

Note: This example requires separate outsourcing agreements for each contractor. One agreement 

with the software contractor and one agreement with the cloud storage provider. For instance, if the 

contractor (licensing software vendor) subcontracts services (cloud storage) that would result in the 

subcontractor having access to CHRI, written permission for the execution of outsourcing 

agreements will be required for both the contractor and the subcontractor.