As you may be aware, from July 1 2019, all APRA regulated entities will be required to adhere to a new prudential standard, CPS 234. According to APRA, “this Prudential Standard aims to ensure that an APRA-regulated entity takes measures to be resilient against information security incidents (including cyber-attacks) by maintaining an information security capability commensurate with information security vulnerabilities and threats.”
APRA-regulated entities that do not have a plan in place for being compliant with CPS 234 need not worry; in this blog, we break down the steps you need to take, as well as offer help in getting ready to be compliant.
Firstly, let’s look at the standard broadly. Minter Ellison offers a fantastic summary, which I’ve copied below:
- The board of an APRA-regulated entity is ultimately responsible for ensuring that the entity maintains its information security. More particularly the new standard requires that the board must 'ensure that the entity maintains information security in a manner commensurate with the size and extent of threats to its information assets and which enables the continued sound operation of the entity.
- Clearly defined roles/responsibilities: The new standard also requires that APRA regulated entities clearly define the information security-related roles and responsibilities of the Board, senior management, governing bodies, and individuals with responsibility for decision-making, approval, oversight, operations, and other information security function'.
- The new standard applies to 'all information assets managed by service providers, this includes 'all outsourcing of information assets, whether or not those assets form part of the outsourcing of material business activities' ie the new requirements on 'information security capability, information asset identification and classification, implementation of controls, testing control effectiveness and internal audit would apply to information assets, including those assets managed by related parties and third parties.
- Identifying and classifying information assets: The new standard requires regulated entities to classify all information assets by both 'criticality and sensitivity…irrespective of whether the regulated entity manages the information assets itself, or the information assets are managed by a third party or related party. Rather than establishing a threshold whereby controls would only apply to information assets deemed ’material’, APRA writes, the classification of assets in this way is intended to allow an entity to apply 'proportionate controls by assessing the impact of a loss of confidentiality, integrity, and availability of each information asset'.
- Implement controls to protect information assets and undertake regular testing and assurance of the effectiveness of controls: eg regulated entities will be required to annually review and test their information security response plans and internal audit activities will be required to include a review of the design and operating effectiveness of information security controls including those maintained by third parties.
Whilst the summary above offers a quick TL;DR version of the prudential standard, what does it mean in terms of activities, documents, and processes? So let’s break that down:
- A detailed set of roles, responsibilities, and accountabilities: Quite often, information security is dumped on the heads of a select few. With CPS 234 (and also sound reason) these responsibilities should be spread out as per the different roles in the organisational hierarchy. The goal here is to ensure that the right people are shouldering the responsibility of maintaining information security in a sustainable manner.
To understand how CPS 234 compares to ISO27001 and NIST download our helpful guide here.
These new standards are compulsory and are designed to help protect your organisation against a major security breach, which could seriously impact your business. Infotrust can help you navigate your way to compliance through building a map of the required activities that you can take to ensure you build out a sound security management practice within your organisation.
If you would like any other information feel free to contact Infotrust at info@infotrust.com.au or phone +61 2 9221 5555.
