What is APRA CPS 234?​

APRA CPS 234 June 2024 Deadline

APRA has now released its final deadline for all remaining regulated entities to submit their CPS 234 tripartite assessments, and is calling for all remaining APRA CPS 234 tripartite assessments to be submitted by end of June 2024.

Outlined as part of its 2020-2024 Cyber Security Strategy, the one-off tripartite assessments require regulated entities to engage an independent auditor to report on their compliance against CPS 234 – Information Security.

What is APRA CPS 234?

APRA CPS 234 is a prudential standard that applies to all ‘APRA-regulated entities’. The finalised standard, known as APRA CPS 234, is designed to ensure APRA-monitored organisations are more resilient to cyber-attacks and can respond quickly should a security breach occur.

APRA CPS 234, 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 institutions must go beyond simply following the new standards, they must demonstrate compliance with the new CPS 234 standard across all of its services in order to minimise the likelihood and impact of information security incidents on the confidentiality, integrity or availability of information assets, including those managed by related or third parties.

How does Sekuro approach APRA CPS 234 compliance?

Sekuro adopts a pragmatic approach when assessing an organisation’s compliance against the Australian Prudential Regulation (APRA) CPS 234, utilising our industry knowledge and experience with regulatory standards. APRA recognised the threat in the digital environment and implemented the new APRA CPS 234 to ensure that APRA-regulated entities had sufficient information security protections.

At the conclusion of the assessment, Sekuro will provide a set of recommendations on how to address any identified gaps against APRA CPS 234. A commentary on the current status of compliance, and any improvement opportunities to uplift and strengthen existing controls further will also be provided.

The key steps to achieving the above include, but not limited to:

  1. Gathering and assessing information available
  2. Reviewing existing documentation
  3. Conducting interviews and workshops with relevant stakeholders
  4. Consolidating our findings
  5. Delivering the assessment report
  6. Presenting findings to management (if required)

Depending on the size and maturity of the organisation, and the number of controls present in the environment, this will determine the total effort required to complete the assessment. 

Smaller Organisation Setting
Larger & More Complex Organisations
Up to 2 weeks
4 or more weeks

Who is responsible for compliance to APRA CPS 234?

The Board of an APRA-regulated entity is ultimately responsible for ensuring that the entity maintains its information security.

More Information on APRA CPS 234

APRA CPS 234 started on 1 July 2019; by December 2020, the level of compliance was still in its infancy across APRA regulated entities. APRA noted areas of weaknesses included testing programs, control environments and incident response capabilities.

APRA granted more than 100 requests for regulatory relief to entities struggling to meet the 1 January 2021 deadline for CPS 234 relating to third-party services, but “with consistent evidence that many entities are failing to adequately comply with CPS 234”.

APRA introduced a new cyber-security strategy for 2020 to 2024 that seeks to uplift cyber-security standards and heighten accountability where companies fail to meet their legally binding requirements. Although the board’s accountability is a focus of this regulatory standard, APRA has mandated further board and management accountability. Non-compliance may lead to a breach notice that requires a rectification plan, and action to be taken in a timely manner. Failure to do so may result in formal enforcement action.

APRA requests one-off, tripartite independent cyber-security reviews across all its regulated industries from 2021. It requires boards to use an external audit firm to review CPS 234 compliance and report back to both APRA and the board. 

FAQs

APRA-regulated entities include:

  • Authorised deposit-taking institutions (ADIs), including foreign ADIs, and non-operating holding companies authorised unde r the Banking Act (authorised banking NOHCs);
  • General insurers, including Category C insurers, non-operating holding companies authorised under the Insurance Act (authorised insurance NOHCs), and parent entities of Level 2 insurance groups;
  • Life companies, including friendly societies, eligible foreign life insurance companies (EFLICs) and non-operating holding companies registered under the Life Insurance Act (registered life NOHCs);
  • Private health insurers registered under the PHIPS Act; and (e) RSE licensees under the SIS Act in respect of their business operations.

As indicated by the recent update from APRA, formal enforcement action may be taken for non-compliance, and potential breach notice issued for lack of timely action.

ISO 27001 provides a baseline to work from as it is an internationally recognised information security standard. There is a one-to-one mapping of the nine key requirements from APRA CPS 234 to the ISO 27001 information security standard.

Depending on where your gaps are, we will work with you to address the key areas of concern as a priority and devise a plan for any improvement activities required to further uplift the existing controls. Contact us and we will walk through the process with you.

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Aidan Tudehope

Co-Founder of Macquarie Technology

Aidan Tudehope, Co-Founder of Macquarie Technology

Aidan is co-founder of Macquarie Telecom and has been a director since 1992. He is the Managing Director of Macquarie Government & Hosting Group with a focus on business growth, cyber security and customer satisfaction. 

Aidan has been responsible for the strategy and execution of the investment in Intellicentre 4 & 5 Bunkers, Macquarie Government’s own purpose-built Canberra data centre campus. This facility is leveraged to deliver Secure Cloud Services and Secure Internet Gateway.

With a unique pan-government view on the cyber security landscape, we are invested in leading the contribution from the Australian industry on all matters Cyber policy related.

Aidan holds a Bachelor of Commerce Degree.

James Ng

CISO, Insignia Financial

James Ng, CISO, Insignia Financial

James is a leader with a range of experience across various cyber security, technology risk and audit domains, bringing a global lens across a diverse background in financial services, telecommunications, entertainment, consulting and FMCG (Fast Moving Consumer Goods). He is currently the General Manager – Cyber Security at Insignia Financial and most recently was at AARNet (Australia’s Academic and Research Network) where he oversaw a managed Security Operations Centre (SOC) capability for Australian universities. Prior to this James was the acting Chief Information Security Officer for Belong and led the cyber governance and risk team at Telstra.

Noel Allnutt

CEO, Sekuro

Noel Allnutt CEO | Sekuro

Noel is a driven and award-winning IT leader. He has a passion for developing great teams and accelerating client innovation, and in enabling organisations to create a secure and sustainable competitive advantage in the digital economy. Noel also hosts the ‘Building Resilience Podcast,’ which explores the world of sport and deconstructs the tools and ethos of world-class athletes that can help create growth and optimise business and life.

Audrey Jacquemart

Bid Manager, Sekuro

Audrey Jacquemart, Bid Manager, Sekuro

Audrey is an innovative cybersecurity professional with a versatile profile spanning across Product Management, Presales and Delivery. She has worked within organisations from start-ups to large international organisations in Europe and APAC before joining Sekuro.

Nicolas Brahim

Principal Consultant, CRP and OT

Nicolas Brahim, Principal Consultant, CRP and OT

Nico leads Sekuro’s Cyber Resilience Program and OT Cybersecurity, ensuring continuous support and effective program execution for our clients. With over a decade in the security industry, including the creation and leadership of several Security Programs for IT and OT across Australia, New Zealand, Argentina, Chile and the US, his core philosophy emphasises an equal balance of people, process, and technology in delivering actionable and simple solutions.

Trent Jerome

Chief Financial Officer, Sekuro

Trent Jerome

Trent is a seasoned CFO with over 30 years’ experience in Finance. Trent has broad experiences across Capital raises, debt financing, M&A and business transformation. He is a CPA and member of AICD. Trent works with Boards around risk and risk mitigation plans and assists Boards in navigating the risk mitigation versus cost conversation.

Ada Guan

CEO and Board Director, Rich Data Co

Ada Guan, CEO and Board Director, Rich Data Co

Ada is the CEO and Co-founder of Rich Data Co (RDC). RDC AI Decisioning platform provides banks the ability to make high-quality business and commercial lending decisions efficiently and safely. With over 20 years of global experience in financial services, software, and retail industries, Ada is passionate about driving financial inclusion at a global scale.

Before launching RDC in 2016, Ada led a Global Client Advisor team at Oracle Corporation, where she advised Board and C-level executives in some of the largest banks globally on digital disruption and fintech strategy. She also drove Oracle’s thought leadership in banking digital transformation for Global Key Accounts. Previously, Ada implemented a multi-million dollar program to deliver a mission-critical services layer for Westpac Bank in Australia and formulated the IT strategy that was the basis of an $800m investment program to transform Westpac’s Product and Operation division and complete the merger with St. George Bank. Ada is an INSEAD certified international director and holds an EMBA from the Australia Graduate School of Management, and a Master of Computer Engineering from the University of New South Wales, Australia. She also graduated from the Executive Insight Program at Michigan University Ross Business School and IESE Business School.

Megan Motto

Chief Executive Officer, Governance Institute of Australia

Megan Motto, CEO, Governance Institute of Australia

Megan Motto is Chief Executive Officer of Governance Institute of Australia, a national education provider, professional association and leading authority on governance and risk management. The Institute advocates on behalf of professionals from the listed, unlisted, public and not-for profit sectors.

Megan has over 25 years of experience with large associations, as a former CEO of Consult Australia, as well as holding significant positions in Australia’s built environment sector and business chambers.

She is currently a director of Standards Australia, a member of the ASIC Corporate Governance Consultative Panel and a councillor of the Australian Chamber of Commerce and Industry (ACCI) where she chairs the Data, Digital and Cyber Security Forum.

Megan’s expertise spans governance, risk management, public policy and education. She holds a Bachelor of Arts/Bachelor of Education, a Masters of Communication Management and a Graduate Diploma of Corporate Governance and Risk Management. She is a Fellow of the Governance Institute of Australia, the Chartered Governance Institute and the Australian Institute of Company Directors and is also a member of Chief Executive Women. Megan is also an Honorary Life Trustee of the Committee for Economic Development of Australia (CEDA) and was a 2014 recipient of the AFR/Westpac 100 Women of Influence.

Shamane Tan

Chief Growth Officer, Sekuro

Shamane Tan, Chief Growth Officer, Sekuro

Sekuro’s Chief Growth Officer, Shamane Tan, is passionate about uniting minds and experiences, excelling in aligning C-Suite and Board members with cyber security imperatives. As the author of “Cyber Risk Leaders,” she unravels executive communication nuances and distils C-Suite expectations. 

Her work extends to “Cyber Mayday and the Day After,” a roadmap for navigating crises by mining the wisdom of C-level executives from around the globe. It’s filled with interviews with managers and leaders who’ve braved the crucible and lived to tell the tale. Her most recent book, “Building a Cyber Resilience: A Cyber Handbook for Executives and Boards,” was featured on Forbes Australia’s top list of books for CEOs. 

Shamane has also founded a transcontinental cyber risk and executive meetup spanning Sydney, Melbourne, Adelaide, Perth, Singapore, the Philippines, and Tokyo, fostering mentorship, women’s empowerment and thought leadership. As a strong advocate for the importance of having a voice and helping others use theirs, Shamane Tan has spoken at TEDx and global conferences, including FS-ISAC, RSA, Silicon Valley, Fortune 500 and ASX companies. 

Recipient of the IFSEC Global Top 20 Cybersecurity Influencer award and named among the 40 under 40 Most Influential Asian-Australians, Shamane leverages her unique fusion of technical prowess and business acumen to help organisations progress on their security maturity journey.

David Gee

David Gee, CIO, CISO, NED, Board Advisor & Author

 

David Gee, CIO, CISO, NED, Board Advisor & Author

David has just retired in July 2024 and is building out his portfolio. He is an Advisor with Bain Advisory Network and also an Advisor to JS Careers (Cyber Recruitment) and Emertel (Software Commercialisation).

He is a seasoned technology executive with significant experience and has over 25 years’ experience in CIO and CISO roles across different industries and countries. At Macquarie Group David served as Global Head Technology, Cyber and Data Risk. Previously was CISO for HSBC Asia Pacific. His career as a CIO spans across multiple industries and geographies including – Metlife, Eli Lilly and Credit Union Australia. He was winner CIO of the Year 2014, at CUA where he successfully completed a significant Transformation of Core Banking, Online and Mobile Banking systems.

David is past Chairman for the FS-ISAC Strategy Committee and awarded Global Leaders Award in 2023 for his contributions to the cyber security industry. A regular conference keynote speaker and 150+ published articles for CIO Australia, Computerworld, iTnews and CSO (Cyber Security), David now writes for Foundry CIO.com and AICD.

His most recent book – the Aspiring CIO & CISO was published in June 2024 and David is writing his second – A Day in the Life of a CISO with a number of CISOs from around the world for 2025.

Naomi Simson

Co-founder, Big Red Group and Former Shark Tank Judge

Naomi Simson, Co-founder, Big Red Group

INTRODUCTION

For 25 years as an entrepreneur, Naomi Simson has been bringing people together whether it’s with her business experience, her speaking or writing. Passionate about small business and local community, Naomi is considered a home grown success story.

Naomi had a corporate career with Apple, KPMG, IBM and Ansett Australia prior to becoming an entrepreneur. She is a prolific blogger, podcaster and business commentator, and appeared as the #RedShark in four seasons of Shark Tank Australia and she appears regularly on ABC The Drum. She is a non-executive director at Big Red Group, Australian Payments Plus, Colonial First State and Weebit Nano, as well as the Cerebral Palsy Research Foundation and the University of Melbourne Business and Economics Faculty.

A true business leader and influencer, with more than 2.7 million LinkedIn followers, Naomi is Australia’s most followed person on the business networking platform. She has four seasons of her podcast ‘Handpicked’, and she has authored two best-selling books Live What You Love, and Ready to Soar, and is sought after speaker.

FULL BIO

For 25 years Naomi has been bringing people together whether it’s with her business experience, her speaking or writing. She is a strong advocate of business owners.

Known as an entrepreneur and business leader; following the growth of RedBalloon which she founded in 2001, Naomi co-founded the Big Red Group (BRG) in 2017.

Naomi had a corporate career with Apple, KPMG, IBM and Ansett Australia prior to becoming an entrepreneur. She is a prolific blogger, podcaster and business commentator, and appeared as the #RedShark in four seasons of Shark Tank Australia. She is a non-executive director at Big Red Group, Australian Payments Plus, Colonial First State and Weebit Nano. As well as the Cerebral Palsy Research Foundation and the University of Melbourne Business and Economics Faculty.

A true business leader and influencer, with more than 2.7 million LinkedIn followers, Naomi is Australia’s most followed person on the business networking platform. She has authored two best-selling books Live What You Love, and Ready to Soar, and is an engaging, humorous and insightful speaker. She has four seasons of her Podcast – Handpicked.

Naomi is relatable across a broad variety of audiences and topics, often drawing on her personal experiences to provide thoughtful and valuable views into topics; including the customer obsession, intentional leadership, growth mindset, personal development. She is a regular panellist on ABC The Drum.

Peter Ngo

Product Line Manager, Global Certifications, Palo Alto Networks

Peter Ngo | Sekuro

Peter leads the Commercial Cloud, Global Certifications organisation at Palo Alto Networks which oversees global cloud security compliance efforts to various frameworks and standards including IRAP, SOC 2, ISO, PCI, C5, ISMAP, and IRAP and more for 25+ cloud products.

He has held many roles over the years covering areas of IT Operations, and Governance, Risk, & Compliance (GRC) for a wide range of industries including technology, insurance, and manufacturing.

Peter holds various security and professional certifications, including the CCSP, CISSP, PCI ISA, CISA, CISM, CDPSE & ISO Lead Auditor, in addition to a Master of Science degree in Information Assurance. 

Jack Cross

CISO, QUT

Jack Cross | Sekuro

Jack Cross is an experienced business leader with expertise in digital technologies and risk management. Through a steadfast commitment to integrating people, processes, and technology, he champions the fight against cyber threats while mitigating organisational risks. 

Over the past 15 years, Jack has navigated diverse leadership roles within the Defence and Education sectors, honing his skills in steering multidisciplinary teams through intricate and sensitive technical landscapes. In addition to this experience, he holds numerous formal qualifications such as: a Master of Systems Engineering (Electronic Warfare); CISSP; and CISM certifications.

Nadene Serman

Global CTO, Infotrack

Nadene Serman | Sekuro

Nadene Serman is a leading IT executive with a proven track record spearheading first-of-its-kind technology and business transformation for some of the most prominent organisations globally and in Australia. As the Global Chief Technology Officer of InfoTrack, she is a key protagonist of innovation as an enabler of InfoTrack’s next stage growth. Her energy, commercial acuity and strategic capability have fueled her success.

Nadene leads with clarity, transparency and urgency, uniting people in complex, multi-layered technology and business execution, and go-to-market transformation and innovation. She tackles and resolves complex and seemingly intractable challenges while building support and collaboration – even in times of crisis. Her people-first, ‘think straight, talk straight’ approach makes her a formidable force.

John Doe

President Great Technology

Cyber Resilience Program | Sekuro

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