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APRA, or the Australian Prudential Regulation Authority, is an independent government agency responsible for overseeing banks, insurance companies, and superannuation institutions. Their primary role is to establish and enforce security standards to ensure these financial entities fulfil their promises to customers.
When APRA grants licenses to operate, these businesses must adhere to strict regulations, including standards like APRA Prudential Standard CPS 234, which APRA actively monitors and enforces.
In today's digital age, safeguarding data and assets is crucial both socially and financially. To counter the ever-present threat of cybercrime, APRA-regulated entities are required to meet minimum standards:
Under CPS 234, the Board is responsible for protecting company digital assets and information. They must ensure that information security is maintained in line with the size of the assets and threat profile, by maintaining resilience and the capability to maintain operations.
Your MSP can assist in clearly defining and communicating the roles and responsibilities within your organisation – including Board members, senior management, governing bodies, and individuals who play a role in information security.
Your MSP can support you to maintain a policy framework that demonstrates how you will establish and maintain systems that increase your business’s resilience to information security threats and incidents. You must also prove your business capability to respond swiftly and effectively to any breach from any source.
These frameworks must be scalable, appropriate to your threat exposure and data sensitivity – and your policy must clearly outline responsibilities for the maintenance of information security.
As an APRA-regulated entity, get MSP support to create and maintain information security response plans to respond swiftly and vigorously to incidents. You must have processes in place to:
Get support to put controls in place that are commensurate with:
Every APRA-regulated entity must use a systematic regime to test the effectiveness of its information security controls. Your MSP stays across the types and frequency of testing, that must be changeable and scalable to:
Look for a MSP who can deliver testing “conducted by independent specialists with commensurate skills and experience” at least once a year or when there is a ‘material change’ to the business environment or information assets.
CPS 234 requires organisations to implement a number of measures to protect their data from unauthorised access, use, disclosure, modification, or destruction. These measures can help to reduce the risk of data breaches and other security incidents.
CPS 234 mandates regular risk assessments and the implementation of appropriate controls to manage identified risks. By complying with these requirements, organisations can proactively identify and address potential vulnerabilities, reducing the likelihood and impact of security incidents.
Customers and stakeholders are increasingly concerned about the security of their data. By implementing CPS 234, organisations can demonstrate to their customers and stakeholders that they are taking information security seriously. This can help to build trust and confidence, which can lead to increased business opportunities.
CPS 234 is a mandatory requirement for APRA-regulated entities. By implementing CPS 234, organisations can help to ensure that they are in compliance with APRA's requirements, thereby avoiding regulatory penalties, reputational damage and legal consequences associated with non compliance.
CPS 234 promotes the implementation of strategies and controls to ensure the resilience of critical information assets. This helps organisations identify vulnerabilities, prevent disruptions, and maintain continuity of operations even in the face of cyber threats or system failures.
CPS 234 mandates the establishment of an effective incident response framework. By complying with this requirement, organisations can detect and respond to security incidents promptly, minimising the impact of potential breaches and mitigating risks effectively.
Organisations that comply with CPS 234 differentiate themselves from their competitors by demonstrating their commitment to information security. This can be a valuable asset when attracting customers, partners, and investors who prioritise data protection and privacy.
Implementing CPS 234 often requires significant organisational changes and a cultural shift towards prioritising information security. This may involve redefining roles and responsibilities, establishing new processes and procedures, and fostering a security-aware culture throughout the organisation. Resistance to change and the need for employee training and awareness programs can pose challenges during implementation.
CPS 234 covers a wide range of information security aspects, including risk assessment, incident response, access controls, and data encryption. Implementing these requirements across various systems, networks, and processes within an organisation can be complex and challenging, particularly for larger institutions with diverse operations and legacy systems.
Many organisations already have information security frameworks in place, such as ISO 27001 or the National Institute of Standards and Technology (NIST) Cybersecurity Framework. These frameworks may overlap with CPS 234, and organisations need to make an informed decision about what frameworks that are committing to.
Many organisations rely on third-party vendors to provide critical services. These vendors may have their own security vulnerabilities, which could pose a risk to the organisation. Adopting CPS 234 requires organisations need to have a process in place for reviewing and auditing 3rd party vendors in order to manage these risks.
Security and usability are often seen as competing priorities. Organisations need to find a way to balance these two priorities, so that their security measures do not make it too difficult for users to access the information they need.
Compliance with CPS 234 can involve significant costs, including investments in technology, infrastructure, personnel, and ongoing maintenance. Smaller financial institutions or those with limited budgets may face challenges in allocating the necessary funds for compliance without compromising other operational priorities.
Implementing CPS 234 often requires close collaboration and coordination between various departments within an organisation, such as IT, risk management, legal, and compliance. Ensuring effective communication and collaboration among these departments can be challenging, particularly in larger organisations with complex organisational structures.
The threat landscape is constantly evolving, and organisations need to be able to adapt their security measures accordingly. This can be a challenge, as it requires organisations to have a good understanding of the latest threats and how to mitigate them.
These are just some of the challenges that organisations face when implementing CPS 234. By understanding these challenges and finding the right MSP, organisations can better prepare themselves for the implementation process.
We specialise in highly regulated industries where data protection is critical for a competitive edge. We’ve helped hundreds of organisations transition to secure, compliant IT environments, conforming with APRA, PCI DSS and ISO 27001 requirements and obligations.
Canon Business Services understands the changing nature of business continuity and the demands of balancing the latest technology with robust security standards. Our industry-leading platforms are ISO 27001 and PCI DSS certified, and APRA-aligned to provide you total peace of mind when reporting back to boards and regulators. Feel total confidence reporting back to boards and regulators.
Does your business need to step up or get a secure edge in the competitive financial services market?
Get proactive about CPS 234 compliance with Canon Business Services and contact us to discuss our Solutions for Financial Services.
According to CPS 234, financial organisations must conduct systematic testing of their information security controls at least once a year or when there is a 'material change' to the business environment or information assets. This regular testing helps ensure the ongoing effectiveness of security measures.
Implementing CPS 234 offers several potential benefits to financial institutions and their customers. It enhances data security, improves risk management, fosters trust among customers and stakeholders, ensures regulatory compliance, strengthens business resilience, and enhances incident response capabilities.
CPS 234 aids financial organisations in detecting and responding to security breaches effectively by requiring them to have processes in place for timely incident response. This ensures that security incidents are addressed promptly and that their impact on information assets and stakeholders is minimised.
CPS 234 recommends controls to protect information assets, including access controls, data encryption, risk assessments, and incident response plans. For instance, implementing robust access controls ensures that only authorised individuals can access sensitive data, enhancing overall security.
