APRA CPS 234: A Comprehensive Guide for Compliance

At Cybra Security (“Cybra”), we are dedicated to helping financial organisations safeguard their systems and networks against cyber threats. As experienced cyber security consultants, we recognise the significance of adhering to industry standards, particularly the Australian Prudential Regulation Authority’s (APRA) CPS 234 on Information Security. This guide aims to provide a comprehensive understanding of the essential requirements, with actionable advice for implementation.

1. Risk Management

APRA CPS 234 requires organisations to establish and maintain a comprehensive risk management process that is ongoing and tailored to their specific risk profile. This process involves regularly assessing the organisation’s information security risks, documenting the results, and implementing effective risk mitigation strategies.

For implementing a comprehensive risk management process, Cybra recommends:

  • Risk Assessments: Conduct regular risk assessments to identify and evaluate the organisation’s information security risks. This includes identifying the types of sensitive information that need to be protected, the systems and networks that store and transmit this information, and the potential threats and vulnerabilities that could compromise this information.
  • Risk Documentation: Document the results of risk assessments and update the organisation’s risk management plan accordingly. This includes creating a risk register that lists the identified risks and their associated impacts, likelihoods, and mitigation strategies.
  • Risk Mitigation: Develop and implement effective risk mitigation strategies to reduce the likelihood and impact of security incidents. This includes implementing security controls, such as firewalls, intrusion detection systems, and security monitoring, to protect sensitive information and prevent unauthorised access.
  • Ongoing Monitoring and Review: Continuously monitor and review the organisation’s risk management process to ensure it remains practical and relevant. This includes regularly reviewing the risk register and updating the risk management plan to reflect changes in the organisation’s risk profile.
  • Involvement of Key Stakeholders: Ensure that key stakeholders, including senior management, the information security team, and business units, are involved in the risk management process. This helps to ensure that risk management is integrated into the organisation’s overall security strategy and that the risk management plan is aligned with the organisation’s goals and objectives.

2. Information Security Policy

A clearly defined information security policy is essential to comply with APRA CPS 234. This policy sets the foundation for an organisation’s information security program and outlines the organisation’s objectives, responsibilities, and measures for protecting sensitive information.

Cybra’s advice for developing and implementing an effective information security policy:

  • Objectives: Clearly define the organisation’s information security objectives, including the types of sensitive information that need to be protected, the systems and networks that store and transmit this information, and the desired level of security for this information.
  • Roles and Responsibilities: Specify the roles and responsibilities of staff members and departments, including the information security team, business units, and senior management, to ensure that everyone understands their obligations to protect sensitive information.
  • Information Security Measures: Detail the measures in place to protect sensitive information, including technical, administrative, and physical controls. This should include details on network security, access control, data encryption, and incident response processes, among others.
  • Policy Review and Updating: Regularly review and update the information security policy to ensure it remains relevant and practical. This includes reviewing the policy in response to changes in the organisation’s risk profile, new security threats, and changes to laws and regulations.

3. Access Control

Access control is a crucial aspect of compliance with APRA CPS 234, as it helps to ensure that sensitive information is protected from unauthorised access. A robust access control system includes multiple layers of security to prevent unauthorised access, tampering, or disruption of operations.

For implementing adequate access controls, Cybra recommends:

  • User Authentication: Implement robust user authentication mechanisms, such as multi-factor authentication, to ensure that only authorised individuals have access to sensitive information.
  • Password Management: Require strong passwords and enforce policies that encourage users to create complex and unique passwords. Consider using password managers or other tools to manage and store passwords securely.
  • Permission-Based Access: Set specific permissions for data access based on a user’s role, responsibilities, and need-to-know. This helps to ensure that users only have access to the information they need to perform their job functions and that sensitive data is protected.
  • Monitoring and Review: Regularly monitor user access to sensitive information to detect unauthorised access. Consider implementing tools such as log analysis, security information, and event management (SIEM) to automate the monitoring process.

4. Data Encryption

Encryption is essential to compliance with APRA CPS 234, as it helps to protect sensitive information from unauthorised access, tampering, or theft. The requirement for encryption applies to all types of sensitive information, including data sent over the internet or stored on portable devices, backup tapes, and other storage media.

Cybra’s advice for implementing effective encryption:

  • Encrypting Data in Transit: When transmitting sensitive information over the internet or other networks, use encryption protocols such as SSL/TLS to encrypt the data in transit. This helps to prevent eavesdropping and other forms of tampering during transmission.
  • Encrypting Data at Rest: When storing sensitive information, use encryption technologies to encrypt the data at rest. This helps to prevent unauthorised access to the information if the storage media is lost or stolen.
  • Robust Encryption Algorithms: Use strong encryption algorithms like AES to encrypt sensitive information. This helps to ensure that even if the encrypted data is intercepted, it will be difficult to decrypt without the proper key.
  • Regular Encryption Protocol Updates: Regularly update encryption protocols to ensure they remain secure against evolving threats. This includes updating encryption algorithms, key lengths, and other security measures to maintain the security of encrypted information.
  • Key Management: Implement effective key management practices to ensure the security of encryption keys. This includes securely storing encryption keys, regularly rotating keys, and implementing strict access controls to prevent unauthorised access to encryption keys.

5. Incident Response

An effective incident response plan is a critical requirement of APRA CPS 234. In the event of a security breach or other information security incident, a well-defined incident response plan helps organisations respond quickly and minimise the impact of the incident.

For implementing an effective incident response plan, Cybra recommends:

  • Define Key Procedures: Define the procedures for detecting and reporting security breaches, conducting investigations, and communicating with relevant stakeholders. Ensure that all staff are familiar with these procedures and know what to do during a security breach.
  • Appoint a Responsible Team: Appoint a team of individuals responsible for responding to security incidents. This team should have the knowledge, skills, and resources necessary to quickly and effectively respond to incidents.
  • Regular Testing: Regularly test and update the incident response plan to ensure it remains adequate and relevant. This includes testing the procedures for detecting and reporting security breaches, conducting investigations, and communicating with relevant stakeholders.
  • Communication Plan: Develop a communication plan to ensure that relevant stakeholders are informed of security incidents promptly and effectively. This includes communication with employees, customers, partners, and regulatory authorities, as appropriate.
  • Post-Incident Review: Conduct a post-incident review after each security breach or other information security incident to assess the effectiveness of the incident response plan and identify areas for improvement.

6. System and Network Security

APRA CPS 234 requires organisations to implement strong security measures for their systems and networks to safeguard against unauthorised access, tampering, and disruptions. This includes protecting against malicious software, cyber-attacks and ensuring the confidentiality, integrity, and availability of sensitive information.
When it comes to implementing security measures for systems and networks, Cybra recommends:

  • Software and System Upgrades: Regularly update software and systems to ensure they are protected against known security vulnerabilities. This includes installing software patches and upgrades on time to address potential security risks.
  • Firewalls and Intrusion Detection Systems: Implement firewalls and intrusion detection/prevention systems to prevent unauthorised access to sensitive information and detect potential security breaches. These systems help to secure the organisation’s network perimeter and monitor incoming and outgoing traffic for any suspicious activity.
  • Security Assessments and Penetration Testing: Regularly conduct security assessments and penetration testing to identify and address security vulnerabilities. This includes performing regular vulnerability scans and penetration testing to identify any potential security weaknesses that need to be addressed.
  • Security Monitoring and Logging: Implement security monitoring and logging mechanisms to detect and respond to security incidents in real time. This includes monitoring network activity, server logs, and user activity to detect potential security incidents or breaches.
  • Network Segmentation: Segment the organisation’s network into different security zones to minimise the impact of any security incidents. This includes separating sensitive and critical systems from less sensitive and non-critical systems.

7. Employee Training

APRA CPS 234 requires organisations to provide ongoing training to staff on information security best practices and the importance of protecting sensitive information. This includes providing training on the organisation’s information security policy and procedures and regular reminders and updates on the latest security threats. Regular training and awareness programs help to ensure that staff understand the importance of information security and are equipped with the knowledge and skills to protect sensitive information effectively.

Cybra’s advice for implementing a practical employee training and awareness program:

  • Develop a Training Plan: Develop a training plan that outlines the training type, frequency, and who will be responsible for delivering the training. Ensure that all staff receive regular training on best practices and the organisation’s information security policy and procedures.
  • Customise Training: Customise training to meet the specific needs of different groups of employees. For example, employees who handle sensitive information should receive more in-depth training on information security best practices.
  • Use Engaging Methods: Use engaging methods to deliver training, such as interactive workshops, simulations, and gamification. This helps to ensure that employees are more engaged and better able to retain the information they have learned.
  • Regularly Update Training: Regularly update training materials to reflect the latest security threats and information security best practices. Ensure that employees receive regular reminders and updates on the latest security threats.
  • Evaluate Training Effectiveness: Regularly evaluate the effectiveness of training programs and make improvements where necessary. This includes gathering employee feedback and monitoring their performance to ensure they follow best practices.


In conclusion, following these guidelines and practical advice will help organisations to ensure their systems and networks are secure and compliant with APRA CPS 234. A comprehensive approach to information security is crucial for protecting sensitive information and maintaining the organisation’s resilience against cyber threats.


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