Privacy and Protection: Integrating APRA, ASIC, ACSC, and OAIC Cybersecurity Expectations into Organisational Governance
Cybersecurity is no longer just an IT issue - it is a core governance and strategic risk for Australian businesses. As a result, 30% of surveyed Australian businesses intend to increase their investment against cybercrime in 2025 according toNAB Business Pulse (March 2025).
The recent high-profile breaches at Optus, Medibank, and Latitude Financial illustrate how cyber risks can disrupt operations, erode customer trust, invite financial penalties, and trigger intense regulatory scrutiny.
To address these challenges, Australian authorities - including APRA, ASIC, ACSC, and OAIC - have outlined clear cybersecurity standards and expectations. These frameworks are critical for boards and executives to integrate into their existing governance structures and risk management frameworks. Successfully doing so not only ensures compliance but also creates a foundation of trust, stability, and long-term resilience.
While APRA, ASIC and OAIC enforce regulations, the ACSC and OAIC acts as a trusted advisory body providing expert guidance on managing cybersecurity threats and privacy risks. Together, they form a comprehensive framework for navigating cyber risks.
These are now further supported by the new Cybersecurity Act 2024, which introduces mandatory ransomware reporting and minimum cybersecurity standards for smart devices, reflecting a shift to stronger legal obligations beyond guidance alone.
Key Cybersecurity and Privacy Expectations for Australian Organisations
When it comes to managing cybersecurity risks, Australian organisations must align with critical expectations from four key authorities: APRA, ASIC, OAIC, and the Department of Home Affairs. Together with the ACSC, these regulatory and advisory bodies provide the framework for businesses to protect sensitive data, build resilience, and confidently navigate the evolving cyber threat landscape.
Australian Prudential Regulation Authority (APRA)
APRA sets mandatory prudential standards for financial institutions and insurers, underscoring the importance of cybersecurity as a governance priority:
CPS 234 (Information Security): Organisations are required to establish and maintain robust information security capabilities, clearly define accountability across leadership, regularly test security controls, and notify APRA of material cybersecurity incidents.
CPS 230 (Operational Risk Management): Businesses must manage operational risks (including cyber risks), define risk tolerance levels, conduct regular scenario planning, and strengthen governance oversight to ensure operational resilience.
Australian Securities and Investments Commission (ASIC)
ASIC’s cyber resilience expectations offer practical guidance for regulated entities to protect their operations and maintain market trust (outlined in ASIC Report 429):
Adopt recognised cybersecurity frameworks such as the ACSC Essential Eight, ISO 27001, or NIST Cybersecurity Framework.
Conduct regular cyber risk assessments, manage third-party risks, implement ongoing employee awareness programmes, and ensure timely reporting and transparency during incidents.
Australian Cyber Security Centre (ACSC)
As Australia's lead cybersecurity authority, the ACSC, sitting within the Australian Signals Directorate, provides essential tools and insights for businesses to combat evolving cyber threats. The Essential Eight framework includes practical controls every organisation should adopt:
Application whitelisting
Timely patching of applications and operating systems
Secure macro configurations
Application hardening to reduce vulnerabilities
Restriction of administrative privileges
Multi-factor authentication (MFA)
Regular backups with rigorous data recovery testing
These strategies form the baseline for building cyber resilience and mitigating high-priority risks.
Office of the Australian Information Commissioner (OAIC)
The OAIC ensures businesses adhere to privacy standards directly tied to cybersecurity, as outlined in the Australian Privacy Act 1988. Key requirements include:
Australian Privacy Principle (APP) 11: Organisations must take reasonable steps to protect personal data from misuse, interference, loss, or unauthorised access.
Administration of the Notifiable Data Breaches (NDB) scheme, which demands businesses notify individuals and the OAIC of breaches likely to cause harm.
A collaborative approach with ACSC offering practical guidance on privacy-by-design principles, incident response, and data breach management.
Department of Home Affairs
The Department of Home Affairs plays a central role in Australia’s national cybersecurity landscape, focusing on strategy, legislation, and coordination. It leads the government’s cybersecurity agenda through initiatives such as the 2023–2030 Australian Cyber Security Strategy.
It also oversees the Cyber Security Act 2024, including key measures like ransomware reporting, smart‑device standards, and the Cyber Incident Review Board, and the Security of Critical Infrastructure Act 2018 (SOCI Act), which mandates cyber incident reporting for critical infrastructure entities.
By understanding and integrating these regulatory expectations, boards and executives can turn mandatory compliance into a powerful framework for resilience, improved trust, and strategic advantage.
Comparison of Australian Government Bodies' Cybersecurity Role
Practical Cybersecurity Steps for Australian Senior Leaders
Integrating cybersecurity expectations into governance and risk management has become a strategic imperative. For board members and senior executives, leadership in this domain requires more than delegation. It demands structured accountability, proactive planning, and a culture of vigilance to protect organisational resilience.
Here are six practical steps that Australian leaders can adopt to navigate cybersecurity risks with confidence:
Step 1: Explicit Board and Leadership Accountability and Governance
Cybersecurity starts at the top. Strengthen governance processes by:
Assigning clear accountability to senior executives for overseeing cybersecurity risks and initiatives.
Embedding cybersecurity oversight into governance structures to ensure clear ownership and proactive action.
Establishing regular, structured reporting to the board that provides visibility into cybersecurity risks, incidents, and mitigation efforts.
Step 2: A Clearly Defined Cyber Risk Appetite
A well-defined cyber risk appetite acts as a strategic guide. Ensure that risks are managed effectively by implementing these processes:
Documenting your organisation’s cyber risk appetite explicitly, making it clear what levels of risk are acceptable and unacceptable.
Aligning the cyber risk appetite with your organisation’s strategic goals to ensure consistency in decision-making.
Communicating this risk appetite across leadership and integrating it into both governance and operational decision-making processes.
Step 3: Regular Risk Assessments and Scenario Testing
Proactive assessment is key to staying ahead of cyber threats. This includes:
Conducting structured tests, such as penetration testing and vulnerability scanning, to identify and address weaknesses in your digital infrastructure.
Performing regular scenario-based incident response exercises to ensure recovery plans are practical and well-rehearsed.
Include ransomware or cyber extortion incident simulations that incorporate mandatory reporting obligations under the Cybersecurity Act.
Step 4: Proactive Management of Third-Party Cybersecurity Risks
Your cybersecurity defences are only as strong as your weakest vendor. Strengthen third-party partnerships by:
Embedding clear and enforceable cybersecurity requirements into all third-party contracts.
Regularly assessing vendor compliance with these contractual obligations to ensure alignment with your risk appetite and governance framework.
Step 5: Privacy Protection and Notifiable Data Breach Readiness (OAIC Obligations)
Data is one of your organisation’s most critical assets - protect it meticulously. To meet OAIC expectations:
Create robust procedures to identify, assess, and report eligible data breaches promptly as required by the NDB scheme.
Explicitly integrate privacy protection and cybersecurity into your broader risk management framework to avoid blind spots.
Step 6: A Cybersecurity-Aware and Incident-Ready Culture
Even the best technical defences are incomplete without a people-first approach to cybersecurity. Build a culture of awareness and readiness by:
Delivering regular, tailored cybersecurity training across every level of the organisation, from frontline staff to board members.
Establishing transparent, user-friendly processes for reporting incidents, creating a safe space for employees to escalate potential cyber risks without fear of blame.
Embedding your cybersecurity-aware and incident-ready culture within your organisation’s overall risk culture.
Real-Life Scenarios: Lessons in Cybersecurity Governance and Privacy Management
Scenario A: Proactive Cybersecurity Integration
An Australian financial services organisation that has successfully integrated APRA CPS 234 and CPS 230, ASIC Report 429, ACSC Essential Eight controls, and OAIC privacy guidance into its governance framework. By implementing privacy-by-design, regular scenario testing, vendor management controls, and strong incident response measures, they effectively handle attempted cyber incidents, protect personal data, ensure operational continuity, and preserve customer trust. They are also aligned with the new Cyber Security Act requirements.
Scenario B: The Cost of a Reactive Approach
A different organisation neglects to embed regulatory expectations and cybersecurity practices into its governance and risk management strategy. Following a ransomware attack, sensitive data is compromised, triggering mandatory breach notifications under the OAIC's NDB scheme. The aftermath includes regulatory investigations, steep remediation costs, and a damaging loss of customer trust - underscoring the critical need for proactive cybersecurity governance.
Effective Cybersecurity Governance Aligned with APRA, ASIC, ACSC, and OAIC Expectations
Aligning with APRA, ASIC, ACSC, and OAIC expectations offers more than compliance; it builds a foundation for trust, operational resilience, and strategic leadership in an era of rising cyber threats.
If your organisation is ready to strengthen its cybersecurity and privacy frameworks, I bring deep expertise in guiding organisations through integrating regulatory requirements and guidelines into risk and governance frameworks.
Contact me for a confidential discussion to explore tailored strategies that integrate governance, compliance, and resilience for your organisation’s future.
