Data management strategy, data quality, data controls, and data breach obligations. CPS 232 ensures APRA-regulated entities manage data as a critical asset. CyberHeed maps every obligation and tracks compliance continuously.
Prudential Standard CPS 232 Business Continuity Management establishes requirements for APRA-regulated entities to manage data risk. While CPS 230 has consolidated and replaced parts of the original CPS 232 (Business Continuity Management), the data risk management obligations remain critical. APRA expects entities to treat data as a strategic asset requiring governance, quality controls, and breach management at board level.
CPS 232 applies to all APRA-regulated entities:
Authorised deposit-taking institutions must ensure data governance frameworks cover all customer data, transaction data, and regulatory reporting data. Data quality directly affects prudential reporting accuracy and regulatory trust.
Insurers hold vast quantities of policyholder data, claims data, and actuarial data. Data quality failures in insurance can lead to mispriced risk, regulatory sanctions, and customer harm. CPS 232 requires structured data management across the insurance lifecycle.
RSE licensees manage member data spanning decades. Contribution records, investment allocations, beneficiary details, and retirement projections all depend on data integrity. CPS 232 ensures this data is governed, quality-controlled, and protected.
Health insurers manage sensitive health data alongside financial data. Data governance must address both privacy obligations and prudential requirements, with particular attention to data breaches involving health information.
APRA has increasingly focused on data risk as a prudential concern. Key drivers:
Poor data quality leads to inaccurate prudential reporting. APRA relies on entity data for systemic risk monitoring. Data errors are not just operational issues - they undermine regulatory oversight of the entire financial system.
Entities must have robust processes for detecting, managing, and reporting data breaches. This intersects with the Notifiable Data Breaches scheme and CPS 234's incident notification requirements. CPS 232 ensures data breaches are managed as a prudential risk, not just a privacy issue.
Data shared with or processed by third parties must be governed under the same standards. As entities increasingly rely on cloud providers and outsourced processing, CPS 232 ensures data risk management extends beyond the entity's own infrastructure.
The board is accountable for data risk management. CPS 232 requires board-approved data management strategies, regular reporting on data quality, and oversight of data-related incidents. Data governance is a board-level responsibility.
CPS 232 structures data risk management obligations into four key areas. Each requires documented policies, implemented controls, and ongoing monitoring.
Establish a board-approved data management strategy that defines how the entity will govern, manage, and protect data as a strategic asset. The strategy must cover data lifecycle, data ownership, data architecture, and alignment with business objectives.
- Board-approved data management strategy and governance framework
- Clear data ownership and stewardship roles across business lines
- Data architecture that supports regulatory reporting and risk management
- Data lifecycle management from creation to destruction
- Regular review and update of data strategy aligned to business changes
Ensure data used for decision-making, regulatory reporting, and risk management is accurate, complete, timely, and consistent. Data quality is not aspirational - it must be measured, monitored, and remediated continuously.
- Data quality dimensions: accuracy, completeness, timeliness, consistency
- Data quality measurement and reporting frameworks
- Automated data validation and reconciliation processes
- Root cause analysis for data quality failures
- Remediation tracking for identified data quality issues
Implement controls that protect data confidentiality, integrity, and availability throughout its lifecycle. Data controls must address access management, data classification, encryption, and secure data handling across all environments.
- Data classification framework aligned to sensitivity and regulatory requirements
- Access controls ensuring least-privilege access to data
- Encryption for data at rest and in transit
- Data loss prevention controls across endpoints and networks
- Secure data disposal and destruction procedures
- Controls over data in third-party and cloud environments
Detect, manage, and report data breaches promptly and effectively. Data breach management must be integrated with CPS 234 incident management and the Notifiable Data Breaches scheme. APRA expects entities to notify material data breaches within 72 hours.
- Data breach detection and monitoring capabilities
- Incident classification and severity assessment for data breaches
- Notification processes for APRA, OAIC, and affected individuals
- Root cause analysis and remediation for data breaches
- Board reporting on data breach trends and response effectiveness
CyberHeed maps every CPS 232 obligation, captures your current data governance posture, identifies gaps, and provides the framework for ongoing compliance.
SmartPrep guides your team through structured conversations covering data management strategy, data quality practices, data controls, and breach management. AI captures your current state against each CPS 232 obligation and identifies gaps in your data governance framework.
Upload evidence for each obligation. AI validates whether your data management strategy, quality frameworks, controls, and breach procedures meet APRA's expectations. Cross-reference with CPS 230 and CPS 234 evidence automatically.
Track data quality metrics, monitor control effectiveness, manage breach reporting obligations, and generate board reports on data risk posture. CyberHeed ensures your data governance remains current between APRA reviews.
CPS 232's data risk management obligations complement CPS 230 (operational resilience), CPS 234 (information security), and ISO 27001. CyberHeed maps across all four frameworks - evidence gathered for one directly supports the others.
Information security controls under CPS 234 - access management, encryption, incident response - directly support CPS 232's data controls and data breach management requirements.
Operational resilience under CPS 230 covers business continuity and service provider management. Data continuity and third-party data risk under CPS 232 align closely.
ISO 27001's data classification, access control, and information handling controls map strongly to CPS 232's data controls and data governance requirements.
Other frameworks: [Links to: cps-230.html], [Links to: cps-234.html], [Links to: iso-27001.html], [Links to: essential-eight.html], [Links to: nist-csf.html]
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