What evidence do auditors commonly ask for on CPS 234 para 15 Maintain an information security capability?

Information security capability assessment or maturity baseline, with target state; Security function organisation chart, headcount and skills inventory; Security budget and resourcing plan approved by management; Capability uplift roadmap with tracked delivery; Contracts for managed security services that form part of the capability.

What is the most common gap auditors find on CPS 234 para 15?

No baseline of current capability, so adequacy against threats cannot be shown

APRA CPS 234 · Information security capability (paras 15 to 17)

`CPS 234 para 15` Maintain an information security capability

The entity keeps an information security capability (the people, skills, resources and controls taken together) that is scaled to the size and reach of the threats facing its information assets and that supports continued sound running of the business.

Source: APRA CPS 234, CPS 234 para 15. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open APRA CPS 234 in the compliance library.

Applies to APRA-regulated entities.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Information security capability assessment or maturity baseline, with target state · Cloud console / configuration management

governing documentDocuments that govern the control

Security function organisation chart, headcount and skills inventory · Policy repository / GRC workspace
Security budget and resourcing plan approved by management · Policy repository / GRC workspace
Capability uplift roadmap with tracked delivery · Document repository
Contracts for managed security services that form part of the capability · Vendor register / contract repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

No baseline of current capability, so adequacy against threats cannot be shown
Capability sized to budget rather than to an assessment of threats
Reliance on one or two key people with no succession or backup

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CPS 234 para 14 Information security roles and responsibilities defined · CPS 234 para 16 Assess the security capability of related and third parties