What evidence do auditors commonly ask for on CPS 234 para 19 Policy direction to everyone with a security obligation?

Policy statements setting out responsibilities for staff, contractors, consultants and third parties; Acceptable use policy with signed acknowledgements; Contract clauses or schedules imposing security obligations on third and related parties; Customer-facing security guidance or terms where customers carry security duties; Security awareness training records linked to policy content.

What is the most common gap auditors find on CPS 234 para 19?

Policies address employees only and are silent on contractors and third parties

APRA CPS 234 · Policy framework (paras 18 to 19)

`CPS 234 para 19` Policy direction to everyone with a security obligation

The policy framework tells every party with an obligation to keep information secure what their responsibilities are. A footnote lists those parties: the governing bodies and individuals named under paragraph 14, plus every other staff member, contractor and consultant, related and third parties, and customers.

Source: APRA CPS 234, CPS 234 para 19. 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

Vendor register / contract repository

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

Security awareness training records linked to policy content · HR system / LMS

governing documentDocuments that govern the control

Policy statements setting out responsibilities for staff, contractors, consultants and third parties · Vendor register / contract repository
Acceptable use policy with signed acknowledgements · HR system / LMS
Contract clauses or schedules imposing security obligations on third and related parties · Vendor register / contract repository
Customer-facing security guidance or terms where customers carry security duties · Policy repository / GRC workspace

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

Policies address employees only and are silent on contractors and third parties
No acknowledgement that staff have read the policies
Third-party contracts lack any reference to the entity's security requirements

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 18 Maintain an information security policy framework · CPS 234 para 20 Classify information assets by criticality and sensitivity