Standards Comparison

    ISO 27018

    Voluntary
    2019

    Code of practice for PII protection in public clouds

    VS

    APRA CPS 234

    Mandatory
    2019

    Australian prudential standard for information security resilience

    Quick Verdict

    ISO 27018 provides voluntary cloud PII controls for global CSPs, extending ISO 27001. APRA CPS 234 mandates information security governance for Australian financial firms with strict testing and notifications. CSPs adopt 27018 for trust; banks use CPS 234 for compliance.

    Cloud Privacy

    ISO 27018

    ISO/IEC 27018:2025 PII protection code for public clouds

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • Tailored PII protection controls for public cloud processors
    • Mandatory subprocessor transparency and customer notifications
    • Prompt breach notification obligations to controllers
    • Prohibits PII secondary use like marketing without consent
    • Integrates seamlessly with ISO 27001 ISMS audits
    Information Security

    APRA CPS 234

    APRA Prudential Standard CPS 234 Information Security

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Board ultimate responsibility for information security
    • 72-hour notification for material incidents to APRA
    • Covers third-party managed information assets
    • Systematic independent testing of controls required
    • Asset classification by criticality and sensitivity

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    ISO 27018 Details

    What It Is

    ISO/IEC 27018:2025 is an international code of practice extending ISO 27001 and ISO 27002 specifically for protecting personally identifiable information (PII) in public clouds where providers act as PII processors. Its primary scope targets cloud service providers (CSPs) handling customer PII, addressing multi-tenancy, cross-border flows, and subprocessors. It uses a risk-based approach, layering ~25-30 privacy-specific controls onto the ISMS framework.

    Key Components

    • Core control areas: transparency, contractual obligations, data subject rights support, breach management, secure PII lifecycle handling.
    • Aligned with privacy principles like consent, purpose limitation, data minimization, accountability.
    • Maps to ISO 27001 Annex A (93 controls across Organizational, People, Physical, Technological themes).
    • No standalone certification; assessed within ISO 27001 audits via Statement of Applicability.

    Why Organizations Use It

    CSPs adopt it for procurement acceleration, customer trust, GDPR Article 28 alignment, cyber insurance benefits, and market differentiation. It mitigates privacy risks in cloud environments and demonstrates processor diligence.

    Implementation Overview

    Start with gap analysis on existing ISMS, update policies/contracts, implement technical safeguards. Applicable to CSPs of all sizes globally. Requires third-party audits integrated into ISO 27001 cycles (annual surveillance, 3-year recertification).

    APRA CPS 234 Details

    What It Is

    APRA Prudential Standard CPS 234 (Information Security) is a binding regulation issued by the Australian Prudential Regulation Authority, effective 1 July 2019. It mandates information security capabilities for APRA-regulated financial entities to ensure resilience against cyber threats. The risk-based approach requires commensurate governance, controls, testing, and reporting across information assets, including those managed by third parties.

    Key Components

    • **11 core requirementsBoard accountability, role definitions, capability maintenance, policy framework, asset classification, lifecycle controls, incident response, systematic testing, internal audit, and APRA notifications.
    • Built on CIA triad (confidentiality, integrity, availability).
    • No fixed controls; focuses on assurance-driven compliance via independent testing and audits.

    Why Organizations Use It

    • Mandatory for ADIs, insurers, super funds to avoid penalties, enforcement.
    • Enhances cyber resilience, stakeholder protection, operational continuity.
    • Builds trust, reduces incident impacts, integrates with CPS 220/230.

    Implementation Overview

    • Phased: gap analysis, governance, asset inventory, controls, testing, monitoring.
    • Applies to all sizes in Australian financial sector; third-party transition by 1 July 2020.
    • Requires internal audit and annual testing; no formal certification but APRA supervision.

    Key Differences

    Scope

    ISO 27018
    PII protection in public clouds for processors
    APRA CPS 234
    Information security across financial entities

    Industry

    ISO 27018
    All sectors, global CSPs
    APRA CPS 234
    Australian financial services only

    Nature

    ISO 27018
    Voluntary code of practice, ISO 27001 extension
    APRA CPS 234
    Mandatory prudential standard, enforceable

    Testing

    ISO 27018
    Assessed in ISO 27001 audits
    APRA CPS 234
    Systematic, independent, risk-based testing

    Penalties

    ISO 27018
    Loss of audit alignment, no legal penalties
    APRA CPS 234
    Regulatory sanctions, fines, enforcement actions

    Frequently Asked Questions

    Common questions about ISO 27018 and APRA CPS 234

    ISO 27018 FAQ

    APRA CPS 234 FAQ

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