Cyber Security Policy and Procedures Template (AFSL & ACL)

For AFSL holders and Australian credit licensees

$190.00 +GST

Free Download for COMPASS Members

Use this policy to:
  • Document a board-approved framework for identifying and managing cyber risk;
  • Assign roles and responsibilities for incident detection, response and reporting;
  • Set technical controls aligned to the ASD Essential Eight maturity model;
  • Support regulatory obligations under the Corporations Act and Privacy Act.

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Cyber Security Policy table: Source, Obligation, and Relevance to Policy columns

About this Document

Use this policy if you:
  • Hold an Australian Financial Services Licence (AFSL) or Australian Credit Licence (ACL) and need a board-approved cyber security policy and procedures
  • Rely on an outsourced IT service provider or managed security service provider rather than an in-house security team
  • Want to support your obligations under s 912A of the Corporations Act 2001 (Cth), s 47 of the National Consumer Credit Protection Act 2009 (Cth), the Privacy Act 1988 (Cth) and the Cyber Security Act 2024 (Cth)
  • Need clear roles, responsibilities and reporting lines for identifying, managing and responding to cyber risk
  • Want to address the control gaps highlighted in ASIC v FIIG Securities Limited, including multi-factor authentication, privileged access, vulnerability scanning and incident response testing
It is suited to:
  • AFSL holders, including advisers, dealers, fund managers, responsible entities, custodians and platform operators
  • ACL holders, including credit providers, brokers and lessors
  • Small to medium licensees (typically up to 100 staff) that rely on an outsourced IT service provider
  • Not designed for APRA-regulated entities (subject to CPS 234 and CPS 230), responsible entities of critical infrastructure assets under the Security of Critical Infrastructure Act 2018 (Cth), market operators, clearing and settlement facilities or large listed entities
What this policy covers:
  • Governance, roles and responsibilities for the Board, Responsible Officer, Compliance, Privacy Officer and IT Service Provider
  • Cyber risk assessment and information classification (Restricted, Confidential, Internal and Public)
  • Identity and access management, including least privilege, multi-factor authentication and privileged account controls
  • Password and passphrase standards, network and endpoint security, and vulnerability and patch management timeframes
  • The ASD Essential Eight as the baseline technical control set, with maturity targets for each strategy
  • Email and communications security, data protection, backup and recovery, and third party and cloud service provider controls
  • Staff training and awareness, phishing simulation, and cyber incident management including the Cyber Incident Response Plan
  • Ransomware and cyber extortion, including Cyber Security Act 2024 (Cth) payment reporting, plus monitoring, testing, assurance, cyber insurance and record keeping
You receive an editable Word document with placeholders for your entity name, ACN, licence numbers, role holders and control settings (timeframes, frequencies and maturity targets), plus appendices for staff cyber security rules, incident escalation contacts, external notification obligations and required registers and records. It is a practical, lawyer-drafted starting point for a board-approved cyber security framework, not a substitute for tailored legal or technical advice in complex or high-risk situations.

How To Use This Template

This template is a starting point, not a final document. It’s been drafted by Australian lawyers to be practical and flexible, but it still needs to be reviewed and tailored for your specific business, transaction and risk profile.

Before you use it, you should:

  • Complete all placeholders, bracketed items and optional fields;
  • Remove any drafting notes or clauses that aren’t relevant to your situation; and
  • Check that party names, entity details, dates, addresses, contact details and defined terms are accurate.

Make sure the template is consistent with your other documents and obligations – including any existing contracts, policies, procedures, website terms, privacy disclosures, regulatory requirements or internal governance documents. If anything conflicts, it should be resolved before you sign, issue, adopt or implement the document.

If you are using the template as an agreement, it should be reviewed and signed by all relevant parties in accordance with applicable law and your internal signing requirements. If you are using it as a policy, procedure, notice or compliance record, it should be approved and stored under your organisation’s normal document control processes.

This template is provided as general information only and is not legal advice. Complex, high‑value, highly regulated or cross‑border matters will usually require bespoke drafting. For anything outside a straightforward use case, we strongly recommend obtaining legal advice before relying on, signing or implementing this document.

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