Critical Infrastructure Risk Management Program (CIRMP) Update

The Security of Critical Infrastructure Risk Management Program (CIRMP) rules came into effect, as of 17 February 2023, under the Security of Critical Infrastructure Act 2018 (SOCI Act). The new protocol sets baseline standards related to cybersecurity, physical security, personnel security and supply chain security.

Australian organisations deemed as critical infrastructure will now have to increase their investment in cybersecurity protection to comply with new national security requirements.
This is the latest measure by the Australian Government to reduce the exposure of the country to global cyber threats and uplift core security practices relating to the management of critical infrastructure assets.

WHICH ASSET CLASSES DO THE CIRMP OBLIGATIONS APPLY TO?

The CIRMP obligations apply to the following asset classes:

• a critical broadcasting asset;
• a critical domain name system;
• a critical data storage or processing asset;
• a critical electricity asset;
• a critical energy market operator asset;
• a critical gas asset;
• a designated hospital;
• a critical food and grocery asset;
• a critical freight infrastructure asset;
• a critical freight services asset;
• a critical liquid fuel asset;
• a critical financial market infrastructure asset;
• a critical water asset.

To determine whether your business falls within any of these classes, it’s vital to review the definitions in the SOCI Act.

WHAT ARE THE CIRMP OBLIGATIONS?

The CIRMP rules outline specific requirements that must be included within a CIRMP for a critical infrastructure entity. These requirements are broken down into four key hazard vectors, which include the following:

1. Cyber and Information Security Hazards - covering the improper access or misuse of information or systems to obtain unauthorised control of critical infrastructure systems.
2. Personnel Hazards - the insider risk posed by workers who have access to the functioning asset and the ability to disrupt its function or cause significant damage.
3. Supply Chain Hazards - the risk of disruption to critical supply chains, whether naturally occurring, malicious or purposefully intended to compromise the asset.
4. Physical Hazards - the risk of physical security hazards to parts of the asset, including unauthorised access to sensitive facilities or natural disasters.

WHAT SHOULD YOUR BUSINESS BE DOING?

As of 17 February 2023, responsible entities have a six-month grace period within which they will need to put in place a critical infrastructure risk management program, after which it will need to be maintained, reviewed and updated accordingly. The CIRMP must be approved by the entity’s board or governing body and an annual report should be submitted to the Secretary of the Department of Home Affairs, the first of which will be due at the end of the 2023-24 financial year.

The first steps for those deemed critical infrastructure entities should be the following:

• Review any existing risk management plans.
• Create a CIRMP that complies with the CIRMP Rules.
• Ensure the CRIMP complies with ISO 27001, NIST or an equivalent standard.
• Consider third-party arrangements.
• Educate the board about CIRMP.
• This includes informing your board they will need to approve an annual report on CIRMP with the first report required by 28 September 2024

HOW TO STRENGTHEN YOUR RISK MANAGEMENT PROGRAM

At Infotrust, we offer consulting services to uplift your security program and increase your capacity to meet any future mandatory legislative standards. Our cyber security experts learn about your specific challenges and provide tailored services to assist you in improving your security posture.

If you’d like to bolster your risk management program or find out what the new rules coming into force mean for your business, contact the cyber security experts at Infotrust today to book a consultation.

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