NDIS: Protective Security Policy Framework (PSPF) & Cybersecurity - obligated or not?

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Dear National Disability Insurance Agency,

You seem to be on a hiring blitz for cybersecurity folk. As of 13 Nov 22, you have no less than 6 cyber security positions you are trying to fill, all seemingly new roles.

1. Director Cyber Security Risk & Compliance (Canberra) https://www.seek.com.au/job/59173631
2. Director Cyber Security Risk & Compliance (Geelong) https://www.seek.com.au/job/59173632
3. Assistant Director Cyber Security Operations Centre (Capability Development) (Sydney) https://www.seek.com.au/job/59086662
4. Assistant Director Cyber Security Operations Centre (Capability Development) (Geelong) https://www.seek.com.au/job/59086570
5. Assistant Director Cyber Security Operations Centre (Capability Development) (Canberra) https://www.seek.com.au/job/59086597
6. Assistant Director Cyber Security Operations Centre (Capability Development) (Canberra) https://www.seek.com.au/job/59086645

All Assistant Director Roles state: "A new role awaits - The Protective and Cyber Security Branch implements the requirements of the Protective Security Policy Framework (PSPF) and Information Security Manual (ISM) within the Agency. This is achieved by providing strategic, Agency-wide oversight of Security across security governance, information security, personnel security, physical security, and cyber security and operations."

Whereas the Director Roles state: "Ensuring that the Agency meets all legislated and regulatory responsibilities for Agency information technology security, including remaining up to date with amendments to the Information Security Manual (ISM) and the Protective Security Policy Framework (PSPF)."

This seems odd or mistaken. As the NDIA/NDIS has repeatedly stated that the PSPF has nothing to do with the NDIS and the NDIA have no obligations what so ever to follow or adhere to the Commonwealth Government's Protective Security Policy Framework.

"As a corporate Commonwealth entity, the Agency is required to adhere to the PSPF.", page 5, NDIS/NDIA Agency Security Plan, Sep 2020 seems somewhat at odds with the NDIS' declaration that "The NDIA is a Corporate Commonwealth Entity (CCE) which means that the Agency is NOT required to adhere to the PSPF", page 3, FOI 21/22-1320 - Notification of Decision, 2 May 22
https://www.righttoknow.org.au/request/n...

Repeatedly refuted and denied by the NDIS:

1. Data/information security - Salesforce (FOI 20/21-0873) 30 Jul 21
https://www.righttoknow.org.au/request/d...

2. NDIA Project Risk Management Policy and Procedure (FOI 20/21-0872) 11 Jun 21
https://www.righttoknow.org.au/request/n...

3. NDIS APIs, Security, Risk and Assurance (FOI 22/23-0600) 25 Oct 22
https://www.righttoknow.org.au/request/n...

4. NDIS Register of Security Designated Positions (FOI 21/22-0864) 11 Mar 22
https://www.righttoknow.org.au/request/n...

5. NDIS: Security Plan, Security Quality Assurance Policy & Personnel Security - PSPF (FOI 21/22-1320) 2 May 22
https://www.righttoknow.org.au/request/n...

So, my questions are:

1. Who specifically provided the advice that the NDIA was not required to comply with or follow the PSPF? Job title and location will suffice
2. Noting all these new roles and requirements, was the person(s) consulted at the NDIS at the time qualified and competent to answer questions on cyber/security and the PSPF?
3. As the NDIS seems to have overnight sought to align with and comply with the PSPF, please provide a copy of the instruction or directive to do so.
4. Has there been (or is there) an investigation into providing inaccurate, seemingly false or potentially misleading information about the NDIS security (cyber included) obligations, compliance and assurance requirements?
5. Prior to this new found support and embracing of the PSPF, which specific security standards and framework did the NDIS/NDIA employ, attest to, report to the Attorney General's Department or provide guarantees, compliance or alignment with to any other Government/public entity?
6. Please provide a copy of the requirement and approval for all these new, sudden cyber security roles. Has the threat changed?
7. How many NDIS staff, contractors, providers and participants have been affected or compromised as a result of the Medibank, Optus, Australian Clinical Labs, or any other data breach, compromise or hack?

No doubt all this change will summed up and clarified further in the recent device security and cyber security question around BYODs
https://www.righttoknow.org.au/request/n...

Yours faithfully,

Florence

foi, National Disability Insurance Agency

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Florence left an annotation ()

Remembering, the NDIS has never ever had non-Australian Citizens work there:
https://www.righttoknow.org.au/request/n...

Hired anyone for roles without prior experience and qualifications in the key area of management
https://www.righttoknow.org.au/request/n...

Was ever impacted by the Log4j2 vulnerability
https://www.righttoknow.org.au/request/n...

Complied with all data storage (on shore, etc) required by a government entity
https://www.righttoknow.org.au/request/n...

And can access them accordingly (and lawfully)
https://www.righttoknow.org.au/request/n...

foi, National Disability Insurance Agency

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Dear Florence

 

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foi, National Disability Insurance Agency

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Dear Florence

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The NDIA acknowledges the Traditional Custodians of Country throughout
Australia and their continuing connection to land, sea and community. We
pay our respects to them and their cultures and to Elders past, present
and emerging.

 

 

[You don't often get email from
[3][FOI #9565 email]. Learn why this is
important at [4]https://aka.ms/LearnAboutSenderIdentific... ]

 

Dear National Disability Insurance Agency,

 

You seem to be on a hiring blitz for cybersecurity folk. As of 13 Nov 22,
you have no less than 6 cyber security positions you are trying to fill,
all seemingly new roles.

 

1. Director Cyber Security Risk & Compliance (Canberra) 
[5]https://aus01.safelinks.protection.outlo...

2. Director Cyber Security Risk & Compliance (Geelong)
[6]https://aus01.safelinks.protection.outlo...

3. Assistant Director Cyber Security Operations Centre (Capability
Development) (Sydney)
[7]https://aus01.safelinks.protection.outlo...

4. Assistant Director Cyber Security Operations Centre (Capability
Development) (Geelong)
[8]https://aus01.safelinks.protection.outlo...

5. Assistant Director Cyber Security Operations Centre (Capability
Development) (Canberra)
[9]https://aus01.safelinks.protection.outlo...

6. Assistant Director Cyber Security Operations Centre (Capability
Development) (Canberra)
[10]https://aus01.safelinks.protection.outlo...

 

All Assistant Director Roles state: "A new role awaits - The Protective
and Cyber Security Branch implements the requirements of the Protective
Security Policy Framework (PSPF) and Information Security Manual (ISM)
within the Agency. This is achieved by providing strategic, Agency-wide
oversight of Security across security governance, information security,
personnel security, physical security, and cyber security and operations."

 

Whereas the Director Roles state: "Ensuring that the Agency meets all
legislated and regulatory responsibilities for Agency information
technology security, including remaining up to date with amendments to the
Information Security Manual (ISM) and the Protective Security Policy
Framework (PSPF)."

 

This seems odd or mistaken. As the NDIA/NDIS has repeatedly stated that
the PSPF has nothing to do with the NDIS and the NDIA have no obligations
what so ever to follow or adhere to the Commonwealth Government's
Protective Security Policy Framework.

 

"As a corporate Commonwealth entity, the Agency is required to adhere to
the PSPF.", page 5, NDIS/NDIA Agency Security Plan, Sep 2020 seems
somewhat at odds with the NDIS' declaration that "The NDIA is a Corporate
Commonwealth Entity (CCE) which means that the Agency is NOT required to
adhere to the PSPF", page 3, FOI 21/22-1320 - Notification of Decision, 2
May 22

[11]https://aus01.safelinks.protection.outlo...

 

Repeatedly refuted and denied by the NDIS:

 

1. Data/information security - Salesforce (FOI 20/21-0873) 30 Jul 21

[12]https://aus01.safelinks.protection.outlo...

 

2. NDIA Project Risk Management Policy and Procedure (FOI 20/21-0872) 11
Jun 21

[13]https://aus01.safelinks.protection.outlo...

 

3. NDIS APIs, Security, Risk and Assurance (FOI 22/23-0600) 25 Oct 22

[14]https://aus01.safelinks.protection.outlo...

 

4. NDIS Register of Security Designated Positions (FOI 21/22-0864) 11 Mar
22

[15]https://aus01.safelinks.protection.outlo...

 

5. NDIS: Security Plan, Security Quality Assurance Policy & Personnel
Security - PSPF (FOI 21/22-1320) 2 May 22

[16]https://aus01.safelinks.protection.outlo...

 

So, my questions are:

 

1. Who specifically provided the advice that the NDIA was not required to
comply with or follow the PSPF? Job title and location will suffice 2.
Noting all these new roles and requirements, was the person(s) consulted
at the NDIS at the time qualified and competent to answer questions on
cyber/security and the PSPF?

3. As the NDIS seems to have overnight sought to align with and comply
with the PSPF, please provide a copy of the instruction or directive to do
so.

4. Has there been (or is there) an investigation into providing
inaccurate, seemingly false or potentially misleading information about
the NDIS security (cyber included) obligations, compliance and assurance
requirements?

5. Prior to this new found support and embracing of the PSPF, which
specific security standards and framework did the NDIS/NDIA employ, attest
to, report to the Attorney General's Department or provide guarantees,
compliance or alignment with to any other Government/public entity?

6. Please provide a copy of the requirement and approval for all these
new, sudden cyber security roles. Has the threat changed?

7. How many NDIS staff, contractors, providers and participants have been
affected or compromised as a result of the Medibank, Optus, Australian
Clinical Labs, or any other data breach, compromise or hack?

 

No doubt all this change will summed up and clarified further in the
recent device security and cyber security question around BYODs

[17]https://aus01.safelinks.protection.outlo...

 

Yours faithfully,

 

Florence

 

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this information is prohibited and may result in severe penalties. If you
have received this e-mail in error please notify the sender immediately
and delete all electronic and hard copies of this transmission together
with any attachments. Please consider the environment before printing this
e-mail
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