QFF regards personal information as its chief business asset and has invested multiple resources to safeguard it. 4.53 Formal PIAs are generally only undertaken for major projects. This Code sets out expectations for how we act, solve problems and make decisions. The Group is keenly aware of the risk posed by trusted insiders people who seek to use privileged access provided in the context for doing their jobs to facilitate illegal activities, such as transporting illicit substances. [8] The European Union General Data Protection Regulation (the GDPR), which commenced 25 May 2018, contains new data protection requirements. Qantas. All analytic insights work is run in a de-identified environment by a separate team using the anonymous identification number discussed above at 4.71, which enables analysts to examine behaviours and answer questions without referring to personal information. Your cyber security policy doesn't need to be very long; most SMEs should be able to fit theirs onto a single sheet of paper. Weve overcome many obstacles in our long history and this is because weve quickly responded to changing environments and worked hard to produce the right outcome helped by the resilience of our people and their commitment to the national carrier. 3.4 Registration involves collecting a variety of personal information from individuals, including: 3.5 Following registration, members receive a membership number, confirmation email, and a membership pack including a QFF card. Therefore, the OAIC recommends that QFF, along with Qantas, formalises the current cyber security governance material, such as the GCSC charter documents, to specifically encompass privacy. 4.39 The QFF CEO is ultimately responsible for business risks (including privacy risks), and the QFF finance manager has responsibility for the QFF risk profile. The OAIC also suggests, due to the varied and complex nature of such assessments, that QFF regularly revisit and revaluate their privacy assessment mechanisms. The Group Policies apply to Qantas Group entities and employees in line with the Groups Corporate Governance Framework. 4.79 Most marketing communications sent by QFF are customised. We comply with government and regulatory agencies to integrate risk strategies through a holistic approach ensuring a robust framework is in place to counter any crisis management, contingency planning and business continuity event. The cyber safety of Qantas Frequent Flyers is a priority for us. Sydney, Australia. Safety and Health Policy; and 10. This is an internal control or risk management issue, the solution to which may lead to improvement in the quality and/or efficiency of the entity or process being assessed. Complex privacy queries and requests are also referred to Group Legal in the same manner as complaints. Qantas has been looking for a security head since August last year. Executive Summary. 4.24 Qantas Group General Counsel reports to the Qantas Group Chief Executive Officer (CEO). 4.87 Based on the OAICs review of documents and interviews with QFF staff, there appears to be effective privacy safeguards in place for QFFs marketing and data analytics activities. 4.93 QFF uses the Qantas Group-wide privacy policy, also referred to as the Group privacy statement. Multi-factor authentication of member accounts. Crisis response is heavily reinforced in staff training and practice exercises, and involves staff at all levels, including the executive. Access to QFF data requires specific authorisation. Qantas and its related bodies corporate are referred to as Qantas Group in this report. We are at the forefront of improving security outcomes for customers and employees by operating within a security framework that is proportionate, agile and responsive to changing threats and risks across our network. 5.1 The OAIC recommends that QFF develops and implements a Privacy Management Plan that sets out specific goals and objectives for its privacy management with consideration of the specific issues that apply to its operations. This report has been published in full. With the assistance of the Qantas Group Cyber Security Centre, the website was detected not long after it was built and we have worked with the internet service provider to take it down. The Qantas Loyalty segment specializes in customer loyalty recognition programs. We may contact you using the below methods: A phone call from one of our fraud analysts. June 14, 2022 . The OAIC recommended that QFF: 2.1 Loyalty programs are popular with consumers and businesses alike, with one Australian consumer research study reporting that 87 percent of Australians aged 18 and older were members of a loyalty program in 2017. Your use of these systems may be monitored and investigated to ensure compliance with the law and Qantas Policies. How do you quantify cyber risk management? The economic contribution of the Qantas Group to Australia in FY 2017. Staff complete the training at induction and then every three years. The safety and wellbeing of our customers and people is our highest priority. 4.51 The Qantas crisis management plan and its various supporting documents serve as a data breach response plan. IAPP Asia Advisory Board Member & Singapore Chapter Co-Chair, DPO & Privacy Program Manager, International SOS RAAF Base Curtin to see $244m upgrade; Bonza bound for Tamworth with flights from Melbourne, Sunshine Coast; Podcast: How Lockheed Martin 10.Security Policy. This process is documented in a Qantas privacy procedure document, which is a high-level internal document that sets out broad privacy obligations. By continuing to use this system you confirm your acceptance of the above. We encourage our people to report safety and security-related matters, even when they are closely involved and might feel vulnerable to criticism. All SIAs are recorded in the system and can be recalled or examined as needed. The Qantas Group is constantly improving its cyber capabilities as part of its overall data and privacy protection. Our commitment to a healthy, safe and secure environment for our people and customers. Once a SIA is formally underway, its progress is generally informal and collaborative, and may involve the project owner, the DISO, Legal, and any other relevant business units. Qantas has ordered 20 Airbus A321XLRs and 20 A220-300s narrow jets. name, email address, phone number). Specifically, the assessment examined whether: 6.4 Where the OAIC identified privacy risks and considered those risks to be high or medium risks, according to OAIC guidance, the OAIC made recommendations to QFF about how to address those risks. Some projects may be subjected to this process multiple times. It covers the occupational lifecycle from recruitment, ensuring that employees have optimal health, as well as any necessary accommodations and support. 4.85 For this assessment, the OAIC considered that QFFs APP 1 privacy policy and APP 5 collection notice adequately describe how a members personal information may be used for marketing and data analytics purposes. 4.48 The response triggered by an incident notification will depend on the nature and severity of the incident. Where privacy complaints are received outside of this process (including by phone or by mail), a file/record is created in the complaints handling system. The Main Types of Security Policies in Cybersecurity. 4.31 Compliance with APP 1.2 is fundamentally about good privacy governance. We take active, quality measures to help you keep safe online and we also encourage our members to do what's possible to protect their account and personal information. Cyber risk ratings influence business activity from the loading dock to the board room. [5] Qantas EpiQure was re-branded as Qantas Wine after the assessment. Likely breach of relevant legislative obligations (for example, APP, TFN, Credit) or not likely to meet significant requirements of a specific obligation (for example, an enforceable undertaking), Likely adverse or negative impact upon the handling of individuals personal information, Likely violation of entity policies or procedures. In addition to appointing a Group Privacy Officer, Qantas is also establishing a dedicated Data Privacy team to bring together its privacy experts under one team and implement a coordinated enterprise-wide strategy and framework, including further investment in resources and technology that will support the Qantas Group to effectively address the intensifying global privacy regulatory requirements. 4.59 QFFs current approach to PIAs and other privacy assessments is collaborative and thorough. 4.97 Additionally, while the policy identifies that Qantas collects information about dietary requirements and health issues, this is not specifically identified as sensitive information. Join to connect Qantas. 3.1 QFF was established in 1987, and had over 11.4 million members in June 2016. In 2020, security breaches cost businesses an average of $3.86 million, but the cost of individual incidents varied significantly. It may also be updated on an ad hoc basis as needed, for example, following key personnel changes. This was a difficult program of work that required careful planning and scheduling. [10] The Flesch-Kincaid test used to assess the readability of Qantas privacy policy can be accessed at The Readability Test Tool. The CHESS has responsibility for strategy, policy, systems oversight, monitoring and corporate governance over operational risks of the Qantas Group. Request access from Qantas's to view their private documentation available on demand only. Maintaining a regularly updated directory of all of the information assets (including personal information) held by QFF, and where these are stored. When you're managing the travel needs of multiple people, we understand the size of the group can often change. If staff clicked the enclosed link, they were redirected to a notification page informing them that they had failed a phishing test. 4.78 As stated above, QFF holds all personal information in data warehouses, with highly restricted access. provide and operate competitions, promotions and events, distribute newsletters and other communications either directly or through a third party, facilitate participation in Qantas and program partner loyalty programs, conduct marketing activities for Qantas or third party products and services (the collection notice states that this is one of the primary purposes of QFF), conduct market and other research to improve Qantas products, services and marketing activities. The most important thing is clarity. 1.5 The OAIC identified two medium risks regarding QFFs privacy governance and evaluation of the continued effectiveness and appropriateness of its privacy practices, procedures and systems, and made two recommendations to address the risks identified. Darren Argyle (CISM, CISSP) is an accomplished executive with close to 20 years international cyber risk and security experience. Assessment undertaken: MayJune 2017 Draft report issued: 9/10/2018 Final report issued: 30/6/2019. 1.1 This report outlines the findings of an assessment of the Qantas Frequent Flyer (QFF) program undertaken by the Office of the Australian Information Commissioner (OAIC). QFF also has contractual rights to audit the third party and the QFF information they hold throughout the course of the relationship. 5.2 QFF sincerely appreciates the OAIC assessment finding that it has robust and effective privacy practices, and QFF acknowledges that an ongoing compliance commitment is required to protect the privacy and maintain the security of the personal information it holds. A Group data privacy, ethics and governance function has been established to assist us to better ensure personal information is handled fairly, ethically and responsibly. [9] Office of the Australian Information Commissioner (OAIC), Big data and privacy: a regulators perspective, viewed 26 September 2017. The observations and information contained in this report reflect the circumstances as at the date of the assessment (June 2017). Qantas Group Policies The Qantas Group has a set of 10 Group Policies, which reflect the Non-Negotiable Business Principles and outline the minimum expected standards across a range of governance areas where compliance is necessary for legal reasons and to protect our brands and reputation. Sports events, family reunions, mining operations, conferences, incentives and more. November 3, 2021. A data breach will trigger a crisis response, the extent of which depends on the nature and severity of the breach. Marketing campaigns are sent to different member lists. This is known as the crown jewels directory, and is owned by the QFF DISO. The recent increase in oil prices has been a threat for the aviation sector's success. QFF requires two-factor authentication for making changes to member accounts. by KirkpatrickPrice / March 29th, 2021 . 4.22 QFF staff have a good awareness of privacy issues. The ability to respond seamlessly to events that impact the Group is fundamentally important in ensuring continued Group operations in the event of a discontinuity of service, mitigating risks and minimising disruptions to our customers. Further detail on this approach is provided in Chapter 7 of the OAICs Guide to privacy regulatory action. IT Security Specialist, Security Supervisor, Information Security Analyst and more on Indeed.com Cadetship, Cyber Security Jobs in Sydney NSW (with Salaries) 2022 | Indeed.com Australia All employees receive security, privacy, and compliance training the moment they start. We pay our respects to the people, the cultures and the elders past, present and emerging. Due to this assessments scope, the OAIC did not consider most of these controls in detail. The Qantas Groups FY21 performance for Total Recordable Injury Frequency Rate and Lost Work Case Frequency Rate both improved compared to the prior year. The OAIC has not identified any privacy risks based on the assessment scope and the above-mentioned observations. While membership of the GCSC includes representatives from Legal/Privacy, and a reference to the Privacy Commissioner, the objectives and responsibilities of the Committee outlined in the charter document focus on cyber risks and do not specifically call out privacy issues. Incident notifications may come from a variety of channels. 4.88 Additionally, given the amount of personal information that QFF handles and the extent of its use in marketing and data analytics projects (whether in identified or de-identified forms), the OAIC also suggests that QFF continue to monitor and assess the risks of these projects as they progress, including any risk surrounding re-identification or the creation of new data sets. If a query relates to a QFF membership, then the call is referred to the QFF specific customer care team. The DISO regularly briefs both the CEO and Chief Information Officer (CIO), formally and informally. 4.13 Qantas has target timeframes for response due dates, including for privacy complaints. Get Qantas Airways Ltd (QAN-AU:ASX) real-time stock quotes, news, price and financial information from CNBC. Qantas works closely with the Australian Government and overseas agencies, regulators, law enforcement and its global partners across the industry to proactively monitor and manage threats and risks. This includes aviation safety, WHS, environment, security (including cyber security) and business resilience matters. Enterprise security management (ESM) issues directly revolve around the management of Qantas group itself. The companys policy is in the consultation stage, and no direction yet has been made. simplifies the notice to enhance readability, changes the title from important information to something that indicates to potential members that the notice relates to the collection of their personal information. Qantas suffered a 30 percent turnover in its technology personnel as the airline battles staff loss, in the wake of repeated Covid-19 lockdowns. QFF anticipated that the next such large-scale change would occur in 2018 to reflect the commencement of both the Notifiable Data Breaches Scheme[7] and the European Union General Data Protection Regulation (GDPR). It describes the standards of conduct we expect. Additionally, the OAIC has recently released an online PIA learning tool which aims to better equip organisations with the knowledge to conduct an in-house assessment. Members are required to undergo a telephone identity check and staff follow a security procedure and checklist to guide them through the process. A clean desk policy, and non-permanent seating arrangements, necessitating that all personal and confidential items be stored in secure staff lockers. 4.2 The key findings of the QFF assessment are set out below under the following headings: 4.3 The OAIC has applied its guide, Privacy management framework: enabling compliance and encouraging good practice, to its consideration of the reasonable steps that QFF has taken to address the requirements of APP 1.2. 4.98 The OAIC considers that there is room for improvement in the readability of the policy, and suggests that QFF works with the Qantas Group to review and, where possible, simplify the language of the policy. Human resource and other policies exist at entity or business unit level, which also outline the minimum expected standards for our people in the context of their employment. Where privacy complaints are received outside of this process (including by phone or by mail), a file/record is created in the complaints handling system. Participate in group Cyber Security Technical forums to align the Qantas Cyber Security and the Connected Aircraft management systems and communication flow Manage Aircraft Controllable. Villanova University Salary Bands, If a privacy complaint must be escalated, the corporate liaison manager reports the complaint to the Customer Care Manager who then reports it to Group Legal. Possible adverse regulatory impacts, such as Commissioner Initiated Investigation (CII), public sanctions (CII report) or follow up assessment activities. We collect, share, use, store and process personal information in accordance with an ever changing and increasingly complex landscape of both international and domestic laws and regulations. This may lead to the loss of vital information regarding identified privacy risks. Number of Employees: 25,000. Privacy Amendment (Notifiable Data Breaches) Act 2017, Australian entities and the EU General Data Protection Regulation (GDPR), Big data and privacy: a regulators perspective, Ting 4.42 However, in view of the complexity of Qantas current risk management structure and framework, the OAIC suggests that QFF: 4.43 The Qantas Group has a co-ordinated Group-wide approach to crisis management, which includes a crisis management plan. Security Policy. Queries and access requests are managed on Resolve and are checked daily by customer care managers. 4.23 QFF Legal has primary responsibility for advising QFF on privacy compliance matters. This involves the project owners explaining to an executive panel, including the Group CEO and CFO, the risks of the project, including privacy and data risks, and justifying the need to accept those risks, as well as presenting mitigation strategies. QFF Legal reports to the Qantas Group General Counsel, who has ultimate responsibility for all privacy compliance matters in the Qantas Group. Some complaints were caused by operator error, for example, passing on details to the wrong recipient. The Head of Human Resources is required to sign-off on the completion of all required training in a report to the QFF CEO. 3.7 Members personal information continues to be collected at various points throughout their membership, including when they earn and redeem Qantas Points and Status Credits,[6] and when they interact with QFF marketing campaigns. We ensure the safety and welfare of our people, the protection of our reputation and the maintenance of critical services. However, the OAIC notes that it is heavily dependent on key staff involved and is not recorded unless it forms part of the SIA or includes written advice from Legal. The Cyber Cooperation Program and Singapores Ministry of Transport has partnered with the Association of Asia-Pacific Airlines, Qantas Group and EY to support the Aviation Cyber Resilience Project, a series of workshops aimed at building cyber capacity in the aviation industry throughout the Asia-Pacific. Accuweather Ulster County Ny, Oct 2016 - Present6 years 4 months. The Group Business Resilience Management System (GBRMS) is an integrated response and recovery system across Qantas Groups strategic, operational and tactical environments, and is subject to a variety of airline and safety standards and regulations. Possible ministerial involvement or censure (for agencies), Risks are limited, and may be within acceptable entity risk tolerance levels, Unlikely to breach relevant legislative obligations (for example, APP, TFN, Credit), Minimum compliance obligations are being met. Possible reputational damage to the entity, such as negative publicity in local or regional media. In addition, Jetstar's head of cyber security Yvette Lejins started a broader Group role at Qantas this month as the head of 'cyber business protect', which covers the Jetstar Group, Qantas .
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