I am working on an assessment - here is the scenario and information I have:

Turtle Movers is committed to protecting the privacy of the personal information of our clients and employees. We value and respect the privacy of the people we do business with and who work for our company. Turtle Movers' Privacy Policy complies with the Australian Privacy Act 1988 (Cth) and other relevant privacy laws and regulations. This Privacy Policy covers all employees and clients of the company and outlines how we collect, use, retain and disclose personal information gathered to carry out our business activities.

Information we may collect Contact information Name and surname Pickup address Delivery address Email address Phone number Transaction details and history Bookings Cancellations and rescheduling Insurance Payment method Refunds Rewards and loyalty benefits Banking and/or credit details Details of payment method (For example, financial institution, account) Correspondence and communication Emails Phone messages Phone records How data is collected Turtle Movers collect data from your online transactions. Transactions include information on your online removalists' queries, service bookings and payments. How data is used We use the data collected from your online transactions to: process your online removalists bookings and related activities deliver a personalised experience manage internal administrative and taxation processes support our marketing strategy We retain your personal information linked to removalists' jobs for the period of time required by the taxation department. For other situations, we only retain the data collected for the duration of the business activity. Disclosure of information Turtle Movers does not share or sell your data to third parties and will seek your consent if personal data needs to be shared with a third party, such as an insurance company. There may be circumstances where we need to disclose your data to legal authorities, and we will do so as permitted by the law. Retention and disposal of data Turtle Movers will keep your personal contact details and transaction data stored securely for the required period of time to comply with taxation legislation. After that period has elapsed, your data will be destroyed. Concerns and complaints To lodge a complaint against this policy, download the complaint form from our website and follow the lodgement instructions. All complaints are addressed promptly and professionally. Contact us if you have any questions or concerns regarding this policy. Contact details: Email: t..stm.com.au Phone: 123456789 PRIVACY PROCEDURES for Turtle Movers Lodging a Privacy Complaint

Purpose: This procedure outlines the actions that need to be carried out to lodge a Privacy Policy complaint. Scope: All employees and clients of Turtle Movers Responsibilities: The responsibility for actioning, processing and resolving privacy complaints falls on Turtle Movers' management. Lodging a privacy complaint: To lodge a privacy complaint, you need to access the Privacy Complaint Form from the company website. It is located in the legal section of the website. You can request the form to be sent to you via email. Once you have the form, complete all sections with as many details as possible to ensure that there are no delays in processing the complaint. Submit the completed form if you accessed the website form, or email the form if you requested one via email. Acknowledgement of privacy complaint Turtle Movers take complaints seriously, and will endeavour to acknowledge receipt of the complaint within 48 hours. Processing a privacy complaint Management will investigate the complaint within 7 days of receiving it. During this period, they may contact the complainant if further information is required. In most cases, complaints are resolved in conversation with the complainant by addressing all the issues and concerns and negotiating a resolution. If more information or investigation is required and the process is delayed, management will keep the complainant continuously updated on the process. Resolving and closing a privacy complaint Once processing, investigation and communication with the complainant has concluded, management will communicate the resolution to the complainant. If both parties agree at this stage, the resolution will be formally documented and archived by management. If it is pertinent, management will formally apologise to the complainant and take the necessary measures to eradicate the problem. In the event that a mutually agreeable resolution has not been reached, either party may decide to get independent legal advice on the matter. Turtle Movers is committed to resolving all complaints promptly and amicably. PRIVACY PRACTICES for TURTLE MOVERS

Turtle Movers has in place a set of privacy practices to ensure that employees comply with company policy regarding privacy. These practices aim to protect the privacy of customers' personal data.

Privacy practices: Enforce strong passwords. Employ encryption for sensitive data. Compulsory privacy training and awareness of all employees. Back up data. Protect data from insider threats. This type of threat may originate from: Negligent employees Third-Party Partners Ex-employees Policy Evaders Use end-point security systems to protect data Conduct proper disposal of electronic and physical copies of personal and protected data. Implement a trifecta of physical, technical, and administrative controls to safeguard personal information.

One of the task are as follows:

Cyber Security Findings and Recommendations

After completing the review of the two organisations in the preceding tasks, write the recommendations you would make as the Cyber Analyst/Consultant for each organisation, regarding:

a) Compliance with legislation and regulatory requirements

b) International cyber security legislation impacting their businesses -Turtle moves only trade in Australia hence no International cyber security legislation is impacting their businesses

c) Potential impact of upcoming reforms in privacy, consumer and surveillance legislation

And after some research I have answered:

1.Revise and Strengthen Privacy Policies

Though Turtle Movers comply withAustralian Privacy Act, I have found no evidence that outline their use of cookie identifiers. While the Privacy Act does not directly mandate specific rules for cookies, businesses must ensure they comply with the APPs in their privacy policies. This means they should inform users about the types of personal information collected, how it's used, and how users can manage their information. In practice, this includes disclosing the use of cookies and similar technologies. With the potentially new reform that will align close to the European Union's GDPR, it would benefit Turtle Movers to start preparing for the changes and include this in their policy.

With that in mind, I would further advise when collecting personal information, it would be a good idea to ensure all forms, digital or paper- have a consent box that by ticking the box, the customers agree to receive marketing communications or allow the data to be used for marketing purposes. This is a good practise and will also ensure to protect the business if they use the information for marketing purposes in the future.

Moreover, an updated Lodging of privacy Complaint in the privacy procedure is essential, especially if the new laws take place. The policy needs to be more specific and detailed, and words such as 'endeavour' cannot be used. Clear timelines need to be specified and met.

Further, what really needs to be implemented with urgency is anIncident Response Plan (IRP). Though it is mention of administrative controls, it doesn't specifically mention an IRP. This plan needs to clearlyoutline the procedures and protocols Turtle Movers should follow when a cyber-attack occurs.

A framework for this I would recommend is TheIncident Response Frameworks steps from NIST. The steps are:

• Step #1: Preparation
  • Establish a Computer Security Incident Response Team (CSIRT)
  • Create and regularly update the incident response plan
  • Regularly train the incident response team
  • Use threat intelligence to learn about possible cyber threats and then use that information to improve your security tools.
• Step #2: Detection and Analysis
  • Look for signals that indicate an incident might be happening or has already happened.
  • Determine if these signals are real threats or false alarms.
  • If the signals are valid, record all details and actions taken.
  • Evaluate the incident based on its impact on the business, the confidentiality of affected information, and how easy it is to recover from.
  • Inform the relevant departments or individuals according to the IR plan.
• Step #3: Containment, Eradication and Recovery
  • Thecontainment phase focuses on stopping an incident from causing more damage. Once contained, the team can carefully plan the next steps, which include addressing the root cause and restoring systems.
  • Key strategies should be based on:
    • The importance of the affected assets
    • The type and severity of the incident
    • The need to keep evidence
    • The role of affected systems in business operations
    • The resources needed for the strategy
  • All actions should be documented, and evidence collected to improve security and prepare for potential legal issues
• Step #4: Post-Incident Activity
  • After any cyber incident, it's crucial to hold a "lessons learned" meeting to improve future responses. This meeting should involve all relevant parties and focus on:
    • What happened and when
    • How effectively the incident response team performed
    • Whether procedures were followed and if they were adequate
    • What information was missing and what actions slowed recovery
    • What could be done differently and how to prevent future incidents
    • Identifying new indicators or precursors
  • These meetings help improve security, update policies, and train new staff, while building valuable institutional knowledge.

This plan helps will help Turtle Moves respond quickly and effectively to minimise damage and recover from cyber incidents(Incident Response Plan: Frameworks and Steps, 2024).

Lastly, while Turtle Movers' privacy practices for network and data security appearappropriate, it would be beneficial to specify the types of endpoint security in place and clarify what strategies are in place for regularly updates. Additionally, clearly outlining the trifecta of physical, technical, and administrative controls in detail would strengthen the privacy policy

Then later in the assessment there is this task:

Privacy Compliance Findings and Recommendations

After examining the organisation' privacy policy and practices, write your findings and a set of recommendations regarding:

a) The level of compliance with current privacy legislation and required improvements

b) Adequacy of current practices and required improvements

So my question is, what is the difference?