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    Stuart Low

    It's all well and good for the ACCC to state that independent testing isn't required but declaring an organisation "accountable" triggers compliance obligations of "how do we make sure" and CPS234 is pretty explicit about components related to information security (which is a major part of the aforementioned Consumer Data Standards) notably around testing control effectiveness.

    Outside of the Big 4, very few organisations would have the capability required to be specialists in the CDR especially given the continuing ambiguity and myriad of sources of truth.

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