Policy Insight

It's Not Our Fault No Longer Protects

Australia's Consumer Data Right determination shows why third-party failures are still your accountability.

Home · Customers · It's Not Our Fault No Longer Protects
Overview

Regulators are making one thing clear: accountability cannot be outsourced

The Australian Privacy Commissioner held Regional Australia Bank liable for a Consumer Data Right breach caused by its third-party service provider, Biza Pty Ltd. Even without knowledge of the technical failure, the bank remained responsible for data governance, data integrity, and the controls needed to ensure its provider met compliance obligations.

CaseRegional Australia Bank and Biza
RegimeConsumer Data Right
ExposureCDR data from up to 197 consumers
MessageData holders remain accountable
Risk drivers

Third-party failures now create direct governance, trust, and executive risk

Contracts are not enough

Contractual protection does not prove that providers are meeting data, security, and compliance obligations.

No news is not assurance

Regulators expect active oversight, regular assurance, and proof that third-party risks are being managed.

Customers hold you responsible

Customers rarely separate direct failures from provider failures when their data, trust, or service is affected.

Board scrutiny is rising

Directors and executives face increasing pressure to explain supply-chain governance and operational resilience.

Ikara response

Ikara helps organisations orchestrate third-party accountability in real time

Monitor continuously

Replace annual questionnaires with live visibility into provider security posture, compliance status, and service risk.

Align commercial controls

Connect contractual obligations to measurable technical controls, service levels, and data governance practices.

Escalate provider issues

Create predefined response, remediation, customer communication, and service restoration pathways.

Map supply-chain exposure

Show where vendors, systems, services, data flows, and regulatory obligations intersect.

Evidence reasonable steps

Capture proof that third-party obligations are being monitored, reviewed, and acted on.

Report accountable action

Give boards, executives, and regulators a clear record of control ownership and assurance activity.

Implications

The new operating model is risk orchestration, not risk avoidance

The RAB determination shows that organisations cannot depend on indemnities, silence, or provider assurances alone. Mature third-party risk management requires active oversight, integrated commercial and technical governance, and supply-chain visibility that stands up to regulatory review.

Ongoing provider assurance

Risk teams can see whether suppliers are meeting commitments before failures become incidents.

Stronger governance evidence

Commercial obligations, technical controls, and data protection duties are connected in one assurance view.

Faster response to failures

Escalation and remediation workflows help organisations respond transparently when supplier issues arise.

Conclusion

Your organisation remains responsible for the resilience of its digital supply chain

Third-party partnerships are essential, but they no longer diffuse responsibility. Ikara helps regulated organisations turn supplier complexity into monitored, evidenced, and accountable operational resilience.

Active oversight
Reasonable steps
Accountable resilience

Make accountability provable.

See how Ikara can give your organisation live evidence across suppliers, controls, and service obligations.

Book a demo