NDB scheme imposes potentially harsh penalties on companies that fail to disclose breaches of data that they are required to protect under existing Privacy Act provisions. Companies considering broad employee and data monitoring programs will want to proceed carefully despite a global review that found such programs are easier to introduce in Australia than almost any other country. Some will try to tighten their security practices with new employee-monitoring tools, which allow for regular screenshotting and other methods of monitoring everyday activity. CSOs should not go it alone when developing such programs or implementing tools to improve monitoring in line with NDB’s expectations.”]