Business Continuity Management for Risk Managers Lou Drapeau March 12, 2013 Greater Kansas City Chapter, RIMS PERK Program What is BCP? • BCP - Business Continuity Planning – The identification and protection of business processes required to maintain an acceptable level of operations in the event of sudden, unexpected, or not so unexpected, interruptions of these processes and their supporting resources 2 Where Are We Going? • More Integrated Solution – Business Continuity – Disaster Recovery – Emergency Response – Crisis Management Under The Banner of Business Continuity Management 3 Business Continuum Pre-Incident Planning Risk Assessment/Mitigation/ Prevention Evacuation - Life & Safety Incident/Crisis Management - Logical (Technology) BCM - Business Recovery - Relocation - Inventory Control - Processing - Emergency Response - Disaster Recovery - Business Recovery - Crisis Management Claims Processing Increase Production Levels Lessons Learned - Vendor management BCM Creation Post Incident Repair/Restoration - Physical Supply Chain 4 Incident Occurs - Reprioritize Product/Customer - Technology Recovery - Data Recovery - Processing Recovery - Mitigation/Prevention Risk Assessment vs. BCM Cause vs. Effect – Risk Assessment Reducing Causal Implications • Identifies Risk • Recommends Mitigation/Prevention measures – Probability – Cost – Severity – BCM - Deals with Effects Reducing Effects • What are the Implications of failing to mitigate or prevent – Preparation » Structure, planning, resources, testing – Execution » Relocation, operating under duress 5 Operational Risk is the risk that a business does not meet its obligations to its stakeholders due to an erosion of value or operational failure. BCM seeks to mitigate the effects of operational failures. Risk Opportunity How Does BCM Address Enterprise Risk Management? Upside Risk New Markets - Locations Expanded Distribution Channels Research & Develop Products New Technologies Economies of Scale Competitor Activity Compliance Downside Risk 6 Strategic Operational Failure Financial Controls Monitoring/Reporting Change Why BCM? External Drivers Effects • • • • • • • • • • 7 Pressure From Audit Committees Pressure From Financial Institutions Pandemic Concern New Threats & Risks Since 9/11 Demands From Customers Cost Of Insurance Perceived As Competitive Edge Reliance On Third Parties (Supply Chain) Increased Regulatory And Self-regulated Requirements • • • • • Loss Of Customers or Inability to Attract New Customers Loss Of Revenue Decrease In Stock Value Increase Of Insurance Premiums Loss Of Assets And Employees Regulatory Sanctions Post-9/11 Surge in Business Continuity Regulations and Standards Post-9/11 Pre-9/11 Consumer Credit Protection Act OMB Circular A-130 FEMA Guidance Document Paperwork Reduction Act ISO 27002 (Previously ISO17799) FFIEC BCM Handbook Computer Security Act 12 CFR Part 18 Presidential Decision Directive 67 FDA Guidance on Computerized Systems used in Clinical Trials ANSI/NFPA Standard 1600 Turnbull Report (UK) ANAO Best Practice Guide (Australia) SEC Rule 17 a-4 FEMA FPC 65 CAR 8 1991 - 2001 Sarbanes-Oxley Act of 2002 HIPAA, Final Security Rule FFIEC BCM Handbook -2003/ 2008 Fair Credit Reporting Act NASD Rule 3510 NERC Security Guidelines FERC Security Standards NAIC Standard on BCM NIST Contingency Planning Guide FRB-OCC-SEC Guidelines for Strengthening the Resilience of US Financial System NYSE Rule 446 California SB 1386 Australia Standards BCM Handbook GAO Potential Terrorist Attacks Guideline Federal and Legislative BC Requirements for IRS Basel Capital Accord MAS Proposed BCM Guidelines (Singapore) NFA Compliance Rule 2-38 FSA Handbook (UK) BCI Standard, PAS 56 (UK) Civil Contingencies Bill (UK) FPC 65 NYS Circular Letter 7 ASIS State of NY FIRM White Paper on CP NISCC Good Practices (Telecomm) Australian Prudential Standard on BCM HB221 HB292 BS25999 SS507 – SS540 TR19 CA Z1600 ISO/PAS 22399 DRII (SDO) Title IX – 110-53 2002 -------------------------------------------------------2008 Not Just IT “Business continuity planning is about maintaining, resuming, and recovering the business, not just the recovery of the technology.” “The planning process should be conducted on an enterprise-wide basis”. “Business continuity management (BCM) describes a whole of business approach to ensure critical business functions can be maintained, or restored in a timely fashion” “Business Continuity Management (“BCM”) is an over-arching framework that aims to minimize the impact to businesses due to operational disruptions. It not only addresses the restoration of information technology (“IT”) infrastructure, but also focuses on the rapid recovery and resumption of critical business functions for the fulfillment of business obligations.” 9 Title IX – 110-53 a. Goal of the new program is to provide a method to independently certify the emergency preparedness of private sector organizations, including their disaster / emergency management and business continuity programs. The program focuses on certifying the preparedness of businesses and other private sector entities, and does not involve any individual professional certification. b. The program will be voluntary. c. Key stakeholders are invited to participate in the development of the program. Consultation with a variety of organizations and various sectors is required by the legislation. Program development will likely include involvement by a diversity of private sector advisory groups and others. d. The program will be administered outside of government by 3rd party organizations with experience / expertise in managing and implementing voluntary accreditation and certification programs. e. One or more preparedness standards can be designated. NFPA 1600 is reference by example. f. Existing industry efforts, certifications and reporting in this area will not be duplicated or displaced, but rather recognized and integrated. g. Special consideration will be made for small business. 10 h. Proprietary and confidential information is to be protected. DHS Decides Approved Standards • ASIS International SPC.1-2009 Organizational Resilience: Security Preparedness, and Continuity Management System – Requirements with Guidance for use (2009 Edition). • British Standards Institution 25999 (2007 Edition) - Business Continuity Management.(BS 25999:2006-1 Code of practice for business continuity management and BS 25999: 2007-2 Specification for business continuity management) • National Fire Protection Association 1600-Standard on Disaster / Emergency Management and Business Continuity Programs, 2007 and 2010 editions. 11 How It Works ANSI-ANAB In progress - ANSI DHS 12 Next Steps • Creation of Accreditation Rules (AR) for Training of “Certification Bodies” – Approved by ANSI-ANAB – Must comply with ASTM 2659 and be approved by ANSI-CAP or ISO/IEC 17011 – Potential CB’s Must Take Course and Pass Examination • As of this Moment No Organization – Has Been Approved to Accredit Certifying Bodies – No Organization has been Grandfathered into Compliance with PS-Prep NFPA/DRI Audit Course Certification • DRI/NFPA Course is proceeding with ANSI-CAP Accreditation for the Course. Preliminary application has been approved • ANSI-CAP follows the accreditation process outlined in the international standard ISO/IEC 17011, General Requirements for Accreditation Bodies Accrediting Conformity Assessment Bodies as well as ASTM E2659 - 09e1 Standard Practice for Certificate Programs and recognized by ANSI-ANAB • Passing the Exam will Provide a Certificate of Completion (Because training is a requirement there can be no examination only) • This Certificate will Be Required to Seek CBCA/CBCLAs • DRI International will maintain recertification through continuing education (RABQSA requirement) Who Needs BCM? Industries / Sectors Who Needs BCM? By Size BCM Methodology Ensuring a consistent approach • Identifying • Analyzing • Designing • Executing • Testing Risk Plan Test & Maintenance Assessment Plan Develop / Execution BCM Life Cycle Strategy Selection Business Impact Analysis Process Mapping Program Policies & Procedures Policy statement Management commitment Program procedures and resources Roles, responsibilities, and authorities Analysis Risk assessment Impact analysis Criticality analysis Resource analysis Analysis of legal and other requirements Review, Maintenance, Improvement Corrective action process (acting on problems) Program revision and improvement Checking and Evaluation Exercises and testing Nonconformity and problem analysis Internal audits (system) 18 Planning Prioritization Objectives and targets Strategic and tactical plans for prevention, deterrence, readiness, mitigation, response, continuity, and recovery Implementation & Operations Controls Operational procedures Awareness and training Communications and warning Document and information control Resources and finances Incident management (procedures and controls for before, during and after a disruption including prevention, mitigation, response and recovery) DRI International – Who Are We? • A Non-Profit Organization Committed to: – Promoting a base of common knowledge for the continuity management industry – Certifying qualified individuals in the discipline of Business Continuity – Promoting the credibility and professionalism of certified individuals • Will Celebrate our Twenty-fifth Anniversary in 2013. • The Industry’s Premier Education and Certification Program Body DRI International – Who Are We? DRI International has Certified INDIVIDUALS in over 95 Countries. DRI International conducts training courses in over 45 countries. More individuals choose to maintain their certification through us than all other organizations in our industry combined (Over 7,500 individuals as of 2010) DRI International certifies individuals in English, Spanish, French, Japanese, Mandarin (expanding to Portuguese and Russian this year, Italian and Korean early next year) Conducts Courses for: Insurance , Audit, Healthcare, Higher Ed 2nd Annual conference June 4-8, 2013 in Philadelphia Business Continuity Management for Risk Managers Questions?