BCP for Auditors

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Business Continuity & Technical Risk
For Auditors
A Going Concern, 2015
Agenda
 BCP / DR Overview
 Auditors Perspective
 Current Trends in BCP / DR
 Practical Considerations
 BCP / DR Demo in RPX
A Going Concern, 2015
About Us: A Going Concern
 Our company works with an association of highly skilled independent
consultants that are brought together to provide our clients the
specialized skill sets needed. This enables us to control costs and
ensure our clients the best value for their consulting dollar.
A Going Concern, 2015
Why do we care about BCP?
 Depending on where you work
– it may be required
 Changes in organizational
make-up demand it,
consolidation, globalization
 You will need to recover your
programs following a disaster
(really??????)
 Technology advances may
drive it
 People, Process, Technology,
and Third parties all matter to
us!
A Going Concern, 2015
Continuity Planning
 Business Continuity
ERP: Emergency Response Plan
Event Driven Response
(Site Impact)
Contamination,
Bomb-threat,
Fire,
Earthquake,
Wind,
Etc.
ERP
IT-DRP
Integrations
Integrations
Depending on Event,
The integration
of all Plans is
Possible.
Integrations
CMP: Crisis Management Plan
Event Escalation Response
Non-physical or physical impacts,
Examples:
Toyota, Recall
A Going Concern, 2015
IT-DRP: IT Disaster Recovery Plan
(Technology - Voice & Data Impact)
Network Failure,
Sabotage,
Virus,
Physical Loss of Systems
Etc.
BCP
Integrations
CMP
BCP: Business Continuity
Time Driven Response
(Site and Business and Image Impact)
Infrastructure Disruptions,
Healthcare Unit Disruptions,
Department Disruptions
(Failure to deliver product or service)
Business Continuity Program
The Important Components
Recovery
Detection
Emergency Response
Crisis Management
Business Continuity/IT Plans
Minutes
A Going Concern, 2015
Hours
Weeks
7
Planning Concepts and Issues
 Scenario based approach creates problems and roadblocks
– We think in terms of events
– We plan in terms of impacts to build flexible and responsive
plans
• For example, in Healthcare, Patient Safety is key
(immediate recovery need), whereas operations and
administration are vital and some of them can wait a long
time to recover.
 When building plans, the timeline to accomplish all the parts is
difficult to schedule and other priorities will continue to
compete for time from participants
 Some processes may need to be changed to make them
recoverable
A Going Concern, 2015
How do all these different elements work
together?
Incident Occurs
Normal Operations
Capability
Recovery Time Objective
Recovery
Risk Acceptance
Recovery
Return to
Normal Operations
Restoration Activities
Emergency Response
Restoration
Transfer & Finance
[Plan activation, strategy]
[Insurance]
Prevention
[ERM, Crisis Mgmt., DRP, BCP]
Crisis Management
Proactive Risk Activities
Prevention and Preparedness
Time
Reactive Risk Activities
Proactive Risk Activities
Prevention and Preparedness
Response, Recovery & Restoration
A Going Concern, 2015
Minimum
Acceptable
Level
of Capability
Process criticality and recovery sequence are
established with senior leadership and key
stakeholders.
Process
Process Criticality Classification
Determined by senior management
Criticality is a function of tolerance for
downtime and data loss at time of disaster
Sub Process
RPO
Determined by line management
96hrs
Tolerance
for Data
Loss
Recovery
Point
Objective
72hrs
Resources
48hrs
•People
•Data
•Work area
•Vital records
•Computing •Vendors
•Applications
24hrs
6hrs
6hrs 24hrs 48hrs
72hrs
RTO
Event
Tolerance for Downtime
Recovery Time Objective
A Going Concern, 2015
96hrs
Applications
Internal and external
applications
Why do auditors care about BCP?
 Depending on where you work
– it may be required
 Audit programs are an integral
part of the
mitigation/prevention - just
like you help in the Infosec,
Safety, Security, etc.
 You will need to recover your
programs following a disaster
(really??????)
 Driver for needed changes in
the organization’s culture.
A Going Concern, 2015
Some Audit Observations

IT DR Testing – Use of “virtual”
environments which do not completely
replicate the actual production environment

IT DR Testing – Lack of use of opportunistic
testing by way of required maintenance.

IT DR, Detailed Recovery Procedures – Lack
of documentation to allow for appropriate
hand-off between internal IT dependencies
during recovery

IT DR, Shared Drives – Use of network
shares for critical transactional data with
no means in place for failover.

IT DR, Sign-Off – Appropriate level of
leadership not accountable for the contents
of the DR SOP.

IT DR, Documentation – Lack of integration
between IT DR Plan and Business Continuity
Program.
A Going Concern, 2015
Current Trends in BCP / DR
A Going Concern, 2015
Areas to Watch
Trends for 2015
 Supply Chain focus (less manufacturers and suppliers)
 Technology – virtualization & cloud (public and private) services
(continues from the previous 3 years)
 Outsourcing of functions (changes the dynamics and risks)
 Broader communications
 More single points of failure
 Doing more with less
 Crisis Management Issues
A Going Concern, 2015
Supply Chain Focus
 Customers pushing BCP planning
down to suppliers
– Automotive industry has been
doing this for some time
– Food industry has begun this as
well
– HealthCare is poised
 Unreasonable demands
– Partner with competitors
– Suppliers maintain all inventory
– Tier one suppliers bear the burden
without the reward
A Going Concern, 2015
Technology - Virtualization
 Most companies now looking
at how to virtualize data
center and recovery
– See lower operating cost
– Do not realize potential
increase in risk
• Fewer machines, not clustered
• One breaks, many affected
 Applications may not handle it
well
 Complex existing
infrastructure may make it
hard to achieve
 Vendor dependence
A Going Concern, 2015
Outsourcing of Functions
 IT, HR, Data Centers
 They are not employees – their contract specifies actions and responses
 Critical functions may be outsourced
 You may not be their only client, nor their highest priority
A Going Concern, 2015
Broader Communications
 To All employees; not just response teams
 30 minute or less messaging
 External and internal recipients
 More forms
– Email
– Letters
– Printed materials
– Texts
– Media releases
A Going Concern, 2015
More Single Points of Failure
 Loss of personnel and shrinking headcount
– More gaps from senior to junior personnel
– Less staff = less cross-training
– Retirement disaster larger than ever
 Less spend on technology and redundant systems
 Outsourced functions
A Going Concern, 2015
Doing More with Less
 Less staff
 Less budget
 Less testing
 Less time with business
 More capability
 More responsibility
A Going Concern, 2015
Practical Considerations
A Going Concern, 2015
Practical Considerations for Auditors



How often should a plan be updated?
–
How often do you see them updated?
–
The answer is:
How much stuff needs to be in a plan?
–
How long do you think a plan will survive and
event?
–
Does it show how to lead and make decisions?
–
Does it provide for how we communicate?
How do you audit a plan without always being the
bad guys?
–
Just don’t do them?
–
Help explain why and how the planning works?
–
Staff assistance! (the other guy can do the work!)
A Going Concern, 2015
Tools and toolkits
 We commonly find plans built in MS
Word or Excel, which can be housed in
Sharepoint, network shares, or third
party cloud solutions.
 There are outsourced options for you –
we like RPX – Recovery Planner
 There are very complex and
comprehensive programs with web
based or locally hosted option – the
old Strohl Systems LDRPS (now part of
SunGard)
 Many are trying to use Archer to house
plans.
In BCP / DR you need a tool that fits your organizational need and
budget!
A Going Concern, 2015
Disaster Recovery
 BCP & IT DR Not exclusive of each other: Must have both for the system
to function
 Realistic requirements based upon expected impacts
 Team effort
 Must be consistent in “manual” processes and procedures
 Must be able to update systems when they are restored to maintain
accurate data and care provided record
 Tested in small teams, integrated into total package
 Training is essential – all team members must understand and be able
to follow the process
 Leadership and supervisor decisions to the recovery are essential
A Going Concern, 2015
Disaster Recovery
 Multi-layered approach required (Over-Arching DR Plan – DR Teams –
DR SOP’s)
 Simple backup to tape will not suffice (understanding tomorrow's
technology)
 Immediate availability is difficult and costly (and may still fail)
 If possible, design the recovery strategy into the data center(s) or
Colocation / Managed Solution
 Minimize single points of failure
 Automate where possible
 Build resistance to virus/trojan/malicious code into the backup and
recovery processes.
 Train, practice and demonstrate
A Going Concern, 2015
Business Recovery
 After the event, the data from before must be restored, then the data
during must be input to ensure an accurate patient record and business
record
 Cross functional teams are best at designing and implementing these
procedures. IT, Business Units, Public & Client areas, Administration
are all needed in these teams
 This is usually the last area implemented since the other processes
need to be in place prior to a restoration. The decisions in the previous
steps will affect the ability and process of restoration, so often it
becomes and iterative process.
 Keep the restoration in mind during the design phase(s)
A Going Concern, 2015
A practical example
A Going Concern, 2015
RPX – Recovery Planner
A Going Concern, 2015
Closing thoughts
A Going Concern, 2015
What about Ebola?
A Going Concern, 2015
Keys to success
 Keep the frustration level
very low
 Make it easy (BJ Fogg)
 Give it enough time
 Iterative processes
 It isn’t real until you
practice
http://www.behaviormodel.org/
A Going Concern, 2015
Contact Information
 Fred Klapetzky: 618.581.1047
fred@agoingconcern.com
 Keith Gregorio: 949.456.6074
keithg@agoingconcern.com
www.agoingconcern.com
A Going Concern, 2015
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