Business Continuity Management System (BCMS) Policy & Strategy Framework **ABC** Version 1.2 DRAFT INTERNAL USE ONLY Objective: The purpose of the BCMS is to provide a clearly defined and documented policy, framework and operational direction to ensure the resilience and continuance of the business critical activities. Scope: **ABC** (**ABC**) business activities within **Location1**, **Location2**. Audience: All officers, senior personnel and staff of the organisation who are involved in the provision of the Incident and Business Continuity capability of the organisation. Page 1 of 21 Table of Contents 1 Overview ................................................................................................................. 4 1.3 Best Practice ............................................................................................................ 4 1.4 Purpose .................................................................................................................... 5 1.5 Objectives................................................................................................................. 5 2 Policy and Organisation ........................................................................................ 6 2.3 Executive Management - Policy Statement .............................................................. 6 2.4 Incident Response & Business Continuity Structure ................................................ 7 2.5 Roles & Responsibilities ........................................................................................... 8 3 Understanding The Business ...............................................................................10 3.3 Business Impact Analysis ........................................................................................10 3.4 Risk Assessment & Risk Register ...........................................................................10 4 Determining BCM Strategies ................................................................................12 4.3 BCM Strategy Models..............................................................................................12 4.4 Process Level BCM Strategies ................................................................................13 4.5 Resource Recovery BCM Strategies .......................................................................14 5 Developing & Implementing BCM Response Plans............................................15 5.3 Business Continuity Plans .......................................................................................15 5.4 Incident Response & Management Planning...........................................................16 6 Embedding BCM in the Culture ............................................................................17 6.3 Awareness, Training and Culture ............................................................................17 7 Exercising, Maintenance & Review ......................................................................18 7.3 Exercising ................................................................................................................18 7.4 Maintenance ............................................................................................................21 7.5 Audit & Review ........................................................................................................21 Page 2 of 21 DATA STATEMENT The information and data provided herein shall not be duplicated, disclosed or disseminated by the recipient in whole or in part for any purpose whatsoever without the prior written permission from **ABC**. REVISION HISTORY Version/ Revision Release Date Originator Reason(s) for Change 1.0 **Date** **Person1** First draft 1.1 **Date** **Person1** **ABC** Feedback DISTRIBUTION LIST Recipient Role **Person1** BCM Project Documentation BCM Repository **ABC** Network Page 3 of 21 1 OVERVIEW This document provides an overview of the framework for Incident and Business Continuity Management within **ABC**. It is intended to be a ‘top down’ living document which provides vision, direction and unification of business continuity related activities. Its outline approach is based on best practice in order to develop an effective business continuity management capability through an established and robust process. 1.3 Best Practice The approach taken is based on best practice and uses the business continuity lifecycle as per ISO 22301 – Business Continuity Management standard. (Figure 1) illustrates the core components as per the standard. The PDCA methodology as laid by the BSI (Figure 2) Focussing on successful planning, doing, checking and acting. The aim being to ensure that **ABC**’s BCM provision is both holistic and supports the strategy and business need. Figure 1: Business Continuity Lifecycle – ISO22301 Adopting the PDCA - ‘Plan Do Check Act’ approach also ensures alignment with other quality and management systems such as ISO 9001 and 27001 for Information Security Management. Plan – Establish (Policies, objectives, processes, controls etc) Do – Implement & Operate (as above) Check – Monitor & Review (Against policy & objectives) Act – Maintain & Improve (Through preventative & corrective actions) Figure 2 – PDCA BCM (Business Continuity Management) requires planning across many parts of the business, which is demonstrated in this policy and strategy document, which in turn Page 4 of 21 becomes a key focus and of vital importance to all **ABC** management and staff in recognising the links between business activities, facilities, IT/Telephony and people resourcing. 1.4 Purpose The purpose of the BCMS Policy & Strategy Framework document is to provide **ABC** with an effective, fit for purpose, predefined and documented framework and process, in conjunction with best practice. 1.5 Objectives To provide a consistently clear view of the approach to be taken regarding Incident Response & Management and Business Continuity Management (BCM) within **ABC** To develop a BCM capability in line with best practice To ultimately recover and protect the business critical activities of **ABC**, thereby reducing any subsequent financial impact to the organisation To protect the **ABC** brand and minimise any adverse impact to it To be able to continually service the best interests of customers & stakeholders in terms of delivering the core objectives of the business, without compromise Page 5 of 21 2 POLICY AND ORGANISATION 2.3 Executive Management - Policy Statement Unwanted events such as floods, fire, terrorism or even system failures and data loss, all have the potential to cause severe disruption to the continuity of any organisation and its operations. The potential impact to **ABC** could have very real consequences, affecting employee health and safety, revenue, public reputation, stakeholder, customer confidence and above all our operating efficiency. Clearly this is undesirable and we must take appropriate measures as a business to ensure that we are prepared to respond in order to maintain both our operational capability and customer service focus. On this basis, the Executive Management Team and the Board has decided to incorporate Business Continuity Management (BCM) as part of its overall risk management strategy and corporate governance. It also demonstrates that we are a responsible and trustworthy organisation, capable of providing services to our customers. As a result of this challenge, the quality and completeness of our business continuity processes, strategies and plans are vital, as these could be crucial following an incident by underpinning the success of our recovery effort. This is not a one off exercise and will remain as an ongoing programme for the organisation and it is the duty of us all to ensure that we protect our future as we embark on new challenges to continue demonstrating the highest possible standards in all aspects of what we do. **Person2** Chief Executive - **ABC** Page 6 of 21 2.4 Incident Response & Business Continuity Structure The Incident Response Team (IRT) consists of a group of nominated individuals (differs by Incident type and area) who make up the initial IRT. The IRT is the group of key senior management that commands and controls the resources needed to respond to a situation which could impact **ABC** business operations. As the nature of an incident can be unpredictable, it is not possible or indeed wise to provide strict roles for the team members. Ultimately it is for the Incident response team Leader and the team members to organise themselves in an optimal manner, calling on any additional resource it requires. The following roles provide guidance of key areas of responsibility and potential activities. The Incident & Business Continuity structure is made up of Strategic, Tactical and Operational levels (often referred to as Gold, Silver and Bronze). The ‘Strategic’ level is represented by the Incident Response or Management Team, with ‘Tactical’ forming the Business Continuity response. The ‘Operational’ layer consists predominantly of business as usual activities; hence the roles will already be present or well defined within the existing structure at **ABC**. Page 7 of 21 2.5 Roles & Responsibilities INCIDENT RESPONSE Role Incident Response (IRT) Leader Responsibilities Team From the initial Incident notification, the IRT Leader has overall responsibility for declaring and dealing with the situation and for coordinating the strategic response. Communications To provide internal communications and liaise with the outside world including; ultimately ensuring that everyone is kept fully informed and briefed on any actions they need to take IT To ensure the IT systems, applications, data and communications infrastructure is recovered in a timely manner as per the business recovery profile HR To ensure the safety and well being of all **ABC** Staff Corporate Services To maintain the building environment and associated support services Finance To safeguard the financial security and stability of the organisation Core Functions/Depts Depending on the incident and functions which are impacted – decide which of the ‘Core Functions’ are required as part of the IRT. BUSINESS CONTINUITY Role Responsibilities Business Continuity Overall ‘fitness for purpose’ of Business Continuity capability/BCMS, Manager/Sponsor including management of contracts with 3rd parties such as work area recovery and IT resilience, exercising, testing and maintenance. Business Continuity Co-ordinators are responsible for the ongoing maintenance of their Co-ordinators/Plan functions in line with the schedule set out by the BC Manager and are also Owners responsible for co-ordination of the head office and primary location plan activities during execution, including resourcing and recovery. This includes all levels of content, including Business Critical Activities, Recovery Timeframe Objectives, strategies, resourcing, IT requirements, as well as all supporting documentation and appendices. They should also ensure that any dependencies are documented and verified, as being in place. Page 8 of 21 2.5.1 EMT (Sub BCM Steering Committee or Working Group) The BCM Steering Committee or Working Group should consist of a group of high-level stakeholders who are responsible for providing guidance on overall strategic direction on business continuity related matters. They do not take the place of a BCM Sponsor, but help to spread the strategic input and buy-in to a larger portion of the organisation. The meeting is most likely to be chaired by the Business Continuity Manager or natural stakeholder, with representatives from IT, Facilities 3rd party suppliers, project managers and selected business/directorate leaders where appropriate. The committee or group should look to meet on a predetermined but regular basis (every quarter as a minimum) in order to review potentially relevant matters, such IT infrastructure changes, strategic/business change or personnel amendments. It may also be appropriate for business continuity to form a part of the Executive Management meeting as a regular agenda item. Page 9 of 21 3 UNDERSTANDING THE BUSINESS 3.3 Business Impact Analysis Understanding the business and what we do is pivotal to the foundations and success of the **ABC** Business Continuity Programme. Defining the Mission or Business Critical Activities within the organisation is a key and primary activity and is based largely on two key metrics; namely. RTO (Recovery Time Objective) – Timescale in which mission, business critical activities must be recovered RPO (Recovery Point Objective) – Point in time to which work should be restored following a business continuity incident that interrupts or disrupts the organisation Understanding the risks, threats and impacts that surround these key activities will enable **ABC** to quantify and qualify the risk to the business and therefore take appropriate action to protect and recover the required operations. Once this exercise has been conducted, the EMT/BCM Steering Committee will be better placed to form a view or setting of their ‘risk appetite’, which defines the level of risk that it is willing to accept. Other key outcomes from conducting the Business Impact Analysis include: Financial and non-Financial impacts, (Tangible and Intangible) A minimum level of resources required, phased over time, such as personnel, IT Applications, Systems, Data and Vital Records. This will form the Resource Recovery Profile for the Strategy Development. A defined Recovery Profile built on verified and signed off RTO’s and RPO’s. Any additional constraints, such as legal, contractual and regulatory. 3.4 Risk Assessment & Risk Register Reducing risk is a key activity for the business. Not only does it enable us to understand the potential likelihood (frequency and probability) of something affecting us, but it also assists the business in developing its risk appetite. The purpose of the risk assessment and register is to effectively identify, define and evaluate the risks potentially faced by the Business Critical Activities and to put in place a set of controls or countermeasures to manage or reduce the risk. Key outcomes include: Page 10 of 21 Vulnerability and exposure or likelihood of occurrence to **ABC** from a specific type of incident Risk concentration – where a number of risks are located within the same function, activity or building Overall risk appetite view of BIA information and the associated risks Prioritised list of risks and their controls, which may be put forward to the existing risk register for monitoring and review Page 11 of 21 4 DETERMINING BCM STRATEGIES Business continuity strategy models involve the identification and selection of alternative methods of operating the primary ‘Business Critical Activities’ following an incident, to the minimum acceptable level required. There are a number of generic strategies to mitigate the impact of a disruption or reduce the probability of a threat event. Each strategy has parameters of speed of resumption, reliability of availability and cost which will be appropriate to different parts of the business so an organisation may require several elements to form an appropriate solution, depending upon the individual business functions. 4.3 BCM Strategy Models There are four basic strategic BCM Models to bear in mind; 1. Active/back up model – this involves having an ‘active’ backup site for the rapid resumption of the Business Critical Activities (BCA). This relies on the relocation of staff from the active site to the backup location with access to IT. 2. Active/active (split operations) – This model relies upon two or more geographically split ‘active’ operational or production sites for BCA. There is likely to be reciprocal backup and work/load balancing between sites. 3. Alternative site model – The use of an ‘active’ operating or production site with a corresponding backup site that occasionally functions as the primary site 4. Contingency Model – alternative ways of delivering services to cater for the loss of normal operational processes and components, such as a the loss of a critical IT system which requires the use of manual processing or workarounds 4.3.1 Functional relocation measures A ‘do nothing’ strategy may be acceptable for certain non-urgent functions identified in the BIA. Purchasing buildings and installing utilities may take several months Budge up makes use of existing in-organisation accommodation such as a training facility or canteen to provide recovery space or increasing the office density. This will require careful planning and some technical preparation. Displacement involves the displacing staff performing less urgent business processes with staff performing a higher priority activity. Care must be taken when using this option that backlogs of the less urgent work suspended do not become unmanageable. Remote Working includes the concept of “working from home” and working from other non-corporate locations e.g. hotels (Internet Cafes should not be Page 12 of 21 considered). Working from home can be a very effective solution but care must be taken to ensure Health and Safety issues are addressed and sufficient bandwidth capacity is available. Third party alternative site arrangements from a commercial or service organisation, (Easy Continuity Ltd), or **Location1** may be an option for consideration if these can ensure the organisation’s recovery time objectives (RTO) are achieved. o Dedicated space (Work Area Recovery) provides guaranteed and immediate availability but is more expensive than syndicated space. o Syndicated space (Work Area Recovery) usually provides access within 4 hours and enables ‘warm to hot’ recovery of key functions, telephony and back office in order to continue supporting the business ‘Ship in’ Contracts includes generators, IT equipment such as PCs, servers and printers and specialist hardware and equipment such as telephony systems. This may be an appropriate strategy if an unprepared building is to be equipped to provide an appropriate working environment. Most ship-in contracts permit the delivery location to be nominated at invocation, allowing a more flexible response to a specific incident compared to a fixed site recovery capability. Contract terms vary from ‘best efforts’ to guaranteed delivery. Insurance; combined with other BCM measures would provide a potentially good level of ‘risk portfolio’ protection for the business 4.4 Process Level BCM Strategies Process level strategies should be developed for every mission or Business Critical Activity (BCA) that has been identified in order to provide a clear view on how **ABC** will provide protection for its most critical activities. Once defined, this will enable the development of an organisation Resource Recovery Strategy so that a complete BCM capability exists for that activity. Outcomes for process level strategies include; An effective BCP for each critical activity, location or directorate. Any principles relating to the development of the strategy for the activity, including the level of risk or appetite that is acceptable Any linkages to the Incident Management and response team Page 13 of 21 4.5 Resource Recovery BCM Strategies A resource recovery strategy involves the deployment of appropriate resources as part of the continuity planning, in other words, what the requirements of the business are as defined in the BC plans. For example, if Work Area Recovery (WAR) is necessary, then the strategy should evaluate the specific requirements for syndicated work area, location and syndication ratios. Therefore the overall purpose of the resource recovery strategy is to provide a predetermined level of resources available to the business to enable the successful recovery of the process level strategies and options. Outcomes for resource recovery level strategies include; The identification of effective and fit for purpose solutions to enable the restoration of business critical activities A clear framework of the time criticalities or specified timeframes, resources and actions to achieve prioritised recovery of activities, their dependencies and single points of failure Page 14 of 21 5 DEVELOPING & IMPLEMENTING BCM RESPONSE PLANS 5.3 Business Continuity Plans Each plan owner, leader or co-ordinator is responsible for the development of their own plan or component part thereof, in order to cover their department, key functions, processes and activities. To assist in this development, there are two key resources available for guidance; Business Continuity Plan Template - This template will provide the basis and initial high level headings that should be included; such as o Plan Administration (title, purpose, role, scope, objective, version, owner) o Introduction (Overview, Purpose, Objectives, Assumptions) o Initial Response and Assembly Tasks, Ongoing Activities. o Critical Activities and IT Needs (RTO’s & RPO’s) o Resource Requirements & Strategies o Procedures and Tasks o Appendices Reference (Team Contact Details, Overall Structure, logs, pro formas,) Plan Development Guidance – Provided in conjunction with the template, this guidance aims to reinforce the necessary actions required at the plan development stage. The plan should not contain unnecessary information which is likely to distract away from the primary objective which is to aid the recovery of the relevant business area The business continuity plan is only as good as the team around it and the information within it; therefore it is paramount that any solutions, strategies, procedures etc are fully implemented and operational. Page 15 of 21 5.4 Incident Response & Management Planning A clear, strong Incident Management Response, team and plan is vital capability for **ABC**. The ability to co-ordinate, command and communicate is paramount if the business is to minimise impact and initiate an effective recovery. Failure to develop and maintain a Incident capability could lead to significant exposure to **ABC** brand and reputation. Outcomes for the Incident Management Planning include: A fit for purpose framework which interacts and compliments the Business Continuity (Tactical) response. Clear and defined ownership for Incident Management An established Incident Response Team An effective and rehearsed Incident Response plan Clear, defined and fit for purpose response procedures and tasks, including emergency evacuation, emergency services liaison, and internal and external communication strategies. Page 16 of 21 6 EMBEDDING BCM IN THE CULTURE 6.3 Awareness, Training and Culture Creating a BCM culture can be a challenging exercise, however, embedding such a process and ensuring the success of BCM will be enhanced with the following; Visible support from the Executive Management & Board o Making our BCM Policy known to all in the business BCM becoming part of **ABC** strategic and day to day thinking o Effecting changes in our thinking where required e.g. business change and new projects which require resilience or contingency as part of the business case and project delivery o Conducting regular exercises and training across Incident Response, Business Continuity and IT Continuity or Disaster Recovery. Appropriateness levels of ownership, responsibility and accountability o Building BCM into the role of each employee within the organisation that has a particular focus regarding overall risk approach and capability o Recognising and developing performance or appraisal systems to acknowledge contribution towards BCM responsibilities Using appropriate methods of culture delivery o Intranet site development including a policy statement o Downloadable pdf & overview presentation o Briefing content for new employees in key areas, with defined BC responsibilities o BCM awareness aide-memoires; e.g. trifolds, wallet cards, Page 17 of 21 7 EXERCISING, MAINTENANCE & REVIEW 7.3 Exercising Continued exercising and evaluation will ensure that **ABC** continue to have a fit for purpose Business Continuity capability. The following table illustrates the various types, methods and approaches available depending on frequency and level of complexity. Type Desktop Techniques Audit Process Review and challenge the contents of the plan Validation Who Plan Author Frequency Complexity High Low Low High Independent Reviewer Verification Walkthrough Plan and or Infrastructure Scenario Simulation Controlled Free play Extended to desktop to check interaction and roles of participants Plan Author Incorporates Associated Plans Main Participants Time lapse Facilitator o Business o Site/Buildings o Communication o Public Relations o ITDR o BCM Resource Recovery Suppliers (WAR) Unannounced Observers Live Coordinators Tabletop Individual Components Integrated Components Functions Main participants Umpires Move to and recreates one or a number of business functions at an alternative pre-planned site Employees and staff in specific business areas Facilitator Observers Coordinators BC Providers Full Plan Close down of building and relocation of work Page 18 of 21 As above 7.3.1 Schedule Below is an outline exercising schedule based on suggested best practice, however, each business function or directorate should agree it’s own exercising schedule and scope with the business continuity manager or body responsible for programme oversight. Area Who Desktop/Walkthrough Plan Author Business Continuity Plan Review Independent Reviewer Non-Critical Business Areas (Non-BCA’s) Plan Team Frequency Monthly/Quarterly These tests can be conducted ad hoc and require very little preparation. These tests can also be passed around the team as a means of reducing complacency. Bi Annual/Annually Whilst Non-BCA’s are unlikely to change significantly in terms of their plans, requirements and strategies, they should still be tested to the minimum required level Bi-Annually Due to their very nature and potential business impact, BCA’s should be tested more regularly than Non-BCA’s. Those which are subject to continual or more frequent change may require testing on a more regular quarterly basis. Bi Annually As new technologies or recovery providers are brought online or operational, a test of the capability should also take place. Bi Annually The Incident Response Team needs to maintain a high level of preparedness in the event of an incident or Incident. Min. Annually This exercise should be conducted at least annually Due to the time and resource investment in organising an exercise of this type, All interacting elements Business Critical Areas (BCA) Plan Team All Interacting elements Technology/DR Technical Teams Selected Business Users Incident Response Team (IRT) Incident Team Scenario dependent ‘guests’ Full Scale Test (one or more sites) Incident Team All Recovery & Business Continuity Teams All recovery strategy providers Notes & Page 19 of 21 7.3.2 Scenario Based Event Profiles Scenario based event profiles can be used for generating specific responses to particular events or scenarios, for an additional level of preparedness over a standard response set. Understanding these events, scenarios and profiles may also benefit the production of more meaningful exercises, which can be targeted. Area Who Functions – standalone, inward facing, isolated Process – straddles functions, higher degree of organisation Activities, Contact Centre etc Facilities Fire **Location1** (Head Office) Flood Bomb Alert Power Loss Denial of Access (Temporary/Prolonged) Recovery Strategies, Backups & Restore, Testing Days, Backup and Restore testing Major component failure (Single Points of Failure) Business & Strategic Technical Recovery Solution People o IT o Telecoms Work area recovery - 3rd Party (As provided by Easy Continuity) Remote/Home Flu Pandemic Fuel Incident – Shortage Strike/Industrial Action/Walkout Page 20 of 21 7.4 Maintenance 7.4.1 Plan Maintenance – Guidance A plan maintenance checklist is available (as additional guidance to this document) to assist plan owners and developers and potentially internal auditors with the task of regular and consistent Business Continuity Plan maintenance. Each phase of maintenance should consider a variety of possible changes which may affect the plan, its accuracy or validity. These have been listed as ‘Administration’, ‘Minor’ and ‘Major’ tasks within the guidance so as to provide an indication of their importance. One checklist should be completed per plan per review and should be centrally maintained within a register of BC plans where a change copy is retained. The **ABC** standard should be that all plans without exception must be reviewed at least every 12 months as a minimum for completeness and accuracy. Business critical functions should consider every 6 months as a minimum. 7.5 Audit & Review The BCM Audit process ensures that the **ABC** capability is fit for purpose and has been maintained and adapted appropriately. The primary role of the audit function is to; Verify compliance with **ABC**’s policies, strategies and overall framework including any additional guidelines or standards which have been published To review any Incident or Business Continuity plans To review any solutions To ensure all ongoing tasks such as exercising, testing, awareness and maintenance are being conducted as per the schedule To highlight any shortfalls in the programme and ensure these are risk managed, and resolved. The organisation policy needs to be determined regarding the frequency of an audit. The minimum requirement would be to conduct a review at least every year, preferably in advance and to allow remediation before other audits. Equally, there are other trigger events, such as a major business change or new business development, which would initiative a formal review or audit. 7.5.1 Audit Guidance Overview The business continuity programme is tested and reviewed by internal audit as part of the outsourced audit programme. The results are subsequently reported to the EMT and the audit risk committee in line with the governance framework. Page 21 of 21