Business Continuity Program 11/30/2012 Table of Contents I. Executive Summary ............................................................................................................................... 5 II. Introduction .......................................................................................................................................... 5 III. Purpose and Assumptions ................................................................................................................ 6 1. Purpose ............................................................................................................................................. 6 2. Assumptions ...................................................................................................................................... 6 IV. Applicability and Scope ..................................................................................................................... 7 1. Applicability....................................................................................................................................... 7 2. Scope ................................................................................................................................................. 7 V. Essential Functions................................................................................................................................ 8 1. Risk Assessment ................................................................................................................................ 8 2. Business Impact Analysis .................................................................................................................. 8 3. Resource Requirements .................................................................................................................... 8 4. Function Dependencies..................................................................................................................... 9 VI. Authorities and References: (Annex A) ............................................................................................. 9 VII. Concept of Operations ...................................................................................................................... 9 1. Activation and Relocation ................................................................................................................. 9 2. Alternate Facility Operations and Recovery Strategies .................................................................. 10 3. Reconstruction & Resumption Strategies ....................................................................................... 10 VIII. COOP Planning Responsibilities ...................................................................................................... 11 IX. Logistics ........................................................................................................................................... 11 X. 1. BCP Contents................................................................................................................................... 11 2. BCP Management ........................................................................................................................... 12 1. Testing Plans ............................................................................................................................... 12 2. Plan Maintenance ....................................................................................................................... 12 3. Communication ........................................................................................................................... 12 4. Training ....................................................................................................................................... 12 5. Record Retention ........................................................................................................................ 13 Test, Training and Exercises ................................................................................................................ 13 1. Testing and Exercises .................................................................................................................. 13 2. Training ....................................................................................................................................... 13 3|P a g e XI. Multi-year Strategy Program Management Plan ............................................................................ 13 Annex A: Authorities and References ......................................................................................................... 14 Federal: ............................................................................................................................................... 14 CSU: ..................................................................................................................................................... 14 Cal Poly: ............................................................................................................................................... 14 Associated Business Continuity Planning Documents: ....................................................................... 14 Annex B: Business Continuity Acronyms..................................................................................................... 15 Revisions 11/06/12 11/30/12 : Troy Weipert Troy Weipert Action: First Draft Finalized Plan Signature _________________________________________ Cal Poly Business Continuity Planning Committee Chair ____________ Date 4|P a g e I. Executive Summary In accordance with EO 1014, Cal Poly must maintain an ongoing program that ensures the continuity of essential functions and operations following a catastrophic event. This program follows the Federal Emergency Management Agency’s (FEMA) Continuity of Operations Plan (COOP) template. To facilitate oversight of the business continuity program, the president designated a Business Continuity Planning Committee with responsibility for business continuity planning activities. The Cal Poly Business Continuity Planning Committee (BCPC) includes a cross-section of senior administrative leaders who have a working knowledge of business continuity processes and are from business units identified as critical to essential operations. The Business Continuity Committee is responsible for the central review of all Business Continuity plans in conjunction with each department. A standard template is used for the consistent development of the University’s Business Continuity Plans. The template is used to document key information (i.e., staff contact information, critical functions, critical function recovery procedures, vital records, assets) within a department in order to ensure the campus’ ability to recover from a catastrophic event. Each Vice President has the responsibility for the development, testing and maintenance of the Business Continuity plans within their division. The BCPC is assigned to provide training to each division for plan creation and to review the plans on an annual basis. Emergency activities of departments, including requests for resources or services and documentation of financial impact, are coordinated through the Emergency Operations Center (EOC) and are in compliance with the Campus Emergency Management Plan. The Departmental Business Continuity Plans (BCP), Department Emergency Plans, and the Campus Emergency Management Plan are interrelated and together provide for preparation, response and recovery to a campus emergency. II. Introduction The Business Continuity Program provides management framework for resuming critical functions and operations after a disaster or emergency that may threaten the health and safety of the campus community and/or disrupt its essential programs and operations. It is an ongoing program designed to effectively coordinate the use of University resources immediately following a major disaster, in order to restore essential operations. This differs from the Campus Emergency Plan which provides emergency response in order to protect life, safety and campus facilities. The BCPs ensure the continuance of critical campus functions, systems, and services when a disruption to campus operations occurs after a disaster or emergency situation. The BCP also endeavor to identify and mitigate risks in advance through Risk and Business Impact planning. The BCP is activated whenever an emergency affecting the campus cannot be managed through normal channels. Examples of the types of emergencies where plans may be activated include: 5|P a g e a. b. c. d. e. f. Earthquakes Hazardous materials releases Floods Fires and explosions Extended power outages or systems failure Pandemic Flu The CPBCP outlines the overall University Continuity direction, provides a framework for ongoing preparation, and contains detailed planning and analysis to assure campus readiness for any eventuality. III. Purpose and Assumptions 1. Purpose The CPBCP has been structured so that it is consistent with the Continuity of Operations (COOP) template developed by the Federal Emergency Management Agency (FEMA). It also follows the Continuity Guidance Circular 1 from FEMA for more detailed planning. The program is designed to address continuance of Mission Essential Functions (MEF) for Cal Poly University. These include providing life and safety for all campus constituents (Faculty, Staff and Students) while also continuing to support the University mission of student success through balanced education in a Learn by Doing environment. Although there may be other important functions, the plan only covers those that are mission and time critical. An essential or critical function is defined in the Federal Preparedness Circular 65 as a function that enables an organization to: a. b. c. d. Provide vital or “mission critical” services; Exercise civil authority; Maintain the safety of the general public; or Sustain the industrial or economic base during an emergency. Critical functions shall use priority classifications that are based on recovery time objectives (time in which this function must be resumed). BCP shall use the priority categories listed below, along with a brief description of that function, and the position that has lead responsibility. a. b. c. d. Priority 1 - Critical: first 24 hours Priority 2 –Essential: 72 hours Priority 3 – 4-15 days Priority 4 – All other functions 2. Assumptions 6|P a g e The CPBCP is based on a set of assumptions that, if not true, will render the plan ineffective. For Cal Poly, requirements include: Adequate staff to carry out operations Access to campus within 30 days Essential utilities are functional Available student housing is available within commuting range Essential City of San Luis Obispo resources are intact Identified remote facilities are available If any of these assumptions are not met, the CPBCP may not have adequate resources to address and restore the MEF of the University. IV. Applicability and Scope 1. Applicability The CPBCP is designed to operate in conjunction with other campus plans as necessary. These include the Emergency Management Plan (EOP) and unit Business Continuity Plans (BCP.) These plans are interrelated but serve different functions. The EMP is activated at the point of emergency and is designed to provide command communication to the campus and ensure that health, safety and campus integrity are maintained directly after an initiating emergency. If that emergency is great enough to cause interruptions of significance to campus operations, the CPBCP will be activated to bring those operations back on line. This is accomplished by each affected unit activating their individual BCP. There is also the possibility that there is an outage to MEF that was not sufficient to activate the EOP. In this case, the CPBCP and affected BCP will be activated to address the impacts. 2. Scope The scope of the CPBCP strives to map out how to restore MEF with limited equipment and manpower. The program addresses overall campus requirements, risks and impacts. Bringing individual department’s operations on-line are defined within each business unit’s BCP. The CPBCP attempts to address all campus services (utility, IT, communications) that each business unit will rely on while attempting to restore operations after an event causing the initiation of their individual plans. Prioritization of service restoral to each area (in order of importance) is contained within the unit BCP plans that provide those core campus services. The scope is also designed to address interruption to MEFs based on types of outages. Broadly, outage types are for building outages and campus-wide outages for periods up to 30 days. 7|P a g e V. Essential Functions The CPBCP is designed to identify and address all high level campus MEF. Business units will have operations that are necessary to maintain campus functions. Each business unit shall identify and list their critical operations in their BCP, along with a brief description of that operation, and the position within the organization that has lead responsibility for it. The list should be based on the prioritization strategies introduced in Section III: Purpose. 1. Risk Assessment The Risk Assessment (RA) identifies possible risks or hazards that may threaten the continuance of essential functions. The purpose of the risk analysis is to develop a list of hazards that are of such significance that they are reasonably likely to cause devastating harm to the agency if they are not effectively controlled. The objective of this analysis is to identify vulnerabilities in operations and take steps to mitigate losses and/or develop recovery strategies. In completing the Cal Poly RA, the following objectives were followed. a. List all the threats that may potentially have an impact on the organization's ability to deliver its essential functions. b. Assess the impact of the risk based on the severity of the impact of the threat and the probability of occurrence. c. Assess whether the organization has implemented effective control measure or other procedures that mitigate the occurrence of loss or damage resulting from this event. d. Determine if the likelihood or occurrence of this threat is substantial enough to be included in the organization's Business Continuity Plan. The RA is reviewed and approved annually by the BCPC and is managed and retained following the standards per EO1014. 2. Business Impact Analysis The Business Impact Analysis (BIA) identifies essential functions and workflow; determines the qualitative and quantitative impacts of a vulnerability/threat to essential functions, prioritizes/establishes recovery time objectives for the essential functions, and where appropriate, establishes recovery point objectives for essential functions. The RA is reviewed and approved annually by the BCPC and is managed and retained following the standards per EO1014. 3. Resource Requirements Each business unit identifies the minimum resource requirements needed to support each essential function in their BCP. After these resources have been identified, the business units are responsible for ensuring that the resources are protected at all times. For those resources that cannot be adequately safeguarded, the business unit must select alternate or back-up resources in order to ensure that essential functions are available at all times. These resources may include: 8|P a g e a. b. c. d. e. f. g. Facilities or work-sites Communication systems Key personnel Vital records and databases Vital systems and equipment and utility systems Key vendors Contact information for supporting government agencies or departments 4. Function Dependencies Many of the business units’ essential functions rely on the availability of resources or functions controlled by another organization, including other campus business units, outside agencies including federal, state and/or local governments, and private entities. Business units should identify these dependencies and link them to the essential function(s) they support when completing the BCP. The CPBCP will help address inconsistencies to assure inter-campus services are restored to individual units based on importance. As noted, these requirements will be reflected in both the dependent and supporting department’s BCP. VI. Authorities and References: (Annex A) The CPBCP has been authored and updated based on Federal, CSU, and Cal Poly documents and standards. These are listed in Annex A for reference. VII. Continuity of Operations Business units should develop an executive decision process that would allow for a review of the nature and extent of the emergency to determine the best course of action for response and recovery. This process will preclude premature or inappropriate activation of a business unit’s BCP. 1. Activation and Relocation Business Continuity Plans should include activation procedures and relocation procedures from the primary facility to the alternate facility. This section should also address procedures and guidance for non-relocating personnel. a. Decision Process: Explains the incident escalation process; who will activate the plan and under what circumstances will the plan be initiated? The roles and responsibilities of key personnel should be included. b. Alert Notification and Implementation Process: Includes employee alert and notification procedures, and the BCP implementation process. List tools to be used for the alert and notification process. c. Leadership: Identifies lines of succession (LOS) to key positions within the business unit. The LOS should be of sufficient depth to ensure the business unit’s ability to manage and direct its essential functions and operations. The conditions under which succession will take place, the 9|P a g e method of notification, and any temporal, geographical, or organizational limitations of authority should also be identified in this section. d. Relocation: includes procedures for relocating essential functions, including required resources, to an alternate facility. This section should also include procedures for dealing with personnel who are not to be relocated to the alternate facility. If an organization has existing emergency relocation plans, they may be incorporated by reference. 2. Alternate Facility Operations and Recovery Strategies Business Continuity Plans should identify initial arrival procedures, as well as operational procedures, for the continuation of essential functions at an alternative facility. Steps may include: a. Identifying alternate locations/ facilities capable of supporting essential operations, positions, and personnel is critical. These facilities must be capable of supporting operations in a threatfree environment, as determined by the geographical location of the facility and the collective protective characteristics of the facility. b. Documenting mission critical systems and equipment necessary to perform essential functions and activities. Business units must define these systems and equipment and address the method of transferring/replicating them at an alternate site. c. Identify vital files, records, and databases, including classified or sensitive data, which are necessary to perform essential functions and activities, and to reconstruct normal operations after the emergency ceases. d. Identifying the critical communication systems necessary to perform essential functions and activities. Business units must define these systems and address the method of transferring/replicating them at an alternate site. Examples of such equipment include the following: i. Mobile phones ii. Two-way radios iii. Internet connections iv. Facsimile e. Documenting existing procedures that are in place to protect an organization’s resources, with an emphasis on personnel. This section should specify the resources and personnel to be transferred to the alternate site and the methods for safely transporting them to the site. f. Identifying required vendor support at alternate sites. 3. Reconstruction & Resumption Strategies Business Continuity Plans should explain the procedures for resuming normal operations – a time phased approach may be most appropriate. This section may include procedures for returning to the primary facility, if available, or procedures for acquiring a new facility. Notification procedures for all employees returning to work must also be addressed. Business units should also anticipate developing an After Action Report (AAR) to determine the effectiveness of their BCP. Depending on the nature of the event causing the disruption, procedures for returning to primary facilities may be included in the campus emergency plan. 10 | P a g e VIII. COOP Planning Responsibilities Primary responsibility for COOP falls to the BCPC per Executive order 1014. The committee membership is reviewed annually and maintained in the Business Continuity Planning Committee reference. Additional responsibility is held by each department required to create and maintain a BCP. These departments are listed in the BCP Required Departments reference. Each division on campus also reports Business Continuity Planning activities via the annual IT Self-Assessment. IX. Logistics The core of logistical planning is contained in each unit’s Business Continuity Plan (BCP.) As noted, each business unit that is determined by the university to provide essential functions shall develop, document, test, and maintain a Business Continuity Plan (BCP). The plan will ensure the continuance of critical campus functions, systems, and services when a disruption to campus operations occurs after a disaster or emergency situation for that unit. 1. BCP Contents The Cal Poly Business Continuity template should be used for the consistent development of the University’s BCP. The template will be used to document key information (i.e., staff contact information, critical functions, critical function recovery procedures, vital records, assets) within a department in order to ensure the campus’ ability to recover from a disruption. Elements of the BCP should include, but are not limited to: I. II. III. IV. V. VI. Listing and prioritization of essential functions, including the identification of staffing and resource requirements, mission critical systems and equipment, and support activities for each essential function. Lines of Succession/Delegation of Authority for key campus positions, including guidance for the delegation of emergency authorities. I. Organizational charts or similar documentation. II. Documented delegation of authority (DOA) for decision making as needed. Alternate Operating Facilities, including provisions to sustain operations for a period of up to thirty days (or other time frame as determined by the campus) Communications, including procedures and plans for communicating with internal personnel, other agencies, and emergency personnel. Protection and safeguarding of vital records and databases. Tests, Training, and Exercises to familiarize staff members with their roles and responsibilities during an emergency, ensure that systems and equipment are maintained in a constant state of readiness, and validate certain aspects of the Business Continuity Plan. The Business Continuity plan contains confidential information that should not be shared publicly. It is the responsibility of each department to ensure that the plan be held, developed, and reviewed by 11 | P a g e designated individuals only. Business Continuity Plans shall be approved/signed-off by the head of the business unit and the BCPC annually and retained as indicated in Record Retention Section. 2. BCP Management Business Continuity Plans must be managed consistently in order to assure accuracy and compliance. 1. Testing Plans Business units shall test some part of their Business Continuity Plan once a year, with all parts tested every seven years. An actual event necessitating activation of the Business Continuity Plan will meet this requirement. At the completion of each test or review, full documentation of test results and lessons learned shall be recorded in the “testing section” of the BCP. Approval of the testing phase will be included with the BCP approval/sign-off process. Upon request, such documentation shall also be made available to the System wide Office of Risk Management. 2. Plan Maintenance Business units shall review their Business Continuity Plan and tests at least annually or more frequently as needed and update the plans whenever changes occur in their operating procedures, processes, or key personnel. Plans must be updated to maintain accurate lists of key personnel, telephone numbers, and plan elements that may be affected by changes in unit structure or functions. The updated Business Continuity Plans shall be approved/signed-off by the head of the business unit and the Business Continuity Planning Committee and following the standards per EO1014 3. Communication Ongoing communications of business continuity activities to the campus community will be provided by: a. b. c. d. e. Email correspondence to committee members Committee meetings to meet at least twice annually Plan testing should include staff members of each business unit; required annually Notifications issued by the EOC Business Continuity Website The full BC communication plan is outlined in the CP Business Continuity Communication Plan reference. 4. Training Initial training on conducting business continuity planning shall be provided to all individuals responsible for developing and implementing plans. Additional and/or repeat training shall be provided as determined necessary by the Business Continuity Planning Committee following the review of written plans and plan testing. Each business unit shall provide training to all personnel involved in the execution of their BCP during plan testing. 12 | P a g e 5. Record Retention Campus shall retain business continuity records, including BCP, RA and BIA documentation, for a period of not less than five years. X. Test, Training and Exercises 1. Testing and Exercises Testing and exercise Plans (TEP) are a critical part of effective Business Continuity planning. Regular tests are required to assure business unit plan’s effectiveness in the case of an outage. Due to the amount of change in environments, technology, staff and procedures, testing the procedures is essential to assure plans are kept up to date with relevant information and processes. Assumptions of plans should be tested to assure that all of the steps of the plan are valid. In testing, it is also necessary to inform other groups and/or agencies if the plans require their services for completion. Per BCP maintenance, portions of plans are to be tested by each business unit once a year with a full test at least every 7 years. Yearly testing could be physical or paper tests of the procedures. Testing response is recorded in two areas. As noted, the testing results are placed on the annual submission of the BCP to the BCPC for approval. Additionally, units will fill out a corrective action plan (CAP), and participants are encouraged to complete Participant Evaluation Surveys (PES) in order to provide accurate feedback on the plan’s effectiveness. 2. Training Training is also critical to Business Continuity as part of the planning process and in the case of an event. Training is provided to business units by the BCPC to assure that each unit completes their plans, testing, and departmental training effectively. This is covered in the Business Continuity Training plan BCTP. Training is also provided by business units to all of their employees who are essential to the planning and enactment of BCP. This training can be provided by classes, on-line or as part of each unit’s TEP. XI. Multi-year Strategy Program Management Plan In order to provide consistency, relevance and compliance, all Business Continuity activities are to be reviewed and approved as part of a Multi-year Strategy Program Management Plan (MYSPMP.) The MYSPMP defines the schedule for review and ongoing maintenance of Business Continuity planning, testing, documentation, strategy, and leadership for Cal Poly. The goal is to improve processes, plans and awareness as an ongoing basis to assure campus is in the best possible position in the event of an emergency. 13 | P a g e Annex A: Authorities and References Federal: Continuity of Operations (COOP) Plan Template, FEMA: http://www.fema.gov/doc/about/org/ncp/coop_plan_template.rtf Continuity of Operations (COOP), FEMA: http://www.fema.gov/pdf/about/org/ncp/coop_multi_year_plan_guide.pdf Continuity Guidance Circular 1 (CGC 1), FEMA: http://www.fema.gov/pdf/about/org/ncp/cont_guidance1.pdf CSU: CSU Executive Order 1014: http://www.calstate.edu/EO/EO-1014.html Cal Poly: Campus Emergency Management: http://www.afd.calpoly.edu/ehs/emergency.asp Campus Emergency Management Plan: http://www.afd.calpoly.edu/ehs/docs/emergencyplan.pdf Information Security Self-Assessment: http://www.security.calpoly.edu/content/policies/standards/risk/index Associated Business Continuity Planning Documents: BC Planning Committee BCP Required departments Business Continuity Plan Template Business Continuity Risk Assessment Business Impact Analysis Corrective Action Plan Participant Evaluation Survey Business Continuity Communications Plan Business Continuity Training Plan (TBD) Multi-year Strategy Program Management Plan (TBD) 14 | P a g e Annex B: Business Continuity Acronyms AA AFD BC BCP BCPC BCTP BIA BU CAP COG COOP CP CPBCP CSU DOA DRP EO1014 EOC EMP FEMA IT ITS LOS MEF MOA MOU MYSPMP ORP PES RA SLO TEP Academic Affairs Administration and Finance Division Business Continuity Business Continuity Plan Business Continuity Planning Committee Business Continuity Training Plan Business Impact Analysis Business Unit Corrective Action Plan Continuity of Government Continuity of Operations Cal Poly Cal Poly Business Continuity Program California State University Delegations of Authority Disaster Recovery Plan CSU Executive Order 1014 Emergency Operations Center Emergency Management Plan Federal Emergency Management Agency Information Technology Information Technology Services Lines of Succession Mission Essential Function Memorandum of Agreement Memorandum of Understanding Multi-year Strategy Program Management Plan Operation Recovery Plan Participant Evaluation Survey Risk Assessment San Luis Obispo Testing and Exercise Plan 15 | P a g e