Elements of an FFIEC Compliant BCP Plan

Transcription

1 Elements of an FFIEC Compliant BCP Plan Presented by: Joseph Compton CISSP, CISA Merri Voigt CRCM, CCBCO

2

3 Planning Stage Appoint a Project Manager Divide Responsibilities Define Objectives and Deliverables Identify Required Documentation

4 The Project Manager leads the BCP Project. The following information pertains to the current Project Manager. Business Continuity Plan Project Manager Name: Date appointed as Project Manager: Full-time or Part-time position: Position held if Part-time Project Manager: Project Manager reports to: Contact information: Emergency contact information:

5 CONTENT BCP Policy BCP Budget Overall Plan Content Correctness of Information Accuracy of Contract Details Insurance Adequacy Risk Impact Analysis Business Risk Assessment IT Strategy IT Recovery and Back-up Budget Business Recovery Strategy Approving Disaster Status BCP Testing Procedures BCP Training Process BCP Maintenance and Updating BOARD* MANAGEMENT* (SPECIFY NAME)

6 Objectives: Main Objective: To develop and test a well-structured and coherent plan which will enable the institution to recover as quickly and effectively as possible from an unforeseen disaster or emergency which interrupts normal business operations. Secondary Objectives: Ensure that all employees fully understand their duties in implementing a plan Ensure that information security policies are adhered to within all planned activities Ensure that the proposed contingency arrangements are cost effective Deliverables: Business Impact Analysis and Risk Assessment Documented activities necessary to prepare the institution for possible emergencies (including strategic recovery measures) Detailed activities for dealing with the Disaster Recovery Phase Procedure for managing the Business Recovery Process Plan for testing the Business Recovery Process Plan for training the staff in the Business Recovery Process Procedure for keeping the Plan up to date

7 DESCRIPTION OF DOCUMENT/INFORMATION DOCUMENT LOCATION Organization chart showing names and positions Staff emergency contact information List of suppliers and contact numbers BCP List of professional advisers and emergency contact information BCP List of emergency services and contact numbers BCP Premises addresses and maps IT system specification Communication system specification Copies of maintenance agreements/service level agreements Existing evacuation procedures and fire regulations Health and Safety procedures Operations and Administrative procedures Personnel administrative procedures Copies of floor plans Asset inventories IT inventories Off-site storage procedures Relevant industry regulations and guidelines Insurance information

8 Risk Assessment Stage Threat Assessments Impact Analysis

9 Environmental Disasters POTENTIAL DISASTER PROBABILITY RATING IMPACT RATING BRIEF DESCRIPTION OF POTENTIAL CONSEQUENCES (SEE TABLE BELOW) (SEE TABLE BELOW) Tornado 4 4 They can cause significant structural damage and can also cause severe injuries and death Flood 4 4 Floods can seriously affect buildings and equipment causing power failures and loss of facilities and can even result in injury or death Snowstorm/Ice 3 4 Snow and ice can impact power and communications and employees may be unable to travel to work due to the impact on public transport or road conditions. It is possible for buildings to collapse under the weight of snow and injuries or even death could occur through freezing temperatures and icy conditions. Earthquake 5 4 Severe earthquakes can destroy power and communication lines and disrupt gas, water and sewerage services. Significant damage to structures can occur including total collapse of buildings, bridges or other elevated structures. In addition to being trapped in a collapsing building, of particular danger to human life is the possibility of falling glass or other objects. Electrical Storms 4 4 It can cause disruption to power and can also cause fires. It may also damage electrical equipment including computer systems. Structural damage is also possible through falling trees or other objects. Fire 4 4 A fire can cause human injury or death and damage can also be caused to records and equipment and the fabric or structure of premises. Contamination and Environmental Hazards 4 4 Polluted air, polluted water, chemicals, radiation, asbestos, smoke, dampness and mildew, toxic waste and oil pollution can disrupt business processes directly and, in addition, cause sickness among employees. This can result in prosecution or litigation if more permanent damage to employees health occurs. Epidemic 5 4 This can have a particularly devastating short-term impact on business through a large number of persons being absent from work at the same time. Certain illnesses can have a longer-term effect on the business where long term illness or death results.

10 PROBABILITY RATING IMPACT RATING SCORE LEVEL SCORE LEVEL 1 VERY HIGH 1 TERMINAL 2 HIGH 2 DEVASTATING 3 MEDIUM 3 CRITICAL 4 LOW 4 CONTROLLABLE 5 VERY LOW 5 IRRITATING

11 Loss of Drainage/Waste Removal 4 4 This is likely to impact on the business through the possible loss of its workforce during the period where drainage services are not available. This, in turn, will have an immediate impact on revenue. Loss of Utility Service POTENTIAL DISASTER PROBABILITY RATING IMPACT RATING BRIEF DESCRIPTION OF POTENTIAL CONSEQUENCES (SEE TABLE BELOW) (SEE TABLE BELOW) Electrical Power Failure 3 4 Data can be lost, customers can be lost and there can be a serious impact on revenue. Pre-planning is essential as a regional outage can cause a shortage of back up electrical generators. Consideration should be given to installing UPS systems to avoid brownouts. Loss of Gas Supply 4 4 The impact on the organization will also be particularly acute where the loss of gas-fired heating could render the premises unusable during periods of low external temperatures. Loss of Water Supply 4 4 The loss of water supply is also a health and safety issue as minimum sanitary needs cannot be met. Petroleum or Oil Shortage 3 4 This has a serious impact on businesses as rationing is likely to be imposed immediately affecting transportation and the normal operations of diesel or petrol fuelled machinery. Communications Services Breakdown 4 3 A disruption to the telecommunications services can result in the business losing revenue and customers. The use of cell-based telephones can help to alleviate this but the main reliance is likely to be on the land based lines.

12 Emergency Preparedness Backup and Recovery Strategies Organization of Personnel and Supplies

13 Business Recovery Phase Checklists for tracking recovery of: Utilities, Premisses Communications, IT Systems Customer Service and Sales, HR, Information and Documentation and Office Supplies

14 BCP Testing You Want Me to Do What?

15 TESTING GUIDELINES Who is going to be responsible for the testing; What is going to be tested; How is the testing going to be conducted; Document the results; Adjust the plan if necessary. Testing is to be conducted no less than annually, but more frequently if warranted.

16 TESTING METHODS Tabletop Exercise/Structured Walk-Through Test Attendance of employees who play a critical role in the BCP process; Discussion about each person s responsibilities as defined by the BCP; Individual and team training, which includes a walk-through of the step-by-step procedures outlined in the BCP; and Clarification and highlighting of critical plan elements, as well as problems noted during testing.

17 TESTING METHODS Walk-Through Drill/Simulation Test Attendance by all operational and support personnel who are responsible for implementing the BCP procedures; Practice and validation of specific functional response capabilities; Focus on the demonstration of knowledge and skills, as well as team interaction and decision-making capabilities; Role playing with simulated response at alternate sites to act out critical steps, recognize difficulties, and resolve problems in a nonthreatening environment; Mobilization of all or some of the crisis management/response team to practice proper coordination without performing actual recovery processing; and Varying degrees of actual, as opposed to simulated, notification and resource mobilization to reinforce the content and logic of the plan.

18 TESTING METHODS Functional Drill/Parallel Test A full test of the BCP, which involves all employees; Demonstration of emergency management capabilities of several groups practicing a series of interactive functions, such as direction, control, assessment, operations, and planning; Testing medical response and warning procedures; Actual or simulated response to alternate locations or facilities using actual communications capabilities; Mobilization of personnel and resources at varied geographical sites, including evacuation drills in which employees test the evacuation route and procedures for personnel accountability; and Varying degrees of actual, as opposed to simulated, notification and resource mobilization in which parallel processing is performed and transactions are compared to production results.

19 TESTING METHODS Full-Interruption/Full-Scale Test Enterprise-wide participation and interaction of internal and external management response teams with full involvement of external organizations; Validation of crisis response functions; Demonstration of knowledge and skills as well as management response and decision-making capability; On-the-scene execution of coordination and decision-making roles; Actual, as opposed to simulated, notifications, mobilization of resources, and communication of decisions; Activities conducted at actual response locations or facilities; Actual processing of data using back-up media; and Exercises generally extending over a longer period of time to allow issues to fully evolve as they would in a crisis and to allow realistic role-playing of all the involved groups.

20 SAMPLE TESTS 1.Q & A 2.Scenario Testing 3.Documentation of Testing Results