Citizens Property Insurance Corporation Business Continuity Framework

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1 Citizens Property Insurance Corporation Framework Dated September 2015 Approvals: Risk Committee: September 17, 2015 (via ) Adopted by the Audit Committee: Page 1 of 12

2 Table of Contents 1 INTRODUCTION PURPOSE AND SCOPE OF THIS FRAMEWORK WHAT IS BUSINESS CONTINUITY? BUSINESS CONTINUITY GUIDING PRINCIPLES RELATIONSHIP TO THE ENTERPRISE RISK MANAGEMENT PROGRAM BUSINESS CONTINUITY AT THE ORGANIZATIONAL LEVEL Dependencies for Success Program Deliverables RELATIONSHIP TO OTHER PROGRAMS BUSINESS CONTINUITY MANAGEMENT ROLES AND RESPONSIBILITIES NOTIFICATION AND ACTIVATION TRIGGER EXISTING BUSINESS CONTINUITY ARRANGEMENTS ALTERNATIVE SITE STRATEGY DETERMINATION OF CRITICAL FUNCTIONS TESTING AND MAINTENANCE OF BUSINESS CONTINUITY ARRANGEMENTS TESTING REVIEW AND MAINTENANCE Framework Business Impact Analysis Plans Audit TERMINOLOGY REFERENCES Page 2 of 12

3 1 Introduction 1.1 Purpose and Scope of this Framework This (BC) Framework is designed to assist management and staff of Citizens to conduct BC activities across the organization and to familiarize staff members where necessary. Citizens BC program is based on ISO and has been customized to Citizens needs. BC requires cross functional coordination to be successful, as working BC efforts in silos will delay efforts to recover operations in a timely manner. Consequently, this framework applies to all business units, operations, and functions regardless of the location in which they are located, and should be referenced by employees who are responsible for the establishment, implementation, or maintenance of the Citizens BC program. The information within this framework serves to provide guidance to Citizens leadership during an interruption to operations. This framework does not include specific requirements and strategies for critical functions; these are detailed in the specific business continuity plans of Citizens business units and can be found in Virtual Sustainable Planner. 1.2 What is? The objective of Citizens BC program is to promote the continuity and/or rapid recovery of critical services/functions required to support the core business of the organization, its policyholders, and other stakeholders. BC is a continuous process of establishing, maintaining, and enhancing Business Continuity Plans and related information needed, like Business Impact Analyses, in order to respond to and recover from disruptions that threaten key resources, locations and functions. This capability contributes to the Citizens emergency management process, which comprises four components: Emergency Response the immediate response to an event with a focus on ensuring the safety of people followed by the protection of assets; refer to the Safety Manual for details Communication fluid communication among leadership and decision makers regarding any event causing an interruption of operations and Disaster Recovery the process of restoring critical elements of Citizens processes and functions, and supporting technical infrastructure and systems, within the organization s core business units Page 3 of 12

4 Recovery the broad activities required to restart, rebuild and regenerate the affected capabilities, not just the restart of business operations. 1.3 Guiding Principles It is the intent of Citizens to: Maintain a strategy for reacting to, and recovering from, adverse situations which is in line with senior management s level of acceptable risk Maintain a program of activity which ensures the company has the ability to react appropriately to, and recover from, adverse situations in line with the business continuity objective Maintain appropriate response plans underpinned by a clear escalation process Exercise response and recovery plans at least annually Maintain a level of resilience to operational failure in line with the risk faced, the level of negative impact which could result from failure and senior management s level of acceptable risk Maintain employee awareness of the organization s expectations of them during an emergency or business continuity threatening situation Take account of changing business needs and ensure that the response plans and business continuity strategy are revised where necessary Remain aligned with best practice in BC 1.4 Relationship to the Enterprise Risk Management Program BC supports Citizens Enterprise Risk Management Program and provides a means of mitigating certain risks should they occur and impact a business unit or information technology systems. BC allows the organization s processes to recover from the incident in a planned manner. 1.5 at the Organizational Level Dependencies for Success The success of the BC program is dependent upon several things: Becoming an integral part of the organization s strategic and day to day management activities Developing and enhancing the skills, knowledge and experience required to implement, maintain, manage and execute BC Visible proactive support from Citizens executive leadership, as well as senior and middle management Ownership by business units across the organization of their Plans Commitment to maintain and review the BC program s framework, methodology, and deliverables on a regular basis Awareness and understanding by employees of the importance of BC and their roles, accountabilities, and responsibilities Job descriptions and associated skills that include BC at specified levels within Page 4 of 12

5 the organization Clearly defined and documented management information system to support the BC program Ongoing BC training for those directly involved in the implementation, maintenance, and execution of Citizens BC program Understanding of which Teams are dependent on one another for performance Program Deliverables A robust, mature BC program should produce the following deliverables: Business Impact Analysis Results Organizational level prioritization and strategy for recovery Application ratings and recovery times for Disaster Recovery planning Business unit/function level Plans, which should include: o Introduction (aim and scope) o Summary of critical functions including the maximum tolerable downtime for each function o Continuity arrangements for critical functions o Contact lists o Outline of testing/exercising/training/review guidelines Tabletop exercises with outcomes resulting in updates to Plans Training on BC program and processes to business unit owners and designated business continuity coordinators 1.6 Relationship to Other Programs The following policies and procedures are relevant to either preparing a Business Continuity Plan or for the implementation of BC across the organization: Enterprise Risk Management Framework Risk Information Management Team ( BCMT ) Redbook Guidelines for the development of Business Impact Analyses Business Unit Plan Template BC Training Modules BC Testing and Exercising Plan IT Disaster Recovery Plan 2 Management Roles and Responsibilities CEO Sponsor the BC program Endorse awareness and participation in business continuity activities Page 5 of 12

6 Endorse key business continuity documents, such as the Business Impact Analysis and the Corporate Strategy for recovery Team Develop the Business Impact Analysis survey, facilitate the timely completion of the survey, and analyze the results Facilitate the development, validation, and update of Plans, in particular the contact details Participate in tests and exercises of the Plans Provide training to stakeholders on their specific BC role, as well as good practices in BC generally Fulfill roles and responsibilities as detailed in the BCMT Redbook Maintain the BCMT Redbook Chief Risk Officer Ensure accountability for the administration of the BC business unit and program Provide resources to ensure BC is an ongoing program and integrated with other corporate management processes Endorse budget to support business continuity activities Coordinators Coordinate within respective organizational units to gather needed information Work with the Team to provide timely updates to the Business Impact Analysis and Plans Executive Leadership Team Ensure corporate governance framework supports business continuity Ensure BC approach supports strategic goals of the organization Provide overall direction and support for the BC program Establish milestones and performance reporting requirements as recommended by the Chief Risk Officer Approve revisions to the Framework Approve the test and exercise schedule and scenarios Review post incident/exercise reports for gaps and provide input regarding proposed revisions of the Plans Management Team Fulfill roles and responsibilities as detailed in the BCMT Redbook Review post incident/exercise reports for gaps and provide input regarding proposed revisions of the Plans Disaster Recovery Function Receive Business Impact Analysis outputs to drive disaster recovery (DR) strategy Page 6 of 12

7 Ensure IT DR plans support business continuity and are based on priorities understood from the Business Impact Analysis Participate in tests and exercises of the Plans Review post incident/exercise reports for gaps and provide input regarding proposed revisions of the IT DR plans Technical Operations Center (TOC) Provide notice of potential or occurring incident Ensure resources to restore IT capabilities during emergencies and outages Participate in tests and exercises of the Plans, as needed Review post incident/exercise reports for gaps and provide input regarding proposed revisions of the IT DR plans Office of Internal Audit Observe tests and exercises of the Plans Provide assurance of compliance with BC processes and procedures Review post incident/exercise reports for gaps and provide input regarding proposed revisions of the Plans Independently consult on the development and review of BC deliverables, as requested 3 Notification and Activation Trigger The BCMT, following the process set forth in the BCMT Redbook, will determine which plans and approaches shall be implemented based on the event characteristics. Two typical event scenarios are: An event occurs, but business unit owners do not immediately know that their functions and processes have been, or will be, interrupted. An event occurs, and business units immediately know that their functions and processes have been interrupted. In both situations, the notification and activation processes are the same; however, the size and level of complexity of the event will determine which plans are activated. 4 Existing Arrangements 4.1 Alternative Site Strategy In the case of events that result in the failure of the room or building that houses the affected function and/or supporting systems and services, continuity options have been developed to utilize alternative sites. Two alternative site options are generally considered in the Plans Page 7 of 12

8 which are: Alternative site on campus Alternative site off campus These options are facilitated by Facilities Management and, where applicable, the relevant BCMT members. For specific alternative site continuity arrangements, refer to individual Plans for details. 5 Determination of Critical Functions The organization s critical functions are determined by the Business Impact Analysis survey. An overview of the priority services, which need to be restored in the first instance following an event, is provided in the Corporate Strategy for recovery. The basis for determining criticality for each business unit is based on the following recovery time frames: Critical Important Deferrable 0 to 72 hrs. 72 hours 2 weeks > 2 weeks The determination of critical functions is separate from the identification of critical systems and applications. 6 Testing and Maintenance of Arrangements As part of Citizens commitment to BC culture, the organization will maintain an active and regular program of BC training, testing and review. 6.1 Testing Plan testing will be conducted no less frequently than annually based on management decisions and planning. Plan testing may include, but is not limited to, tabletop testing for selected business units, restricted plan activation and mobilization to stress test critical functions, or simulated exercises involving multiple functions and potentially an entire site. Post analysis shall be completed after each exercise. Lessons learned should be discussed and incorporated into relevant Plans, Business Impact Analyses, and other applicable BC materials. The BC team will oversee test exercises, keep records of tests including participants and dates, document all post analysis information, and lessons learned incorporation into respective processes and policies. Page 8 of 12

9 6.2 Review and Maintenance Framework The BC Team is responsible for ensuring that this framework is reviewed annually Business Impact Analysis The Business Impact Analysis survey must be reviewed at least annually Plans Plans must be reviewed at least annually, in conjunction with the relevant Business Impact Analysis. Plans should be updated after each training / testing exercise (if weaknesses or changes are identified) and after actual events. Contact names and details within the Plans should be reviewed and updated on a sixmonthly basis, or when a restructure occurs (change to operations, change to legislation/compliance, etc.), whichever occurs first Audit Internal Audit may review Business Impact Analyses and Plans. Internal Audit may also participate as observer in other business continuity related activities and provide feedback. 7 Terminology Term Alternate Site Application Recovery Asset Definition An alternate operating location to be used by business functions when the primary facilities are inaccessible: 1. Another location, computer center, or work area designated for recovery 2. Location, other than the main facility, that can be used to conduct business functions 3. A location, other than the normal facility, used to process data and/or conduct critical business functions in the event of a disaster The component of Disaster Recovery that deals specifically with the restoration of business system software and data after the processing platform has been restored or replaced. An item of property and/or component of a business activity/process owned by an organization. There are three types of assets: physical assets (e.g. buildings and equipment); financial assets (e.g. currency, bank deposits and shares) and non tangible assets (e.g. goodwill, reputation) Page 9 of 12

10 Term Planning Plan Strategy Team Business Impact Analysis Business Interruption Coordinator Command Center Crisis Definition The ability of an organization to provide service and support for its customers and to maintain its viability before, during, and after a business continuity event. The development of a document detailing the actions, resources and procedures to be utilized in the event that facilities are rendered inoperative by any event that causes disruption to a company s operations or business functions for a period beyond the maximum acceptable downtime. The primary goal of Planning is to minimize the extent of the disruption and damage and prevent its escalation, thereby reducing the economic impact. The plan covers not only the immediate emergency procedures needed to reduce loss of life and damage to property, but also the long term actions needed to expedite operational recovery for critical business functions. A Plan covers those incidents involving an operational downtime in excess of acceptable limits. Incidents within the maximum acceptable downtime limits should be covered by standard operating procedures. Process of developing and documenting arrangements and procedures that enable an organization to respond to an event that lasts for an unacceptable period of time and return to performing its critical functions after an interruption. An approach by an organization that will ensure its recovery and continuity in the face of a disaster or other major outage. Plans and methodologies are determined by the organizations strategy. There may be more than one solution to fulfill an organization s strategy. Examples: Internal or external hot site, or cold site, Alternate Work Area reciprocal agreement, Mobile Recovery, Quick Ship / Drop Ship, Consortium based solutions, etc. Designated individuals responsible for developing, execution, rehearsals, and maintenance of the business continuity plan, including the processes and procedures. A process designed to prioritize business functions by assessing the potential quantitative (financial) and qualitative (non financial) impact that might result if an organization was to experience a business continuity event. Any event, whether anticipated (i.e., public service strike) or unanticipated (i.e., blackout) which disrupts the normal course of business operations at an organization s location. Similar terms: outage, service interruption. An individual or group designated to coordinate or control designated recovery processes or testing. Typically assigned at the Department Director/Manager level. A physical or virtual facility located outside of the affected area used to gather, assess, and disseminate information and to make decisions to affect recovery. A critical event, which, if not handled in an appropriate manner, may dramatically impact an organization s profitability, reputation, or Page 10 of 12

11 Term Management Management Team Damage Assessment Disaster Recovery Disaster Recovery Plan Emergency Impact Incident Prioritization Recovery Response Definition ability to operate. Or, an occurrence and/or perception that threatens the operations, staff, shareholder value, stakeholders, brand, reputation, trust and/or strategic/business goals of an organization. The overall coordination of an organization s response to a crisis, in an effective, timely manner, with the goal of avoiding or minimizing damage to the organization s profitability, reputation, and ability to operate. Any incident can be an emergency. Any emergency could escalate to be considered a crisis, depending upon the scope and impact of an event. Management and the Management Plan are intended as the first step in the recovery process beyond the immediate Emergency Response. This phase of response is intended to control incidents, and set the stage for an increased level of response if needed. A team consisting of key executives, key role players (i.e., media representative, legal counsel, facilities manager, disaster recovery coordinator, etc.), and the appropriate business owners of critical functions who are responsible for recovery operations during a crisis. The process of assessing damage to computer hardware, vital records, office facilities, etc. and determining what can be salvaged or restored and what must be replaced following a disaster. The restoration of the organization s technology assets, including IT infrastructure, systems, and applications needed by the business. The management approved document that defines the resources, actions, tasks and data required to manage the technology recovery effort. Usually refers to the technology recovery effort. This is a component of the Management Program. An unexpected or impending situation that may cause injury, loss of life, destruction of property, or cause the interference, loss, or disruption of an organization s normal business operations to such an extent that it poses a threat. The effect, acceptable or unacceptable, of an event on an organization. The types of business impact are usually described as financial and non financial and are further divided into specific types of impact. An event which is not part of a standard operating business which may impact or interrupt services and, in some cases, may lead to disaster. The ordering of critical activities and their dependencies are established during the Business Impact Analysis and Strategicplanning phase. The Plans will be implemented in the order necessary at the time of the event. Implementing the prioritized actions required to return the processes and support functions to operational stability following an interruption or disaster. The reaction to an incident or emergency to assess the damage or impact and to ascertain the level of containment and control activity Page 11 of 12

12 Risk Term Enterprise Risk Management Table Top Exercise Work Area Facility Definition required. In addition to addressing matters of life safety and evacuation, Response also addresses the policies, procedures and actions to be followed in the event of an emergency. Potential for exposure to loss which can be determined by using either qualitative or quantitative measures. The culture, processes, and structures that are put in place to effectively manage potential negative events. As it is not possible or desirable to eliminate all risk, the objective is to reduce risks to an acceptable level while considering the risk impact, probability and cost of mitigation implementation options. One method of exercising plans in which participants review and discuss the actions they would take without actually performing the actions. Representatives of a single team, or multiple teams, may participate in the exercise typically under the guidance of exercise facilitators. A pre designated space provided with desks, telephones, PCs, etc. ready for occupation by business recovery teams at short notice. May be internally or externally provided. 8 References ISO22301: Management This standard specifies requirements for establishing and maintaining an effective BC program, regardless of the size and type of organization. The BC program should ensure that the organization s needs are met, implement and operate controls and measures for managing an organization s overall capability to manage disruptive incidents, monitor and ensure the effectiveness of the BC program, and ensure continual improvement based on objective measurement. The ISO standard is based on a Plan Do Check Act model for planning, establishing, implementing, operating, monitoring, reviewing, maintaining, and continually improving the effectiveness of the BC program. ISO31000: Risk Management principles and guidelines Enterprise Risk Management Framework Page 12 of 12

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