Professional Practice Eight - Business Continuity Plan Exercise, Audit, and Maintenance
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1 Professional Practice Eight - Business Continuity Plan Exercise, Audit, and Maintenance The goal of this professional practice is to establish an exercise, testing, maintenance and audit program. To continue to be effective, a Business Continuity Management (BCM) Program must implement a regular exercise schedule to establish confidence in a predictable and repeatable performance of recovery activities throughout the organization. As part of the change management program, the tracking and documentation of these activities provides an evaluation of the on-going state of readiness and allows for continuous improvement to recovery capabilities and ensure that plans remain current and relevant. Establishing an audit process will validate the plans are complete and accurate and in compliance with organizational goals and industry standards as appropriate. The Professional s Role in Professional Practice Eight is as follows: 1. Establish an exercise/testing program. 2. Establish a plan maintenance program. 3. Identify or establish appropriate industry and/or organizational standards. 4. Establish a business continuity program audit process. 5. Communicate exercise/test/audit results and recommendations. The Business Continuity Professional would demonstrate knowledge of this professional practice area by performing the following: 1. Establish an Exercise/Testing Program a. Develop an exercise program that meets the entity s continuity objectives. i. Align with the entity s strategy and tactical requirements. ii. Provide a high level of confidence for the continuity ad recovery of operations. b. Obtain executive sponsorship for exercise/testing program development. c. Develop a realistic, progressive and cost effective program. i. Document the exercise/testing standards and guidelines to be used. ii. Defined exercise/testing program assumptions and limitations. iii. Identify exercise types to be included that will create a comprehensive exercise program based on the recovery strategies implemented and the RTO and RPO defined by the entity for its operations. These may include operational, facility and technical exercises and testing such as: 1. Life safety exercises 2. Plan walk through / tabletop review DRII PP8 Business Continuity Plan Exercise, Audit & Maintenance Page 1
2 DRII PP8 Business Continuity Plan Exercise, Audit & Maintenance Page 2 3. Scenario based tabletop exercise 4. Call notification exercise 5. Alternate site exercise 6. Standalone platform, infrastructure or application recovery test 7. Full end to end functional exercise of an operation or technology 8. Comprehensive exercise of all recovery strategies required to recover the time sensitive operations and technology from a single site 9. Integrated technology exercise with internal and external interdependencies iv. Identify participants, roles and responsibilities in the exercise/test program. 1. Recovery team(s) 2. Observers/reporters 3. Time keepers 4. Auditor/reviewers 5. Facilitator 6. Suppliers 7. Out-sourced services and providers v. Define exercise program objectives and select appropriate scenarios. 1. Approximate the types of incidents the organization is likely to experience. Include suitable activities to exercise various facets of the recovery strategies, example(s): a. Technical - Does the equipment work? b. Procedural - Are the procedures correct? c. Logistical - Can people access the recovery facility and execute their recovery procedures? d. Timelines - Can the required RPO/RTOs be achieved? vi. Determine exercise requirements for each exercise to be conducted. 1. Define and document exercise objectives 2. Define and document in-scope/out-of-scope requirements 3. Define exercise notification process. a. Announced/planned b. Unannounced/surprised vii. Schedule exercises/tests to be conducted. 1. Develop a multi-year progressive schedule building on lessons learned and mastery of recovery processes. 2. Develop specific schedule for exercises and tests to be conducted on an annual basis or as frequently as necessary to ensure competency and to meet regulatory requirements.
3 DRII PP8 Business Continuity Plan Exercise, Audit & Maintenance Page 3 viii. Define and document evaluation criteria aligned with exercise objectives and scope: 1. Quantitative 2. Qualitative ix. Identify pre - exercise activities 1. Identify resources required to conduct the exercise. 2. Identify participants (example(s): business unit contacts, IT representatives, umpires, adjudicators, etc.). 3. Ensure all understand the objectives of the exercise and their roles. 4. Provide an inventory of hardware, software and physical assets required for the exercise (examples: PC/laptop, Security access, telephone, applications, printers, etc.). 5. Document and communicate specifications for the exercise environment. 6. Specify production vs. test environments. 7. Time for test - business day vs. weekend. 8. Provide a timetable of events and circulate to all participants, facilitators and adjudicators. 9. Establish back-out or test/exercise cancellation plan. x. Conduct exercise. 1. Should an incident occur during an exercise you should have a predetermined mechanism for cancelling the exercise and invoking the actual continuity process. 2. Record exercise process. 3. Document exercise results via the activation and maintenance of the issues log. 4. Declare end of exercise. 5. Shut down procedures. 6. Perform clean-up activities. xi. Identify post exercise activities. 1. Conduct debriefing sessions to review exercise results and identify actions for improvements. 2. Post-exercise reporting. 3. Provide a comprehensive summary with recommendations. 4. Document action plan report. 5. Identify open issues. 6. Identify actionable items with responsibilities and timeframes for resolution.
4 7. Monitor (and escalate where necessary) progress to completion of agreed actions. 8. Communicate exercise results. 9. Document lessons learned. 10. Document expected versus actual results. 11. Document unexpected results. 2. Establish plan maintenance program. a. Define plan maintenance method and schedule. i. Define ownership of plan data. ii. Prepare maintenance schedules and review procedures. iii. Select maintenance tools. iv. Monitor maintenance activities. v. Establish plan update process. vi. Ensure that scheduled plan maintenance addresses all documented recommendations. b. Define change control process i. Analyze business changes with planning implications. ii. Develop change control procedures to monitor changes (utilize existing change control process if already in place). iii. Create proper version control; develop plan re-issue, distribution, and circulation procedures. iv. Identify plan distribution lists for circulation. v. Develop a process to update plans based on response to audit findings. vi. Set guidelines for feedback of changes to planning function. vii. Implement change control process. 3. Identify or establish appropriate standards. a. Review appropriate industry (NFPA, ISO, ANSI, etc.) and national/international (US, British, Australian, etc.) standards. b. Review process owner expectations based on industry standards and organizational as well as client service expectations. c. Develop an organizational standard with a recurring review and enhancement/continuous improvement process. d. Based on industry and/or national/international standards as well as organizational and/ or client expectations. e. Frequency and scope appropriate for the organization. f. Approved by leadership. 4. Establish a business continuity program audit process. a. Define schedule for self-assessment audit. DRII PP8 Business Continuity Plan Exercise, Audit & Maintenance Page 4
5 b. Prepare to support other audits which may occur. i. Internal audit ii. External audit iii. Second-party audit c. Document audit standards and guidelines. i. Select/develop any needed audit tools. ii. Establish audit schedule. iii. Conduct/monitor audit activities. iv. Audit the plan structures, contents, and action sections. 1. Audit program requirements, documents and standards. 2. Audit templates and plan. 3. Audit test requirements and results. 4. Audit repository for plan and test results. 5. Audit the plan documentation control procedures. 6. Audit version control process and documentation. 7. Audit distribution lists and associated processes. 8. Audit change control process. v. Review management response to audit findings. vi. Confirm responses have been submitted and action plans documented. vii. Verify completed actions have been captured in the plan and supporting documentation. 5. Communicate exercise/test/audit results and recommendations. a. Identify appropriate stakeholders. i. Process owners ii. Governance coordinators iii. Senior leadership/operations oversight b. Select appropriate communication methods and communicate in a timely manner. i. Reporting level of detail ii. Where appropriate, consider graphic representations or comparison reports targeted by audience c. Establish a feedback/validation loop to confirm appropriate actions have been taken as a result of reported findings. i. Issues tracking ii. Date item opened iii. Owner of issue iv. Date item closed DRII PP8 Business Continuity Plan Exercise, Audit & Maintenance Page 5
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