Prepare for the worst - Guidelines for Business Continuity
Management
Lyndon Bird,
Managing Director
Continuity
Planning Associates
Technical
Services Director,
The Business
Continuity Institute
February 2006 |
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Recent times have proven to be exceptionally challenging for all
those involved with disasters, emergencies, security and business
continuity. Starting with the Asian tsunami, the world has
experienced a seemingly endless stream of catastrophic events.
Hurricanes in the US, earthquakes in Pakistan and global terrorism,
including the London bombings of July 7, meant that disasters were
never out of the headlines. The impression given was that despite
our technological sophistication we were effectively powerless to
prevent acts of God and only marginally better to deal with those
deliberately wishing to wreak havoc on our lives and businesses.
Even on a more local scale, the explosion at the Buncefield oil
depot, one of the UK's biggest, created what was described as "the
largest fire fighting exercise in peace-time Europe". Many local
businesses were badly affected. The first to signal problems was
Asos, an on-line fashion retailer whose warehouse was badly damaged
by the fire. Asos suspended its shares on December 23 and had to
refund 19,000 customers who had ordered online goods for Christmas.
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Clearly, the growth of online businesses gives the potential for a
better response to certain threats than traditional methods ever
allowed. Public health scares, such as flu pandemics, are best
contained by people not going out and contaminating each other.
Buying your food and other goods online is the obvious solution.
Increasing the number of home workers by providing enhanced
technical capability for them to work online is also an obvious
business continuity strategy.
Many people ask what the connection is between diverse types of
risks - natural disasters, terrorism, fire, accidents, computer
failures and health scares. The answer is that, although they arise
from entirely different sources, the management of the consequences
relies on a set of principles that are largely the same regardless
of cause. This set of principles is now generally defined under the
subject name "business continuity management".
What is BCM?
BCM has suffered from not having a clear, legal definition that is
accepted by all. Many of its original practices emerged from an
earlier technical discipline, "IT disaster recovery". Other concepts
seemed to overlap with different fields, such as emergency
management, crisis management, operational risk and security. Exact
understanding of the terminology varied across the English-speaking
world, which confused other countries and made it difficult to
spread internationally.
The Business Continuity Institute was founded in 1994 and has
actively worked to address these issues. It published jointly, with
the US-based Disaster Recovery Institute, a set of ten standards for
professional practitioners back in the 1990s. These are regularly
reviewed and updated. Although the standards gave definition to the
boundaries of BCM, they were often misunderstood. The standards were
created to satisfy the institute's membership requirements and vet
candidates for professional recognition. They were not a methodology
or statement of BCM best practice.
First, there are the analytical skills, which are particularly
evident in the standards' business impact analysis and risk
evaluation sections. Secondly, the ability to think strategically
and develop original ideas is tested in the sections on business
continuity strategies and emergency response. The standards also
check the practical skills involved in the sections on programme
management and awareness training. Continuous professional
development is needed to ensure that changing standards are applied
in maintenance and exercising. Finally the broader perspective is
assessed in the fields of crisis communications and coordination
with external agencies. Only a person who can combine analytical,
strategic, and practical skills with a wide understanding of the
body of knowledge is certified as a BCI member
The BCI did recognise that although this give a general definition
of what is involved in BCM, it did not provide much help in terms of
actually getting good BCM practice implemented. In an attempt to
rectify this, the institute published its good practice guidelines
in 2002. The guidelines were built in conjunction with many industry
experts, mainly from large financial institutions. Although not
directly comparable, this did prove to be a major influence on the
Financial Services Authority's own guidelines for the UK financial
sector.
The institute's guide defined BCM as: "an holistic management
process that identifies potential impacts that threaten an
organisation and provides a framework for building resilience and
the capability for an effective response that safeguards the
interests of its key stakeholders, reputation, brand and value
creating activities."
The success of this guide was also seen in the British Standards
Institute's PAS 56 (a publicly available specification for BCM). In
2005, the guide was re-written to take into account the following:
·
the comments received in response to the original guidelines
·
the BSI's publication of PAS 56 2003
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legislation, regulatory guidelines and practices that have spread
business continuity implementation into all industrial, public and
not-for-profit sectors around the world
Standards and regulation
Apart from the professional certification standards, much work is
currently being undertaken around the world to get a clearer and
more standardised acceptance for BCM. This is difficult because what
is applicable in one industry is alien in another.
I believe the UK leads the debate, with PAS 56. This has been
purchased by many thousands of interested parties around the world.
It is now being developed into a full British standard for business
continuity - an activity that is being driven by the BCI. It is
almost certainly going to become the EU standard and, hopefully,
become the International Organisation for Standardisation.
In the US, the National Fire Protection Association appears to be
the leader in gaining a wider acceptance for a standard in this
field. NFPA has been working on its emergency preparedness standard
since 2004, although it is still in draft form. It covers emergency
management and business continuity programs and currently runs to 50
pages. It lacks the focus on BCM that the European approach is
taking, however, and concentrates heavily on physical incidents.
There are also many advisory guidelines for business continuity.
These are often industry and country specific, although the new BCI
GPG is crosses industries and regions.
What this is all leading to is more control on how organisations
operate and how they guarantee continuity of business. In
particular, the financial sector should expect much stricter
regulatory control in the future. In the UK for example, the FSA
has, for some years, been moving its regulated firms towards BCM
standards which, although non-mandatory, are still required for
compliance. In the US, the Federal Reserve has taken a similar but
more powerful approach with some mandatory elements. Other
initiatives have taken place in many areas of the world, including
Standards, Productivity and Innovation Board directives in Singapore
and EU guidelines from Brussels.
High profile events have inevitably led to government involvement.
The US
Sarbanes-Oxley Act has created a situation in which directors
and officers of companies are personal responsible for control
failures within their organisations. This Act not only applies to US
companies but also to non-US companies that operate within US
markets and, of course, to the foreign subsidiaries of US domiciled
corporations.
So all of this should, ultimately, lead to improvements in the
quality and consistency of business continuity and the business
continuity professional. It will go a long way towards bridging the
gap in business continuity maturity levels. Another real benefit
will be the ability to benchmark business continuity capabilities
between industries, companies and regions. All of this will enable a
move towards best practice. It should also help to breakdown the
silo mentality and approach by integrating the disciplines of
business continuity with security, emergency and crisis management.
The FSA has undertaken the largest benchmarking exercise in the
world, asking 70 leading firms 1,000 questions on all aspects of
BCM. I will come back to the results of this exercise in future
editions.
Conclusions
BCM is no longer an optional activity in major organisations. The
increased perceived level of threat, the documented consequences of
not planning and the pressure put on management by corporate
governance compliance has pushed BCM well up the business agenda
since 9/11. The main purpose of BCM is to ensure that organisations
have a response to major disruptions that threaten their survival.
Although this must be worthwhile in itself, there are other benefits
that can be gained by embracing BCM as a management discipline.
Some organisations have statutory and regulatory requirements,
either specifically for BCM or more generally for risk management,
as part of their corporate governance requirements. An appropriate
BCM plan will satisfy the specific requirements and contribute a
response to both specific risks and to the overall risk awareness of
an organisation. The primary reason for BCM, however, should always
be that it is undertaken because it adds value to an organisation
rather than for governance or regulatory considerations.
Organisations that sell to other businesses have used BCM as a
competitive advantage to gain new customers and to improve margins.
A thorough review of the business through business impact analysis
can highlight inefficiencies and focus on priorities that would not
otherwise have been recognised.
Nigel Turnbull, chairman of the Turnbull committee on UK corporate
governance, has stated: "For many companies, BCM will address key
risks and help them achieve compliance".
Eliza Manningham-Buller, director-general of MI5, went even further
at a Confederation of British Industry conference in November 2004.
She said "I am often asked what single piece of advice I can
recommend that would be most helpful to the business community. My
answer is a simple, but effective business continuity plan that is
regularly reviewed and tested."
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