Business Continuity Planning and The Sarbanes-Oxley Act...
In the wake of some spectacular corporate governance failures at several
companies, Congress has enacted the Sarbanes-Oxley Act. It addresses
the shortcomings of corporate governance and now requires improved and
demonstrated overall controls associated with the management and reporting
of corporations - it is now law as of April 15, 2004. Failure to comply
with Sarbanes-Oxley exposes Senior Management to possible prison time
and/or significant penalties.
A great amount of activity in the Business Continuity/Disaster Recovery
arena has recently occurred as related to the Sarbanes-Oxley Act. Business
Continuity Programs, or the lack of them, are now on the checklists
of all Corporate Auditors. Active and up-to-date Business Continuity
Programs have now become a “Corporate Necessity”.
Cosmic Software Technology has recently formed a new arm of the company
to provide all aspects of Business Continuity/Disaster Recovery Services.
We now have two nationally recognized experts
on staff to head up and manage our Business Continuity/Disaster Recovery
projects. We feel that we can add great value to your organization with
these services.
Cosmic Software Technology looks forward to further discussion of how
our Business Continuity Program can protect your company’s critical
assets.
The Eight Step Business Continuity Program………
The following program outline is a typical Business Continuity Program
as found in “The Professional Practices for Business Continuity
Planners” which is administered by Disaster Recovery Institute
International (DRII) of Falls Church, Virginia. DRI International was
founded in 1988 to provide a base of common knowledge in contingency
planning. DRII also administers the industry's global certification
program for qualified business continuity and disaster recovery planners
(CBCP). The “Professional Practices for Business Continuity Planners”
serves as the industry’s best practices standard.
The following eight (8) phase approach is utilized as the methodology
for the initiation and timely completion of your Business Continuity
and Recovery Planning Project. These phases are:
Phase 1 -- Project Initiation and Management
Phase 2 -- Perform a Risk Analysis
Phase 3 -- Perform a Business Impact Analysis
Phase 4 -- Develop a Recovery Strategy and establish Recovery Policies
and Budgets
Phase 5 -- Develop the Business Continuity & Recovery (BC&R)
Plan
Phase 6 -- Exercise the Business Continuity & Recovery (BC&R)
Plan
Phase 7 -- Maintain and Update the Business Continuity & Recovery
(BC&R) Plan
Phase 8 -- Train and Maintain Corporate Awareness of Business Continuity
& Recovery (BC&R) Plan.
1. Project Initiation and Management
Identifies the scope of the project and provides an initial review of
the Eight Phases. A high level project timeline is developed at this
point in time.
2. Risk Analysis
Each phase of the BC Program is dependant upon the completion of the
preceding phase except for the Risk Analysis. The Risk Analysis is typically
performed “stand-alone” irregardless of the existence of
an in place Business Continuity Program.
The Risk Analysis (RA) determines the vulnerability of a company’s
physical and operational facilities to internal and external threats.
It results from a focused evaluation of the company’s facilities
and a statement of the most probable threats to those facilities.
The RA provides a rationale and cost justification for installation
of risk mitigation elements (“controls”) to support continuous
availability of business operations. By clearly stating the possible
effects of a threat, it provides a vehicle for decisions by Senior and
Executive Management. Observations made during the Risk Analysis are
verified with key managers, and modified based upon validated information
received from these reviewers. Issues related to risk mitigation are
addressed as an essential element in any upgrade or architectural change.
A set of "next steps" is developed to create a process that
responds to changes in daily operational needs and business processes.
Although all 8 phases are needed for a successful Business Continuity
Program, most practitioners in the industry feel that the Risk Analysis
provides a client “the biggest bang for the buck”. It can
be viewed as a “Business Continuity Physical Exam”.
3. Business Impact Analysis
The Business Impact Analysis (BIA) identifies critical company assets
and determines the financial exposures and operational impacts resulting
from a major outage or disruption in the daily business or telephone
services operations. It results from questionnaires and face-to-face
interviews, with key company and department heads.
4. Business Recovery Strategy, Policies and Budgets
Development of Acceptable Recovery Strategies to effectively
avoid the ìOutage Impactsî as agreed upon during the BIA. In addition
it provides the Disaster Recovery Team Leaders and Alternate Team Leaders
with a ìPlace To Go For Recoveryî in the aftermath of a Disaster Event.
5. Business Recovery Plan Development
Development of a Business Recovery Plan will assume a worst-case,
total facility disaster, thus also providing for recovery from less
severe circumstances. An alternate site location will be identified
for business recovery. Team responsibilities will be detailed. All pertinent
employee and business data will be included.
6. Exercising the Business Recovery Plan
Plan exercises should be conducted bi-annually during the initial
phase of plan introduction. Plan functions and team communications are
tested initially with more elaborate scenarios introduced as each subsequent
test progresses. Plan maintenance is performed as an output of the Plan
exercise.
7. Business Recovery Plan Maintenance
It is recommended that Plan Maintenance be performed on a yearly basis
or as organizational structures may dictate. At maintenance time any
new or changed pertinent information is edited and the updated Business
Recovery Plan is distributed to the team members.
8. Employee Training and Corporate Awareness
Employees need to be aware of their responsibilities during
the activation of the Business Recovery Plan. Employees that are not
required in the execution of the plan still need to know that a plan
exists and what it is expected to provide. Plan Training should be conducted
for existing employees and new employees should be made aware that a
BCR Plan exists and what their role in the plan requires.
Click chart to enlarge.