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    Bank of Canada

    IT Operations and Infrastructure Services

    Bank of Canada (BoC) White Paper

    Business Continuity Plan (BCP) versus Disaster Recovery Plan (DRP)

    for presentation to

    XXXIV MEETING ON CENTRAL BANK SYSTEMATIZATION

    Sept 7-9, 2011, SANTIAGO, CHILE

    Date of Issue: August 17, 2011

    Bank of Canada, Information Technology Services (ITS)

    Daniel Schaffler, Victor Baez with Daniel Lamoureux

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    TABLE OF CONTENTS

    1. WHO WE ARE ..............................................................................................................................1

    1.1. HISTORY .....................................................................................................................................2

    1.2. OUR CHANGING WORLD ................................................................................................................4

    1.2.1. COMPLEXITY OF ENVIRONMENT ADAPTING TO EMERGING TECHNOLOGIES ................................................... 4

    1.2.2. INCREASED RISK SPECTRUM .................................................................................................................... 5

    2. OVERVIEW OF RISK MANAGEMENT FRAMEWORK, CONTINUITY OF OPERATIONS PROGRAM, AND

    IT SERVICE CONTINUITY MANAGEMENT .............................................................................................6

    2.1. RISK MANAGEMENT FRAMEWORK ....................................................................................................6

    2.2. CONTINUITY OF OPERATIONS (COOP) ...............................................................................................7

    2.2.1. MANDATE ........................................................................................................................................... 7

    2.2.2. PRINCIPLES AND FRAMEWORK ................................................................................................................ 7

    2.2.3. RELATION BETWEEN COOP AND THE RISK MANAGEMENT FRAMEWORK ....................................................... 8

    2.2.4. BUSINESS IMPACT ANALYSIS (BIA) .......................................................................................................... 8

    2.3. ITSERVICE CONTINUITY MANAGEMENT (ITSCM) ................................................................................9

    2.3.1. MANDATE ........................................................................................................................................... 9

    2.3.2. PRINCIPLES AND FRAMEWORK ................................................................................................................ 9

    2.3.3. RELATION BETWEEN ITSCM AND COOP................................................................................................ 10

    2.3.4. INPUT FROM THE BIA.......................................................................................................................... 11

    2.3.5. ITSCMPROCESS RELATION WITH ITIL AND OPERATIONAL PROCESSES ......................................................... 11

    2.3.6. CURRENT RECOVERY POSTURE .............................................................................................................. 12

    2.3.7. SPLIT OPERATIONS .............................................................................................................................. 132.3.8. THE FUTURE POSTURE, A MORE RESILIENT ENVIRONMENT .......................................................................... 14

    2.4. HUMAN CAPITAL ........................................................................................................................ 15

    2.5. AWARENESS .............................................................................................................................. 16

    2.6. TESTING AND EXERCISES ............................................................................................................... 16

    2.6.1. ITSCM DRIVEN EXERCISES .................................................................................................................... 16

    2.6.2. DISASTER RECOVERY EXERCISES ............................................................................................................. 16

    2.6.3. TABLE TOP EXERCISES .......................................................................................................................... 17

    2.7. COOP DRIVEN EXERCISES ............................................................................................................. 17

    2.7.1. BANK-WIDE CONTINUITY TESTS ............................................................................................................. 17

    2.7.2. CALL TREE EXERCISES ........................................................................................................................... 18

    2.7.3. SIMULATIONS .................................................................................................................................... 182.8. EVALUATING OUR PREPAREDNESS AND RESPONSE ............................................................................... 18

    3. LESSONS LEARNED FROM THE OCCURRENCE OF REAL CONTINGENCIES....................................... 19

    3.1. CONTINUOUS IMPROVEMENT ........................................................................................................ 21

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    1. Who we areThe Bank of Canada is the nations central bank, with four main areas of responsibility:

    Monetary policy - The Bank contributes to solid economic performance and rising living standardsfor Canadians by keeping inflation low, stable and predictable. Since 1991, the Banks monetary

    policy actions toward this goal have been guided by a clearly defined inflation target

    Currency - The Bank designs, produces and distributes Canadas bank notes and replaces wornnotes. It deters counterfeiting through leading-edge bank note design, public education and

    collaboration with law-enforcement agencies

    Financial System - The Bank promotes a stable and efficient financial system in Canada andinternationally. To this end, the Bank oversees Canadas key payment, clearing and settlement

    systems; acts as lender of last resort; assesses risks to financial stability; and contributes to the

    development of financial system policies

    Funds Management - The Bank provides effective and efficient funds-management services for theGovernment of Canada, as well as on its own behalf and for other clients. For the government, the

    Bank provides treasury-management services and administers and advises on the public debt and

    foreign exchange reserves. In addition, the Bank provides banking services to critical payment,

    clearing and settlement systems

    Our principal role, as defined in the Bank of Canada Act, is to promote the economic and financial

    welfare of Canada.

    The Bank was founded in 1934 as a privately owned corporation. In 1938, it became a Crown

    corporation belonging to the federal government. Since that time, the Minister of Finance has held the

    entire share capital issued by the Bank. Ultimately, the Bank is owned by the people of Canada.

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    The Bank is not a government department and conducts its activities with considerable independence

    compared with most other federal institutions. For example:

    The Governor and Senior Deputy Governor are appointed by the Bank's Board of Directors (with theapproval of Cabinet), not by the federal government

    The Deputy Minister of Finance sits on the Board of Directors but has no vote The Bank submits its expenditures to its Board of Directors. Federal government departments

    submit theirs to the Treasury Board

    Bank employees are regulated by the Bank itself, not by federal public service agencies The Bank's books are audited by external auditors appointed by Cabinet on the recommendation of

    the Minister of Finance, not by the Auditor General of Canada

    1.1.HistoryCanadians have always been firm believers in the value of insurance, and the institution of the

    Bank of Canada is no exception. Making the business case for Business Continuity Management

    (BCM) and Disaster Recovery Planning (DRP) has never been at issue for the Bank. The necessity of

    fulfilling our legislated mandate, practicing good governance, and preparedness for provision of

    uninterrupted, essential services vital to the national and global financial community have all been

    well understood and accepted, and indeed have been a integral part of the Banks culture from the

    early days of the mainframe to the more recent distributed computing environment.

    The IT computing environment running the Banks core applications in the latter part of the 20th

    century consisted of a mainframe computer dedicated to the production environment, and another

    mainframe computer in a separate, geographically disparate location dedicated to the testing and

    development environments. The production environment was very tightly controlled and restricted,

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    with a high degree of policy and procedure in place to manage access to, and migration of changes

    from the development to the production environment.

    Disaster recovery plans were in place to facilitate complete recovery of the production mainframe

    computing and network environment, and included off-site vaulting of what were deemed as vital

    records (eg. tape backups of the system, software, applications and data).

    A dedicated Disaster Recovery Coordinator position was staffed, with responsibility for over-seeing

    the creation and management of disaster recovery plans and procedures to ensure business

    continuity.

    Disaster recovery plans were exercised and tested twice yearly and entailed full recovery of the

    production mainframe environment onto the development mainframe. Additional exercises , limited

    to the IT Services department (at the time known as Automation Services Department (ASD)) were

    also undertaken periodically to ensure that ASD was well positioned to provide IT services to meet

    the business continuity requirements of the larger Bank. Those exercises also provided a means by

    which ASD could ensure that changes enacted into the production environment had been factored

    into business continuity plans.

    With the advent and adoption of the distributed computing environment, the complexity of

    business continuity management increased significantly, but through it all, the Bank has, and always

    will, continue to place high importance on the need to have proven strategies and plans in place.

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    1.2.Our Changing WorldEverything flows and nothing stays. Heraclitus, Greek Philosopher (c.535-c.475 BC)

    In keeping with the long-term trend in the history of computing hardware described by Moores law

    (exponentially increasing capacity), so too has the complexity of both the business and computing

    environments evolved, along with the spectrum of risks to be dealt with.

    In todays world, business and IT organizations are:

    Striving to leverage lessons learned and apply best practices Increasingly required to demonstrate their value (profitability, cost-effectiveness) Re-defining relationships between internal and external business units Dealing with changing business models Addressing rapidly changing technologies, standards and practicesThe Bank of Canada, like every other organization, has been subject to the technological, natural

    and environmental forces that shape the nature of our business and delivery of our services, and the

    changes that need to be undertaken to stay current and sustainable.

    1.2.1. Complexity of environment adapting to emerging technologiesMost, if not all, IT organizations are additionally trying to manage IT as business, amidst a

    dramatically changing technology landscape that is both much more complex and challenging

    than previous computing environments. Computing platform changes (mainframe vs.

    distributed vs. cloud; centralized vs. decentralized), networking advances (multimedia; VOIP;

    data and voice convergence; fiber), server and storage evolution (clusters; virtualization; NAS;

    SAN; backup and recovery technology), applications development (SaaS; multi-threading) and

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    services all come with various benefits and risks, and can dramatically alter the business

    continuity posture of an IT organization. Vigilance with respect to availability, reliability and

    sustainability, along with the imperative need to ensure alignment between business

    requirements, service level expectations and the cost of doing business, is required and

    continuously on-going.

    1.2.2. Increased risk spectrumThe spectrum of risks facing an organization from natural and environmental forces has changed

    significantly over the course of the last two decades.

    Thinking back from 1998 to the present, the Bank has rapidly responded to, and successfully

    dealt with, the following naturally occurring events, with marginal disruption to the conduct of

    business and the delivery of services:

    1998 - ice storm, affecting power distribution lines across central Canada 2010 - a magnitude 5.0 earthquake occurs in central CanadaOn the environmental front, the same can be said for the following actual and on-going events:

    1999 - the new millennium (Y2K) 2001 - heightened terrorism treat after September 11 2002 - Severe Acute Respiratory Syndrome (SARS) outbreak 2002 - 2 day "Take the Capital" protest in Ottawa against G8 meeting being held in Alberta 2003 - The largest power outage in North American history 2008 - Suspicious package deposited outside the Banks head office 2009 - Potential influenza pandemic

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    2010 Major equipment failure affecting the Banks telephony system 2011 - heightened occurrence ofcyber attacks On-going succession planning and the loss of corporate knowledge On-going supply chain (including outsourcing) and vendor induced disruptionsThe above mentioned events and threats, as well as the potential for future ones, have all

    contributed directly to the constant re-assessment, strengthening and evolution of the Bank of

    Canadas risk management, business continuity and IT service continuity management plans and

    posture.

    2. Overview of Risk Management Framework, Continuity of OperationsProgram, and IT Service Continuity Management

    2.1.Risk Management FrameworkThe Bank developed its risk management framework in 1971 in consultation with the Board of

    Directors. Risk management is viewed by the Bank as particularly important to sound governance,

    decision making and accountability. The framework supports informed decision making by ensuring

    that the appropriate competencies, analytic tools, consultation and communication form the

    foundation for innovation and responsible risk taking.

    The risk management framework is fully integrated with the Banks corporate management

    processes. It is incorporated into the annual planning, priority-setting, budget process, and

    quarterly/yearly stewardship processes. It is supported by an in-house tool that allows tracking and

    classification of operational risk events which gives it insight into the nature of problems that arise

    with its processes and systems.

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    The Bank has had a long-standing, well-established security and administrative framework for

    safeguarding its personnel and assets (physical, information and financial). The safeguards include:

    policies and standards; personnel screening; physical and logical security equipment and processes;

    business continuity planning; and security awareness programs.

    2.2.Continuity of Operations (COOP)2.2.1. MandateThe Bank of Canada delivers services that are essential to the economic well-being of the nation.

    To ensure that those services, and the Banks role in the global financial community, continue to

    be delivered during a disruptive event, the Bank has created a Continuity of Operations (COOP)

    program. The COOP program encompasses all disciplines necessary to enable recovery of

    essential Bank services subsequent to a disruptive event, with emphasis on the protection of

    Bank employees and property.

    2.2.2. Principles and frameworkThe Bank of Canada Continuity of Operations program has been explicitly designed to meet the

    standards set by applicable sections of the Bank Security Policy (BSP) and the National Fire

    Protection Association (NFPA) 1600 Standard on Disaster/Emergency Management and

    Continuity of Operations Programs. Compliance with the BSP is mandatory, but compliance with

    NFPA 1600 is voluntary.

    The Continuity of Operations program is an ongoing management and governance process

    mandated and supported by senior management, and resourced to ensure that the necessary

    steps are taken to identify the impact of potential losses, maintain viable recovery strategies

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    and plans, and help ensure continuity of key functions and processes through exercising,

    rehearsal, testing, training and maintenance.

    2.2.3. Relation between COOP and the Risk Management FrameworkThe COOP program is a key part of the Banks risk framework for safeguarding its personnel and

    assets (physical, information and financial), as the COOP program guides, supports, and

    promotes the Banks plans to:

    Help ensure the safe evacuation of all persons on Bank property in an emergency Continue its critical business in the event of a disaster or crisis2.2.4. Business Impact Analysis (BIA)The fundamental goal of the Continuity of Operations discipline is to identify mission-critical

    processes that support key Bank activities, the maximum recovery timeframes for those

    processes after a disruptive event, and the processes and procedures used to restore the

    process subsequent to a business interruption.

    To maintain an inventory of Bank-wide business processes and functions (not all of which are IT

    related or have an IT connotation), the COOP program conducts a Business Impact Analysis

    (BIA), as the mechanism for the identification and prioritization of the Banks critical business

    processes based on impact, injury and loss that would result if a process were to become

    unavailable for any reason.

    The Business Impact Analysis is necessarily a point in time snapshot that reflects the functions of

    the Bank and the recovery priorities and timeframes as they exist when the BIA is created.

    However, the Bank is an evolving organization, and the COOP program recognizes the fact that

    functions and priorities may shift over time. Therefore, the COOP Program Office is charged with

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    responsibility for facilitating a review of the BIA every two years, to ensure that each

    Departments inputs accurately represent the Bank's current operational state.

    2.3.IT Service Continuity Management (ITSCM)2.3.1. MandateInformation Technology Service Continuity Management (ITSCM) is concerned with managing

    the organizations ability to continue to provide a pre-determined and pre-approved level of IT

    service to support the minimum business requirements following an interruption to the

    business. This may range from an application or system failure, to a complete loss of the

    business premises.

    2.3.2. Principles and frameworkITSCM is based on the IT Infrastructure Library (ITIL). ITIL is a publicly available framework, and it

    is used by organizations word-wide to establish and improve capabilities in IT Service

    Management, to provide value to customers in the form of services (a service being something

    that provides value to customers.)

    The main benefits of ITIL include:

    Alignment with business needs Negotiated achievable service levels Predictable, consistent processes Efficiency in service delivery, with well-defined processes Measurable, improvable services and processes Common language and terms

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    ITSCM is a mature process within the IT Service Management group of the IT Services (ITS)

    department. It is supported by IT senior management, and resourced to ensure that the

    necessary steps are taken to identify the impact of potential losses, maintain viable IT recovery

    strategies and plans, and help ensure IT continuity of key functions and processes through

    exercising, rehearsal, testing, training and maintenance.

    2.3.3. Relation between ITSCM and COOPITSCM is a key part of the overall Continuity of Operations process and is dependent upon

    information derived through this process. ITSCM is focused on the continuity of IT services to

    the business, and the COOP program is concerned with the Business Continuity management

    process that incorporates all services upon which the business depends, one of which is IT.

    ITSCM supports the overall COOP process by ensuring the required IT infrastructure,

    applications, and services identified as critical by the business, can be recovered within the

    required, and agreed upon, business timescales.

    To accomplish this goal, ITSCM ensures that proactive measures are:

    in place to minimize or avoid business disruptions caused by IT outages, supported as part of normal IT service deliverables, and factored into all IT projects and initiativesITSCM provides a framework that minimizes risk for the management and provision of IT

    services (for either actual or potential disruptions) to defined service levels. Accordingly, ITSCM

    not only focuses on reactive contingency measures, but also on proactive measures to avoid

    serious business disruptions.

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    2.3.4. Input from the BIAInformation technology is often a critical resource that is required to restore operations of many

    Bank processes and functions; it is a critical enabling resource. Therefore, ITSCM is responsible

    for review the BIA and ensure that the Bank's information technology recovery plan accurately

    reflects the business priorities and timeframes as they are represented in the BIA.

    Also the BIA provides the means to categorize the business processes in Tiers based on the

    maximum allowable downtime. These Tiers allow IT to define:

    Service levels for applications and infrastructure defined by tier, instead of defining servicelevels for each application or service

    Identify the Recovery Time Objectives (RTO) and Recovery Point Objectives (RPO) for theapplications and IT infrastructure depending on the business process that supports.

    The benefits of the categorization by Tiers from the BIA:

    Covers all business line applications and foundational, enterprise-wide services (eg.network connectivity; application hosting; storage management; email; backup/recovery;

    remote access; etc)

    Provides clarity on services provided by ITS, and links them to the costs incurred Provides clarity on Disaster Recovery posture, since Disaster Recovery solutions can be

    offered to the business in Tiers (eg. Critical, Standard, etc.)

    Applies criteria of critical vs. non-critical services, providing guidelines for initialprioritization and cost saving opportunities (where to focus attention and resources)

    2.3.5. ITSCM Process relation with ITIL and operational processes

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    Ensuring the continuity of IT services in the event of a disruption requires a thorough

    understanding of IT services provided and how they operate under normal circumstances. The

    ITSCM process must be aware of and take account of any factors that affect the operation of IT

    services - ITSCM is a process that is engaged in all activities in ITS. Consequently it receives feeds

    from various operational processes and entities such as:

    Configuration Management: IT components and relationships Change Management: Ensuring the currency and accuracy of the Continuity Plans through

    the identification of changes affecting, or modifying the IT continuity posture

    Problem Management: Impact analysis of problems that are affecting or may affect thecontinuity solutions and ITSCM plans

    Incident Management: Early notification of incidents that can potentially interrupt ITservices and could require the activation of ITSCM plans

    Service Level Management: Service Levels based on BIA criticality, detailing what servicelevels must be maintained under normal circumstances and in a disaster situation

    IT Project Management and Delivery Process: Assessment of ITSCM requirements andproposed continuity solutions, based on ITSCM policy

    IT Enterprise Architecture: Assessment of long-term architecture vision and designcompliance to approved continuity solutions and plans

    2.3.6. Current Recovery PostureThe Banks main data center is located at Head Office with an alternate center located 20 km

    away, which serves as the recovery site in the event of a business disruption. The alternate site

    is equipped with computer systems, data links, and staff work areas that enable the Bank to

    continue critical operations if the Head Office location is inaccessible or unavailable.

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    The current alternate posture provides:

    On-site support for a number of users based on BIA requirements Support for remote access connectivity Local workstations configured with business line applications A flexible recovery workspace (since corporate applications and business line tools can be

    provided via workspace virtualization, when users start their personal workspace, they

    view their own familiar and personalized work space where they can access files,

    applications, settings and entire desktop. IT is not dependant on a pre-defined

    workstation.)

    2.3.7. Split operationsThe Bank conducts pre-defined critical business functions from two sites simultaneously, so that

    should an event affect either site, the remaining site will settle the days work. The

    implementation of split operations strengthened and deepened the Banks operational

    resiliency.

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    2.3.8. The future posture, a more resilient environment

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    The Bank recently launched a project to increase the environment resilience, by relocating the

    main data centre. The strategy was developed through a review of the threats with potential to

    impact the Banks operations, the extent to which those threats can be mitigated by increasing

    geographic separation between sites and the associated operational risks, as well as what other

    central banks and similar organizations are doing in this area.

    The strategy is to:

    implement split operations for pre-defined critical operations locate the Banks main data centre and business recovery 6 to 20 km from Head Office, and locate the Banks alternate data centre 20 to 50 km from the main data centre

    2.4.Human capitalA fundamental best practice for all COOP planning is to plan to the worst-case scenario, to ensure

    that the Bank is prepared for a variety of situations, even though we do not necessarily know to

    what degree we may be challenged. In this instance, one of the worst cases would be coping with

    severely reduced workforce. To mitigate this scenario, Managers from across the Bank worked with

    the COOP Office to develop a categorization matrix identifying those functions in their areas that

    were time-critical and determined whether or not those functions could be performed remotely.

    They then identified those individuals who currently fulfill those functions (referred to as the core

    group), as well as a pool of individuals with the skill sets who could do the necessary work if people

    in the core group were unable to.

    This category matrix also provides the guidelines for:

    Identifying areas of vulnerability

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    Establishing remote access priority, ensuring that the pre-determined staff can continue toconduct business-critical operations

    2.5.AwarenessThe success of ITSCM depends on a continuing commitment at all levels in the organization and on

    people's awareness of their respective responsibilities. IT service continuity requirements are

    factored alongside operational activities.

    Each department has a Departmental Emergency Response Coordinator, which is responsible for the

    coordination and logistics of the departments Continuity of Operations plan, and also is responsible

    for the dissemination of information provided by the COOP program office.

    2.6.Testing and exercises2.6.1. ITSCM driven exercisesITSCM policies mandate that IT continuity solutions and plans must be tested on a regular basis

    to evaluate recovery capability effectiveness, and to identify and address any deficiencies.

    The purpose of this policy is to validate that the applications and infrastructure at the alternate

    site can operate isolated from the primary site and meet the required Recovery Time and

    Recovery Point Objectives. It also serves to identify and resolve problems in the IT infrastructure

    that could impact the recovery capabilities of critical bank processes, and ensures compliance to

    the Audit Departments requirements for regular ITSCM assessments and reviews of tests and

    events for operational readiness.

    2.6.2. Disaster Recovery exercises

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    The objective the Disaster Recovery (DR) exercises is to demonstrate the ability to activate the

    production applications and IT environment at the alternate site, within the prescribed Recovery

    Time Objectives (RTO) and Recovery Point Objectives (RPO). These tests validate ITSs

    preparedness to recover operations.

    The DR exercises are conducted twice yearly, during a weekend, with the participation of all IT

    groups and Bank business lines to validate critical systems. The DR exercise has predefined

    conditions, control points, success criteria, and a strict command and control structure.

    A report on the test results is distributed to the COOP program, IT Management, and the Audit

    Department. This report measures compliance to Recovery Time and Recovery Point Objectives,

    quality of the individual test results and reports, and highlights updates required to IT plans and

    IT infrastructure.

    Results are analyzed to determinate if there are variations with the pre-determined level of

    services for the business, and to implement the necessary measures to mend deficiencies.

    2.6.3. Table top exercisesTable top exercises are paper base exercises and are conducted in ITS by ITSCM in preparation

    for the DR exercises. The objective is to identify gaps in the Disaster Recovery plans.

    2.7.COOP driven exercises2.7.1. Bank-wide continuity testsEvery two years the COOP Program Office conducts full-scale tests during business hours, while

    the business is conducting real business transactions at the alternate site. These tests utilize

    close-to-life scenarios and situational injects during the exercise, presenting a realistic and

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    challenging operating environment. The objective is to stress-test the continuity of operation

    plans (business continuity plans) for the departments; including ITS, and identify gaps in those

    plans.

    These exercises are designed with focus on specific situations, and objectives, and normally

    include exercise press releases, in paper and video, as part of the injects during the exercise.

    2.7.2. Call tree exercisesAs part of the ongoing business of individual departments for Bank-wide readiness, all

    departments and business lines must ensure that they maintain up-to-date contact information

    for all of their employees. As such, a Bank-wide Call Tree exercise is conducted once a year. In

    order to represent a realistic scenario, staff are requested not to alter their regular routine to

    accommodate this exercise.

    2.7.3. SimulationsThese are paper base exercises and are conducted by COOP Program Office. The objective of

    these one day exercises, utilizing close-to-life scenarios, is to train personnel and also to identify

    gaps in the continuity of operations plans.

    2.8.Evaluating our preparedness and responseTest result reports are reviewed by the Audit Department, and if required, observations are

    presented to the Bank Senior management. A review of results is conducted with the departments,

    and tasks are assigned to areas to follow-up on gaps found during the tests.

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    3. Lessons learned from the occurrence of real contingenciesThe occurrence of events has provided the occasion for the Bank to update and fine tune its contingency

    plans, policies, processes, communications, and decision-making in a real-time atmosphere, and allowed

    the Bank to test the effect of our response measures to support the critical processes of the Bank.

    A success factor for the Bank to deal with emerging risks has been the rapid reaction to, and

    implementation of, improvements to contingency plans. The use of information gathered in the BIA has

    provided an excellent tool to minimize the time to adapt plans to new risks as the Bank does not need to

    do the data gathering exercise when situations arise.

    In situations when the staff cannot access the Bank premises, either as a risk reduction measure or as a

    consequence (ie. 1998 - ice storm, 2002 - Severe Acute Respiratory Syndrome (SARS) outbreak, 2003 -

    Power outage, 2009 - Potential influenza pandemic), the Bank has adapted the continuity plans to deal

    with the reduction of staff and with the increase of remote access by taking the following actions:

    Identify key functions that would be affected by a shortage of staff

    Identify the minimum necessary number of staff for critical processes during peak periods Identification of pool of staff, from which to draw in case of staff shortage Identify processes that can be done by remote access (users at home), and processes that must be

    conducted on site.

    Implement response in stages for a shortage of staff or the need for social distancing Provide training in the use of personal protective equipment for staff that are identified as required

    to be on site to perform time critical processes

    Review dependencies on key suppliers

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    Revise policies and procedures for remote access, and strengthen processes to assure priorityaccess for critical processes in case of remote access bandwidth limitations

    Provide mobile devices to staff performing critical processes/services Implementation of flexible recovery workspace, that can be accessed from any Bank issued PC or

    from a user owned PC, providing a personalized work space that is not dependant on a pre-defined

    workstation

    In events that require staff to continue operations at the alternate site (ie. 2003 - Power outage, 2008 -

    Suspicious package deposited outside the Banks headquarters, 2010 Earthquake) the Bank has taken

    the following actions:

    Implemented split operations, to conduct pre-defined critical business functions from two sitessimultaneously

    Increased the capacity and redundancy for emergency power distribution (redundant dieselsgenerators); and sign agreements with vendors to guarantee fuel supply at primary and alternate

    sites

    Increased the capacity and redundancy for the Data Centers cooling Assured a minimum number of seats at the recovery site per department and also provide flexibility

    by increasing the number of workstations available for the departments by deploying a virtual

    workspace, which is a work space that is not dependant on a pre-defined workstation

    Strengthened the Incident Management Team structureand will be undertaking the following:

    Relocating the main data center away from Head Office Implementing lights-out Data Centers (all Data Center management will be done remotely)

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    In preparation for events that threatens IT security (ie. cyber attacks), the Bank has implemented an

    Enterprise Security Operation Centre (ESOC), whose objective is to provide centralized security incident

    and event management. The ESOC enables the Bank to take a proactive approach toward mitigating

    threats and protecting its assets by providing the following functions:

    real-time security monitoring and analysis of infrastructure for access control and policy breaches security incident management security metrics gathering, analysis, and reporting

    3.1.Continuous improvementAt the Bank, continuity programs are not only about technology or facilities loss. The scope has

    evolved to manage business disruptions, with a well established multitier approach to deal with

    situations that do or may disrupt critical business processes.

    Regular testing is a key part of our continuous improvement process, providing the means to

    identify gaps and to fine-tune plans, and for staff to learn by executing and testing their recovery

    procedures.