ISO 27001 & ISO 22301

Your management has given you the task to implement business continuity, but you’re not really sure how to do it? Although it is not an easy task, you can use the BS 25999-2 methodology to make your life easier – here are the main steps necessary to implement this standard:

1. Obtain management support

Although this is not a mandatory step in BS 25999-2, this is certainly the crucial step in the beginning – if the management does not understand the benefits of business continuity and is not committed to this project, your project is most probably going to fail.

2. Treat it as a project

It will take quite a lot of time and resources to set up your business continuity management system (BCMS) – you have to define clearly what needs to be done, in which timeframe, and what are the roles in project implementation. In other words, you have to apply project management methods.

3. Define objectives and scope; write down a BCM Policy

You have to define what is it you want to achieve with the BCMS – compliance, decreasing the level of risk, requirements of your customers/partners etc. You also have to define what you are going to include in your BCMS – the whole organization, or just a part of it. For instance, you may decide that you are going to include only your data centre if you are providing hosting services to your customers. All of these have to be documented in the BCM Policy.

4. Defining roles and responsibilities for BCMS

Because the BCMS is going to become a permanent activity in your organization, you have to define clear responsibilities for it, especially for the “sponsor” of the BCMS (someone accountable for the BCMS but not engaged in day-to-day BCMS activities) and “BCM coordinator”, “BCM manager” or something similar to it – one or more persons with active duties regarding the BCMS. It is the best to document these roles and responsibilities in your BCM Policy.

5. Implement mandatory procedures

BS 25999-2 requires the following four mandatory procedures to be implemented: document and records control, internal audit, preventive and corrective actions – these procedures are actually the foundation of your management system, similarly to ISO 27001 or ISO 9001.

6. Perform business impact analysis and risk assessment

Through business impact analysis you have to indentify the critical activities, their maximum tolerable period of disruption, the dependencies of those critical activities (including dependencies to suppliers and outsourcing partners), and set recovery time objectives.

By doing the risk assessment you actually find out what could be the causes to the disruption of your critical activities – those could be natural, but also man-made activities (either malicious or accidental). You would also need to do risk treatment, which means you need to decide how to decrease the possibility of something going wrong. Unfortunately, the risk assessment and treatment are not very well defined in this standard, so you might take a look at ISO 27001 which describes them in more detail.

7. Determining the business continuity strategy

Before you proceed with writing business continuity plans, you actually have to determine which resources you will need for resuming your critical activities – which people, locations, data, hardware, software, suppliers, outsourcing partners etc.

The business continuity strategy has to determine not only what you need, but also how you are going to provide those resources.

8. Developing incident management plans and business continuity plans

The purpose of incident management plans is to describe how you are going to respond directly to the occurrence of an incident (e.g. fire, earthquake, bomb threat, power failure etc.) in order to prevent it to spread, and to try to decrease its direct effects.

On the other hand, the purpose of business continuity plans is to describe how you are going to recover your critical activities – how you are going to put all the resources you have prepared into action. This means you have to describe who is going to do what, in which time, using which data and technology, in order to put your organization back into operation.

All of these plans have to be described in detail, because they must be executed even in case the main personnel is not available – therefore, they have to be written in such a way that somebody else would be able to execute them.

9. Training and awareness

You need to define the level of competence needed for the execution of business continuity plans in case of disruption, and then train all the personnel (both employees and external partners) to reach this level of competence.

However, this is not enough – you also need to explain to your personnel why BCM is necessary. Let’s face it – your business continuity plans will be used maybe only once in a life time, so most people consider it as a waste of time. Therefore, you have to explain to them why such a thing must exist. (See also How to deal with BCM sceptics)

10. BCMS exercising

If you thought you have written your plans perfectly, you are probably wrong – it is almost impossible to write a plan with no errors right at the beginning. This is why exercising is a mandatory part of BCMS – you have to test your plans in a situation that more or less resembles a real disruption. Only then will you find out what you planned well, and what you didn’t.

11. Maintaining and reviewing the BCMS

Another way to keep your BCMS up-to-date is by defining the intervals at which you will review your business continuity plans, but also other arrangements (e.g. contracts with suppliers and outsourcing partners, training and awareness etc.). There are all sorts of changes in the environment that are threatening your documentation to become obsolete – it is enough for an employee to leave the company to have an unusable telephone number in a plan if that person had a role in the BCMS.

It is also mandatory to perform post-incident review if an incident really occurred – the purpose is to find out how the organization really reacted – did it follow the plans or not.

12. Internal audit

The purpose of internal audit is to find out if there is something wrong, in an objective manner – the internal auditor should be a person who can find out if something is done wrong within your BCMS in order to correct it. If done properly, internal audit could be one of the best ways to improve your BCMS. (Read Dilemmas with ISO 27001 & BS 25999-2 internal auditors)

13. Management review

As said before, it is very important to get your management involved in the project – management review is designed exactly for that. The standard requires the management to examine all the relevant facts about BCM and decide whether it has fulfilled its purpose. Once that is done, the management has to decide which improvements must be made.

14. Preventive and corrective actions

The best thing would be to prevent mistakes (or in terms of BS 25999, the “non-conformities”) from happening – this is what the preventive actions are used for – they are a systematic way of correcting things before a problem occurs. Similar to preventive actions, there are also corrective actions which resolve the problem that has already occurred.

Now the question is – why would you use BS 25999-2? Although it is (still) not an international standard, it is the most popular standard for business continuity worldwide – the abovementioned steps are designed by the best business continuity experts, so if you want to implement the best accepted practices for business continuity, you have to look no further.

Here you can download the diagram of BS 25999-2 implementation process showing all these steps together with the required documentation (registration required).

Have you ever heard something like “It can’t be done”, “It has no use”, or “It’s useless if a major disaster occurs”? If you implemented business continuity management, you probably did. Naturally, such an attitude would not help your project, so here are some suggestions how to handle such people.

“If a major disaster occurs, we won’t be able to do anything”

This is probably the most common one. Well, they may be right, unless you really prepared your business continuity strategy and business continuity plans taking into account all the possible scenarios – if you did that, then you can explain to them that you have prepared an alternative site which is distant enough to withstand any kind of disaster, that you’ve made a backup copy of data, that there is a replacement for any employee in the company, that you have alternative suppliers for any critical service etc.

“If a nuclear war breaks out, it won’t work”

Well, unless you are a military supplier, it wouldn’t matter, would it? Basically, in this kind of catastrophic scenarios, your business probably wouldn’t have a purpose anymore.

“It has no use”

Just pray you’ll never have to use business continuity. Even without mentioning the well-known examples like 9/11 or Hurricane Katrina, it is enough to ask – have you ever experienced a power outage? Or did your server break down? Or maybe a PC with important data on it? Have you ever heard of a building that burned down completely? It is enough to read newspaper headlines to understand that those things can happen to anyone.

“We will do this only to satisfy the auditor”

Wrong priority. If you do it properly, you’ll protect yourself, and as a consequence your auditor will be happy.

“We can’t foresee all the incidents”

This is true, at least in the beginning. But if you perform your risk assessment right, use literature and various resources, and review the assessment regularly, the chances are that in time you’ll be able to take into account all the possible risks. Once you know them, you can prepare your response.

“In case of emergency, people will start looking after their families, not after the business”

True also. Who wouldn’t call his/her family first to see if they are all right in case of an earthquake? But if you plan very carefully who can go home right after an incident occurs and who must stay and resolve the situation, and if you take care of the family of the employees that must stay (e.g. by assigning some other employees to this task), then you’ve probably solved this problem.

“People will react irrationally in crisis situations”

Definitely true. But if you train your employees (and suppliers/partners) regularly, and if you exercise your business continuity plans, they will get used to stressful situations, and will probably respond in the right way if such situations occurs.

If you already implemented similar projects, you know how awareness is important – if your co-workers do not recognize the purpose of such projects, you will experience great difficulties with implementation. Not to mention that your project might altogether fail – this is why you need to consider awareness raising in advance.

You can also check out our webinar BS 25999-2 Foundations Part 2: Business Continuity Strategy which explains how to prepare for different disruption scenarios (commercially sold training).

You are thinking about implementing the business continuity management/BS 25999-2 standard? But then you hear it will cost you a lot? It probably will cost you, but not necessarily as much as you thought – this you can solve with good business continuity strategy.

Business continuity strategy, as defined in BS 25999-2 standard, is an “approach by an organization that will ensure its recovery and continuity in the face of a disaster or other major incident or business disruption”. Therefore, the point is to prepare yourself in the best possible manner to counteract a disaster if such would occur. This preparation can include organizational measures (drawing up plans, making contracts with suppliers/partners, exercising, reviewing, awareness raising, etc.), and measures including investment in equipment, infrastructure etc.

Time is a very important factor in recovery – if you do not recover your business in time, you will probably lose your customers and consequently lose your business as well. So the business continuity strategy must set the recovery time objective (RTO) for each of your critical activities, whereas RTO can be different for each of those.

One important consideration: the shorter the RTO, the bigger the investment you will need – for instance, if you want to recover your data centre in less than one hour, you will have to invest in an alternative location almost the same equipment as in the primary location; on the other hand, if you want to recover your data centre in two weeks, the investment will be much lower because it would be enough to store the backup tapes at the alternative location, allowing you two weeks to obtain the necessary equipment. All this means that your RTO must not be too long, but not too short either.

Once the RTO is set, you will still need to make some investment; however, with a good business continuity strategy you will be able to decrease that investment, while still being able to recover your critical activities within the recovery time objective. Here are some examples:

• you might not need your own data centre at an alternative location – in most countries you can rent such a location from a specialized company, which means you don’t need to invest in infrastructure, maybe not even in equipment or software,
• you might not need offices at an alternative location – employees who do not have to meet customers face-to-face can work from their homes,
• you might not need an alternative location at all if you have other business units at different locations which could take over the critical activities affected by the disaster,
• you might not need to purchase equipment in advance if you can find the supplier that could guarantee the delivery of equipment within your RTO,
• etc.

In all these examples you will need to increase your organizational capabilities, but if you want to save some money, it sure is something worth thinking about.

You can also check out our webinar BS 25999-2 Foundations Part 2: Business Continuity Strategy (commercially sold training).