Business Continuity Planning

Recent events have highlighted the need for all firms to have adequate Business Continuity Plans in place in order to cope with extraordinary events. These plans should be properly documented.

The purpose of a Business Continuity Plan is to provide a concise guide for staff on how to deal with an extraordinary event and of what alternative procedures need to be implemented to prevent this from causing an interruption to business. Business Continuity Plans are devised to minimise the impact on business, for example, of key staff not being physically available due to circumstances beyond their control. These plans should therefore establish arrangements for cover of key staff members and for example should encompass what alternative travel arrangements need to be in place so that these members of staff are available as soon as possible.

Business Continuity Plans should also cover other extraordinary scenarios such as not having physical access to business premises or major systems failures and the alternative arrangements available to remedy these obstacles. With this in mind the Business Continuity Plan should identify alternative premises at which staff can assemble and from where operations can continue should physical access to business premises be prevented for whatever reason. The plan should also cover such issues as record retrieval, for example, through adequate off-site back up facilities.
Given the varying nature of the business activities of firms, it is essentially up to the firm's Board and senior management to determine how best business continuity can be achieved. The Commission does however expect those provisions to be adequate for the nature of the business undertaken and that these be properly documented.

With this in mind and in line with the FSC's risk based approach to supervision, it is the intention of the risk review teams when conducting on-site visits of firms to verify the adequacy of these plans.