Welcome » IT Booklets » Business Continuity Planning » Appendix D: Pandemic Planning
Pandemics are defined as epidemics or outbreaks in humans of infectious diseases that have the ability to spread rapidly over large areas, possibly worldwide. Several pandemics have occurred throughout history, and experts predict that we will experience at least one pandemic outbreak in this century.
The current threat originates from an outbreak of avian flu in Asia. It is unknown if an avian virus will result in a human pandemic. The widespread nature of this virus in birds and the possibility that it may mutate over time raise concerns that it will become transmissible among humans, with potentially devastating consequences. The united Sates Government has issued a National Strategy that discusses the threat and potential impact of a pandemic influenza event. The implementation Plan for the National Strategy identifies roles and responsibilities for the federal government, the private sector, and others.
The adverse economic effects of a pandemic could be significant, both nationally and internationally. Due to their crucial financial and economic role, financial institutions should have plans in place that describe how they will manage through a pandemic event. Sound planning should minimize the disruptions to the local and national economy and should help the institution maintain the trust and confidence of its customers.
DIFFERENCES BETWEEN TRADITIONAL BUSINESS CONTINUITY PLANNING AND PANDEMIC PLANNING
There are distinct differences between pandemic planning and traditional business continuity planning. When developing business continuity plans, financial institution management typically considers the effect of various natural or man-made disasters that differ in their severity. These disasters may or may not be predictable, but they are usually short in duration or limited in scope.As evidenced by Hurricane Katrina, while the duration of a specific natural disaster may be relatively brief, the social and economic recovery from such events can be prolonged. In most cases, malicious activity, technical disruptions, and natural/man-made disasters typically will only affect a specific geographic area, facility, or system. These threats can usually be mitigated by focusing on resiliency and recovery considerations.
Pandemic planning presents unique challenges to financial institution management when developing their continuity plans. Unlike natural disasters, technical disasters, malicious acts, or terrorist events, the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration. The nature of the global economy virtually ensures that the effects of a pandemic event will be widespread and threaten not just a limited geographical region or area, but potentially every continent. In addition, while traditional disasters and disruptions normally have limited time durations, pandemics generally occur in multiple waves, each lasting two to three months. Consequently, no individual or organization is safe from the adverse effects that might result from a pandemic event will be staffing shortages due to absenteeism. These differences and challenges highlight the need for all financial institutions, no matter their size, to plan for a pandemic event when developing their BCP.
Pandemic plans should be sufficiently flexible to effectively address a wide range of possible effects that could result from a pandemic. Pandemic plans need to reflect the institution's size, complexity, and business activities. The potential impact of a pandemic on the delivery of a financial institution's critical financial services should be incorporated into the ongoing business impact analysis and risk assessment processes. The institution's BCP should then be revised, if needed, to reflect the conclusions of its business impact analysis and risk assessment.
To address the unique challenges posed by a pandemic. The financial institution's BCP should provide for:
The traditional BCP methodologies detailed in the FFIEC's Business Continuity Planning booklet provide a sound framework for institutions of all types in developing plans for pandemic events. Institutions should review the following:
PHASES: PLANNING, PREPARING, RESPONDING, AND RECOVERING
Traditional business continuity and pandemic planning require management to follow a cyclical process of planning, preparing, responding, and recovering. However, pandemic planning requires additional actions to identify and prioritize essential functions, employees, and resources within the institution and across other business sectors. The issues discussed below highlight the specific challenges faced by management and the mitigating controls that should be considered when developing a pandemic plan.
BOARD AND SENIOR MANAGEMENT RESPONSIBILITIES
As with other BCP activities, pandemic planning should not be viewed as solely an Information Technology (IT) issue, but rather as a significant risk to the entire business. As such, an institution's pandemic planning activities should involve senior business management from all functional, business and product areas, including administrative, human resources, legal, IT support functions, and key product lines.
An institution's board of directors is responsible for overseeing the development of the pandemic plan. The board or a committee thereof should also approve the institution's written plan and ensure that senior management is investing sufficient resources into planning, monitoring, and testing the final plan. Senior management is responsible for developing the pandemic plan and translating the plan into specific policies, processes, and procedures.
Senior management is also responsible for communicating the plan throughout the institutions to ensure consistent understanding of the key elements of the plan and to ensure that employees understand their role and responsibilities in responding to a pandemic event. Finally, senior management is responsible for ensuring that the plan is regularly tested and remains relevant to the scope and complexity of the institution's operations.
INCORPORATING PANDEMIC RISK INTO THE BUSINESS IMPACT ANALYSIS (BIA)
The potential effects of a pandemic should be a part of the financial institution's overall BCP business impact analysis (BIA). The BIA should:
Incorporating the impact of pandemic risk into the institution's BCP involves additional complexity since typical disaster or emergency response mechanisms and methods may not be feasible. For example, moving employees to an alternate facility that is typically used during a natural disaster or other emergency, may not be an appropriate or feasible way to continue operations in a pandemic. There may be a shortage of available staff to relocate and it is possible that the alternate site might be affected by the pandemic. DHS provides a list of twelve planning assumptions that institutions should consider when developing the impact analysis.See The National Implementation Plan at http://www.pandemicflu.gov/plan/community/commitigation.html.
The pandemic issues considered in the impact analysis also should involve forecasting employee absenteeism and considering family care issues that may affect business operations.See The National Implementation Plan at http://www.pandemicflu.gov/plan/community/commitigation.html. DHS believes rates of absenteeism will depend on the severity of the pandemic. In a severe pandemic, absenteeism attributable to illness, the need to care for ill family members and fear of infection may reach 40 percent during the peak weeks of a community outbreak, with lower rates of absenteeism during the weeks before and after the peak. Certain public health measures (e.g. closing schools, quarantining household contacts of infected individuals, or altering or ceasing public transportation schedules) are likely to increase the rate of absenteeism.
A key part of an institution's BIA that addresses pandemics is to examine external factors. For example, assessing the impact of critical interdependencies will involve making planning assumptions regarding the availability of external services and prioritizing the effect of possible disruptions. In addition, potential travel restrictions imposed by health and emergency management officials may limit access to those services, even if they are still operating.
RISK ASSESSMENT/RISK MANAGEMENT
As noted in the main body of this booklet, the institution's risk assessment process is critical and has a significant bearing on whether BCP efforts will be successful. Important risk assessment and risk management steps that are important for pandemic planning include;
Coordination with Outside Parties
Open communication and coordination with outside groups, including critical service providers is an important aspect of pandemic planning. Financial institutions should coordinate information sharing efforts through participation in business and community working groups and develop coalitions with outside parties to provide support and maintenance for vital services during a pandemic. Efforts could include consideration of cooperative arrangements with other financial institutions within the institution's geographical trade area. In addition, management should coordinate its pandemic planning efforts with local public health and emergency management teams, identify authorities that can take specific actions (e.g., who has the ability to close a building or alter transportation), and plan to alert local and state agencies regarding significant employee absenteeism that may be caused by a sudden pandemic outbreak. Communication with customers and the media is also critical to ensure that accurate information is disseminated about business operations.
Critical interdependency challenges require management to ensure an adequate reserve of essential supplies and to proactively manage maintenance of equipment to ensure sustainability during potential weakness in the service and supply chains, and develop potential alternatives for obtaining critical service and supplies.
Triggering Events
Identification of A triggering event occurs when an environmental change takes place that requires management to implement its response plans based on the pandemic alert status. Alerts may be issued by various organizations that have developed surveillance systems to monitor the progression of viral outbreaks. Depending on the severity of the alert, management may need to act quickly to implement elements of its pandemic response plans. Therefore, it is important for financial institution management to monitor national and international pandemic news sources in order to be aware of potential outbreaks. Management should monitor websites devoted to national health care issues, identify key points of contact for emergency and health care organizations, and assess potential implications for the financial institution if a pandemic occurs. Management also should communicate to employees and key service providers the actions it plans to take at specific triggering points.
Employee Protection Strategies
Employee protection strategies are crucial to sustain an adequate workforce during a pandemic. Institutions should promote employee awareness by communicating the risks of a pandemic outbreak and discussing the steps employees can take to reduce the likelihood of contracting a pandemic virus. The following risk management strategies should also be considered:
Mitigating Controls
Despite the unique challenges posed by a pandemic, there are control processes that management can implement to mitigate risk and the effects of a pandemic. For example, to overcome some of the personnel challenges, management should ensure that employees are cross-trained and that succession plans have been developed. The institution may be able to leverage plans already established as part of traditional business continuity planning.
Remote Access
During a pandemic there may be a high-reliance on employees telecommuting, which could put a strain on remote access capabilities such as capacity, bandwidth, and authentication mechanisms. Moreover, employees who typically work onsite may not have remote access authority or the necessary technology infrastructure to work at home. Analysis of remote access capabilities, mapping of related technology infrastructure to employee needs during a pandemic, assessing the infrastructure at the neighborhood level, and considering internal and external capacity are necessary to help ensure telecommuting strategies will work during a pandemic.
RISK MONITORING AND TESTING
As information from medical and governmental experts about the causes and effects of a pandemic continues to evolve, and institution's pandemic plan must be sufficiently flexible to incorporate new information and risk mitigation approaches. As a result, risk monitoring and testing of the pandemic plan is important to the overall planning process. A key challenge for management is developing a testing program that provides a high degree of assurance that critical business processes, including, supporting infrastructure, systems, and applications, will function even during a severe pandemic.
A robust program should incorporate testing:
Test results should be reported to management, with appropriate updates made to the pandemics plan and testing program.
Testing for a pandemic may require variations to the scope of traditional disaster recovery and business continuity testing, as potential test scenarios will most likely be different. Alternatives for pandemic testing can include: well orchestrated "work at home" days for critical and essential employees to test remote access capabilities and infrastructure; crisis management team communication exercises; table top exercises that test various scenarios related to escalated absenteeism rates; additional or modified call-tree exercises; and community, regional or industry-wide exercises with members of the financial services sector to test the financial sector's ability to respond to a pandemic-like crisis.
REFERENCES
In addition to references included above, institutions may find these web sites helpful in their pandemic planning activities: