Role of IA in BCP

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    The Role of Internal AuditIn Business Continuity Planning

    Dan Bailey, MBCP

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    Dan Bailey, MBCPSenior ManagerProtiviti [email protected]

    Actively involved in the Information Technology industry since 1984

    Actively involved in the Business Continuity industry since 1991 Received CBCP designation in 1999; MBCP designation in 2002 Co-Founder of the Arkansas chapter of the Association of Contingency

    Planners 2002 President of the North Texas chapter of the Association of

    Contingency Planners 2003-2005 DRI International Certification Commissioner 2006-2008 DRI International Vice-Chair of the newly established Education

    Commission

    Introduction

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    Agenda

    Establishing A Framework Internal Audit Adding Value to the BCP

    Process Information Available to the Internal Auditor Proven Approaches to Conducting a BCP Audit SOX Section 404? Wrap-up and Summary

    By 2008, we believe more than 50% of the G2000 will have robust and tested BC plans, with the remainder attempting toenhance their capabilities beyond rudimentary BC and disaster recovery through 2012. - META Group (February 2003)

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    Section I

    Establishing A Framework

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    BCM = Crisis Management + Business Resumption Planning + IT Disaster Recovery Planning

    the development of strategies, plans andactions which provide protection or alternativemodes of operation for those activities orbusiness processes which, if they were to beinterrupted, might otherwise bring about aseriously damaging or potentially fatal loss to theenterprise.

    Business Continuity Management Defined

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    Components of A Business Continuity Process

    Contract Termsand Conditionswith Suppliers

    CustomerService LevelAgreements

    GovernanceDocumentation

    - ProcessAccountability

    - RecurringActivities

    - DocumentationStandards

    - Strategy Testing- Training &

    Awareness- Plan

    Maintenance

    - Successionplans

    Audit CommitteeOversight

    Executive MgmtSponsorship

    BusinessContinuityCoordinator

    Crisis MgmtTeam

    BusinessRecoveryCoordinators

    IT DRCoordinators Recovery Teams Internal Audit

    Oversight Industry /

    Governmental

    Oversight

    RiskAssessmentConclusions(Likelihood andVulnerability)

    Business ImpactAnalysisConclusions(RecoveryObjectives)

    Strategy DesignOptions

    Strategy Cost-Benefit Analysis

    Strategy TestResults

    Diagnostic andBenchmarkingConclusions

    BusinessContinuityGovernanceDesign and DataGathering

    RiskAssessment

    Business ImpactAnalysis

    Strategy Design Plan

    Documentation

    Plan Validation KnowledgeTransfer /Implementation

    DocumentationRepository

    PlanDocumentationSoftware

    Risk AssessmentConclusions

    Business ImpactAnalysisConclusions

    Backup /ReplicationSoftware (IT DROnly)

    IT Hardware

    EmergencyResponse

    Crisis Mgmt Crisis

    Communications

    BusinessResumptionPlanning

    IT DR Planning Business Impact

    Analysis Risk Assessment

    BusinessContinuityStrategy Testing

    Training &Awareness

    Supplier RiskMgmt

    BusinessStrategies &

    Policies

    Business &Risk

    ManagementProcesses

    People &Organizational

    Structure

    ManagementReports Methodologies

    Systems & Data

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    The Continuity Life Cycle

    Risk Assessment

    Business Impact Analysis

    Business Continuity

    Strategy Design

    Project Initiation And Management

    Solutions Deployment

    Compliance Monitoring & Auditing

    Training & Awareness Programs

    ContinuityLife Cycle

    Solutions Deployment & Plan Documentation

    Business Continuity Plan Testing

    Typical Participants in thePlanning Process: Executive Sponsor Steering Committee Business Continuity

    Coordinator Business Process

    Owners

    InformationTechnology Human Resources Facilities Security EHS Legal Corporate

    Communications Risk Management Internal Audit?

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    Managing Business Continuity

    Finance Direct Report to CFO Risk Management / Loss

    Prevention Executive Council

    Legal Human Resources Corporate Communications

    Operations Direct Report to the COO EHS Security

    Information Technology Internal Audit

    E f f e c t i v

    e n e s

    s

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    Asked if a plan was in place

    Reviewed the (IT Disaster Recovery) plan forcurrency, if they were truly IT Auditors

    Asked if tests were performed; didnt reviewthe results

    Occasionally owned the BCP process!

    In the Past, The Internal Auditor

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    The Continuity Life Cycle - Revisited

    Risk Assessment

    Business Impact Analysis

    Business ContinuityStrategy Design

    Project Initiation And Management

    Solutions Deployment

    Compliance Monitoring & Auditing

    Training & Awareness Programs ContinuityLife Cycle

    Solutions Deployment & Plan Documentation

    Business Continuity Plan Testing

    Ways In Which the Internal Auditor CanAdd Value to the BCP Process: Keeping Management Informed on

    Progress Toward BCM Developmentand Implementation

    The Internal Sales Person Makingthe Case for Business Continuity

    Participation in the RiskAssessment and BusinessImpact Analysis

    Defining Key Business Functions ByAssisting with the BIA

    Defining Key Controls and Guide

    Toward a Process, not a Plan Project Management Standards Help Craft Maturity Levels and

    Definitions Audit the BCP Process Initially and

    in the Future

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    Section III

    Information Available to theInternal Auditor

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    Guidance from the IIA www.theiia.org

    Business

    ContinuityManagement

    Auditors should evaluate business continuity readiness Internal audit should assess the organization's

    business continuity process on a regular basis provide preparedness summary to senior management

    Internal auditors can play a role in the organizationsplanning, to include the risk assessment Internal audit activity can help with an assessment

    of an organization's internal and externalenvironment

    Evaluate the BCP/DRP during formulation Internal auditors have a thorough understanding

    of the business, the individual functions andinterdependent relationships

    Practice Advisory 2110-2: Internal Audits Role in the Business Continuity Process

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    Guidance from the IIA (cont.)

    Business

    ContinuityManagement

    Review the proposed business continuity and disasterrecovery plans for design, completeness, and overalladequacy

    During that recovery period: Internal audit should monitor the effectiveness of

    the recovery and control of operations Recommend improvements to the BCP Internal audit can also provide support during the

    recovery activities internal auditors can assist in identifying the

    lessons learned from the disaster and therecovery operations

    Periodically audit the organization's BCPs/DRPs

    Adequacy to ensure the timely resumption ofoperations and processes after adversecircumstances

    Reflects the current business operatingenvironment

    Practice Advisory 2110-2: Internal Audits Role in the Business Continuity Process

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    Guidance from the IIA (cont.)

    Business

    ContinuityManagement

    During the audit, Internal Audit should consider : Are all plans up to date? Are all critical business functions and systems

    covered? Are the plans based on the risks and potential

    consequences of business interruptions?

    Are the plans fully documented? Have functional responsibilities been assigned? Is the organization capable of and prepared to

    implement the plans? Are the plans tested and revised based on the

    results?

    Are the plans stored properly and safely? Is thestorage location known? Are the locations of alternate facilities (backup

    sites) known to employees? Do the plans call for coordination with local

    emergency services?

    Practice Advisory 2110-2: Internal Audits Role in the Business Continuity Process

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    Standards and Guidelines COBIT

    FFIEC NIST ISO 9000 & 14000, QS 9000 ISO 17799 NFPA 1600 DRI International

    BCI PAS 56 ITIL Homeland Security COSO

    Regulations and Standards

    Regulatory Requirements Sarbanes Oxley (Governance)

    FEMA FERC JCAHO HIPAA GLBA FFIEC (Updated) OSHA SEC NYSE / NASD State Insurance Departments USA PATRIOT Act IRS Australian/New Zealand Standard

    AS/NZS 4360:1999 California 1386 BASEL II Public Utility Commissions FCC

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    Section IV

    Proven Approaches toConducting a BCP Audit

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    Work in a Collaborative Manner (Advise/Teach)

    Understand the History of BCP, ManagementObjectives and the Level of Maturity Up Front

    Understand the Scope of Business Continuity Approach From a Process Perspective, as Opposed to

    a Documentation Review

    Look for and assess key success factors such asrepeatability, extensibility and maintainability

    Focus on the Entire BCM Life-cycle, Ranging fromStandards Assessments Through Plan Testing

    Brainstorm Ideas for Improvement Engage the

    Business Continuity Coordinator

    A Proven Practice BCP Audit Approach

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    Evaluate the Following: Standards, Policies and Procedures Relationships with External Agencies

    and Authorities Training and Awareness Materials Budgetary Documentation Documented plans Recovery Location / Hot-site Contracts Test Results Service Level Agreements Regulatory Requirements

    Supply Chain / Vendors Network

    Executing A Process Oriented BCP Audit

    A Comprehensive Business ContinuityManagement Process Includes: Crisis Management Crisis Communications Business Resumption Planning IT Disaster Recovery Planning

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    The Assessment Approach

    The Approach Confirm Assessment Expectations / Collect Business Requirements Evaluate the Business Continuity Process

    Process Management Risk Assessment and Business Impact Analysis

    Define Recovery Strategies and Business Continuity Procedures Training and Awareness, Plan Testing Process, Auditing and Plan

    Maintenance Collect Benchmarking Data to Reinforce Findings Validate, Present and Report

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    Nothing Reinforces a Recommendation Like Benchmarking Data Same Industry Same Size Company

    We maintain information in the following areas: BCM Process Description and Scope Who Owns the BCM Process

    Budgetary Data Number of Personnel Addressing Business Continuity Recovery Objectives (Business and IT)

    Benchmarking Data Is Available Through Third-party Specialists, Vendors andInformal Contacts (Like This Session)

    Industry Benchmarking Data

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    In addition to a review of documentation, werecommend discussions with Business

    Continuity Management owners, as well as theBusiness Process owners whom they support(In order to better understand their expectations)

    Participants in the BCP Audit

    Business

    ContinuityManagement

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    Presenting the Findings

    Business

    ContinuityManagement

    Reinforce Scope and Focus Focus on Process Maturity Highlight Strengths and Weaknesses

    Tie Findings to Business Impact, to IncludeRegulatory Compliance

    Provide Action Items and Recommend Points ofContact for Each

    Offer to Track Completion of Each Finding /Action Item

    Next Steps What Will Next Years Audit FocusOn?

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    Section V

    Sarbanes Oxley?

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    Internal Audit and SOX Section 404?

    Section 404 had become a driver for conducting some audits Standard may change audit priority Business continuity will remain a key business issue regardless of Section 404

    scope

    Furthermore, managements plans that could potentially affect financial reporting infuture periods are not controls. For example, a companys business continuity or

    contingency planning has no effect on the companys current abilities to initiate,authorize, record, process, or report financial data. Therefore, a companys businesscontinuity or contingency planning is not part of internal control over financial reporting.

    PCAOB Release No. 2004-001, March 9, 2004

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    Section V

    Presentation Summary

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    Wrap-up and Summary

    Business

    ContinuityManagement

    Establishing A Framework What is Business Continuity? Components of a Business Continuity Process

    The Business Continuity Life Cycle The BCP Maturity Continuum

    Internal Audit Adding Value to the BCP Process In the Past Today: Revisiting the Continuity Life Cycle

    Information Available to the Internal Auditor Regulations and Standards

    Proven Approaches to Conducting a BCP Audit Why Conduct An Audit? Proven Practice Audit Approaches Executing A Process Oriented BCP Audit Participants in the BCP Audit Industry Benchmarking Presenting Findings

    Wrap-up and Summary

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    Questions & Answers

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    Dan Bailey, MBCPProtiviti Inc.

    Senior ManagerNational Leadership Team - Business Continuity Management Services

    [email protected] (office)

    214.207.4543 (mobile)

    Contact Information