Now that all financial institutions (FIs) are in the midst of navigating through the COVID-19 world, the execution of their Business Continuity Plan (BCP) and Pandemic Plan are in full gear.
This is an open letter to those of you that are responsible for the development, testing, maintenance and execution of the BCP within your organizations.
At some banks and credit unions, that can be one individual, and in others, it may be by committee. In either case, now is the time to seize the moment and update your BCP in a real-time environment.
For the past 20 years, I have been a member of the BCP consulting team at Jack Henry and before that, was at IBM. My experience has been in assisting many FIs with the development and testing of their BCP. Testing BCPs involves executing test scenarios that include both natural and man-made disasters, ranging from tornadoes, hurricanes, regional and national power outages, cyber, terrorist attacks, etc. And yes, pandemic outbreaks.
On many occasions I also have conducted exercises that simulated a pandemic. The good news is that because we conducted those drills, many banks and credit unions are now able to develop their pandemic plan, which went into effect once the COVID-19 pandemic broke out.
Some of the subjects addressed include:
- Forming a pandemic crisis team
- Communications with employees, customers/members, heath agencies, regulators, etc.
- Managing absenteeism
- Cross training of employees
- Working from home criteria
- Maximizing the use of online channels
- Social distancing
- Working with governmental agencies
One thing to keep in mind is that under a test simulation, what can be learned and implemented to enhance the BCP is limited. Simulating all of the events and variables that would occur in a real pandemic, or any disaster event for that matter, is impossible.
Simulation testing only touches the surface of the onion, and only at times reaches beneath the skin. It is underneath where we identify and capture the information required to make our plans stronger.
The best means to improve your BCP is not only through testing but also by being involved in an actual disaster event itself as it is unfolding. You may not realize it, but you are currently in the process of peeling back the onion day-by-day as you develop new procedures and tasks to manage your organization’s response to a pandemic.
It is these procedures and tasks that you must take the time to document while you navigate through this new normal.
Let’s face it, at some point we may find ourselves in a similar position again and the lessons we learn today can help us better manage disaster events tomorrow. By dynamically updating the plan, we will be able to utilize and validate the changes when we conduct our annual tests.
Bottom line, in my decades assisting organizations in disaster preparation, I have never seen an event of this magnitude.
Although I hope this will be the worst disaster that we will ever have to face, there is no guarantee that it will be. So, my recommendation is to take advantage of these times to make your FI’s BCP stronger than it has ever been.
While it’s a disaster event itself, it’s also a stress test of your people and your BCP. Use this time to analyze your BCP program as a whole and honestly determine if it was, and is adequate to deal with this pandemic, and whether it be effective for dealing with future incidents.
On a final note, I want to compliment and thank all of you that are doing your part to serve your communities. This includes all the employees of community banks and credit unions, vendors, regulators, and other organizations that support us.
Your efforts have not gone unnoticed. And your customers or members, appreciate the sacrifices that you endure to ensure that our financial sector remains strong and resilient. Thank You.
Tom Williams
Business Continuity Strategy Manager – Gladiator BCP Consulting Team
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