Along with disaster recovery, building a business continuity plan is an essential part of the incident response management process. By providing a redundant set of resources and processes for operation, business continuity planning helps businesses deliver their products and services after a catastrophe strikes.

But business continuity planning is difficult under the best of circumstances, requiring sustained, organization-wide communication and coordination. Regulatory compliance standards such as FINRA/SEC, HIPAA, and PCI-DSS add layers of complexity and uncertainty to the planning process that many in-house teams are unprepared to manage.

  • HIPAA states that healthcare providers “must maintain a quickly actionable contingency plan for establishing and operating an emergency base of operations during a crisis,” with the possibility of non-compliance fines in egregious cases of downtime.
  • Similarly, FINRA rule 4370 outlines very clear requirements for businesses to “create and maintain a written business continuity plan identifying procedures relating to an emergency or significant business disruption.”

In this blog, we’ll go over some of the common pain points and explain what businesses can do to build business continuity plans that satisfy their compliance requirements.

Integrate Compliance into Business Impact Analyses and Risk Assessments

The first step in the business continuity planning phase is to conduct a risk assessment and business impact analysis.

These two distinct steps help you identify the most important risk to your business and understand what fines and damages your business would incur if one of those catastrophes were to compromise your systems. Understanding these two things helps your team allocate budget and build a business continuity plan that is built to support your compliance goals.

There are many great resources on running a business impact assessment elsewhere online, including this resource from the Federal Government. But to ensure you integrate your compliance requirements into this phase, address the following points.

  • Identify gaps in compliance agreements.
    Analyze compliance requirements, then document how those compliance technical controls will affect your compliance processes. Often businesses without in-house technical expertise will find that security controls such as firewall configuration, access management, or hardware configurations are not aligned with their compliance objectives.
  • Focus on technical interdependencies
    Compliance can expose your organization to a wide range of complex issues around interdependency. Take, for example, healthcare organizations contending with HIPAA and HITECH compliance. Could extended downtime at a business associate force your business into non-compliance? What happens to personal mobile phones and their data if a centralized management service is compromised? Carefully analyze each system and its downstream and upstream processes to locate compliance risk areas.
  • Track the flow of protected data
    Modern businesses create and store vast amounts of information every day. In many regulated businesses, a significant portion of that data is subject to regulatory compliance requirements. Without full transparency into how data flows through your organization, a business continuity plan will fail to protect that sensitive information, which means that any risk assessment must follow sensitive data to wherever it travels in your network.

Regulatory compliance concerns are a serious liability and should be accounted for in your business continuity planning. To achieve total confidence, the Complete Network team recommends having documented business continuity plans to address all your most urgent threats, including ransomware attacks, hardware failure, or loss of a primary data center.

Define Roles and Responsibilities

In the best of circumstances, knowing who will be responsible for what systems after catastrophe strikes can be difficult. Those difficulties increase exponentially after you factor personally identifiable information (PII) and other protected data into the equation. Here are some common scenarios.

Are front-line staff at a secondary office location authorized to handle the data on the network systems that they have been assigned? Some businesses may feel they have done an effective job keeping digital data away from unauthorized staff, then soon realize that paper records like bills and invoices have unique compliance requirements.

What are the lines of escalation for issues related to PII when primary communication channels are impaired? To answer this question, you will want to ensure that encryption, multi-factor authentication, and other security controls are sufficient at each of your sites and that all personnel has been assigned the correct permissions to perform their work tasks if they’re forced to work from the backup location.

Ensure Strong Data Governance Across Primary and Secondary Sites

PII and its healthcare counterpoint electronically protected health information (ePHI) now move through computer networks faster and more fluidly than ever before. That data must be properly managed and tracked as it moves through a system, or you risk exposing yourself to compliance risks when triggering a business continuity plan.

Let’s take cloud platforms as an example. Many backup and disaster recovery solutions will feature functionality for keeping data secure at rest. At the same time, in their systems, but that doesn’t mean that the data in transit between your on-premise systems and cloud systems, or primary office locations and secondary hot sites, is always secure.

To keep in-transit data safe, you must deploy the appropriate tools, such as secure VPN tunnels, properly-configured firewalls, and the appropriate multi-factor authentication systems.

Beyond just the confidentiality and accessibility, you will also want to make sure that the integrity of the data is maintained throughout the business continuity process. This includes ensuring that proper audit trails and change controls are applied to data so that you can understand if data has been altered while working from backup systems.

Manage Compliance and Business Continuity with a Trusted Partner

Despite the central importance of business continuity, too many organizations fail to do the required due diligence to align those programs. Many fail due to a lack of business continuity expertise.

The good news is that you don’t have to approach continuity planning or regulatory compliance alone.

The Complete Network virtual chief information officer (vCIO) brings decades of compliance experience to regulated organizations of all sizes. We can help you assess your risk, implement the right administrative and technical controls, then maintain your continuity plan as your business and goals evolve.

Contact our friendly Complete Network team any time at (844) 426-7844. We look forward to chatting with you!

How To Supplement Your Internal IT Team.

In an ideal world, technology would be a consistent source of competitive advantage and benefit for small and midsized businesses. The reality is that many fail to realize that confidence.

Without the right resources and support, even a highly skilled technology team can become overwhelmed by the growing list of technology management duties. When important tasks get neglected, it creates ripple effects throughout an organization that damage productivity and efficiency.

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