The Business Continuity Management Policy and Procedures control is all about making sure an organization has a solid plan in place to keep the lights on when bad stuff goes down. It's about documenting the who, what, where, when and how of maintaining critical operations during a disruption. The policy and procedures need to be regularly reviewed and updated to stay current.

Where did this come from?

This control comes from the CSA Cloud Controls Matrix v4.0.10 - 2023-09-26. You can download the full matrix here. The CCM provides a baseline of security controls that are relevant for cloud computing. It maps to other industry standards like ISO 27001, NIST SP 800-53, PCI DSS, and more.

For more guidance on business continuity planning, check out:

• NIST SP 800-34 Rev. 1 Contingency Planning Guide
• ISO 22301:2019 Business Continuity Management Systems

Who should care?

This control is relevant for:

• Business continuity managers looking to develop or improve their BCM program
• Risk managers needing to assess business continuity risks
• IT managers responsible for keeping systems and services available
• Compliance officers ensuring the organization aligns with relevant standards and regulations
• Senior executives who need to understand the organization's resilience posture

What is the risk?

Without an effective business continuity plan, an organization may experience:

• Prolonged downtime of critical systems and services
• Loss of revenue due to inability to do business
• Damage to reputation and customer trust
• Financial losses from penalties, lawsuits, and recovery costs
• Loss of valuable data assets

A robust BCM policy and procedure can significantly reduce the likelihood and impact of these adverse events by minimizing disruption and enabling timely recovery.

What's the care factor?

For most organizations, business continuity should be a high priority as the consequences of extended downtime can be severe. Even a few hours of disruption to critical services can result in substantial financial losses, angry customers, and reputational harm.

The level of care will depend on factors like:

• How critical the systems and data are to the business
• Contractual obligations for uptime/availability
• Compliance requirements (e.g. for regulated industries)
• Tolerance for risk and disruption

In general though, every organization should have a baseline BCM capability to handle common disruptive scenarios.

When is it relevant?

Having a BCM policy and procedure is relevant for:

• Organizations that rely on IT systems and data for critical business functions
• Cloud service providers who need to meet customer uptime expectations
• Industries with strict availability requirements (e.g. financial services, healthcare)
• Organizations operating in regions prone to natural disasters
• Businesses with complex supply chains or dependencies on third-parties

It may be less relevant for:

• Organizations with simple, non-critical IT environments
• Businesses that can tolerate extended downtime without major impact

What are the tradeoffs?

Implementing a comprehensive BCM program requires an investment in:

• Staff time to develop plans, procedures and documentation
• Training and awareness for employees
• Deploying redundant systems and backup infrastructure
• Regularly testing plans through exercises and simulations

Organizations need to balance the costs of preparedness with the risk of not having adequate business continuity capabilities. Overdoing BCM can lead to high costs and complexity. Under-investing can leave the organization exposed to disruption.

How to make it happen?

Some key steps to implement this control:

1. Assign a business continuity manager and form a steering committee with representatives from key departments.
2. Perform a business impact analysis (BIA) to identify critical systems, processes, and dependencies. Determine maximum tolerable downtime and recovery objectives.
3. Assess risks to business continuity such as natural disasters, cyberattacks, pandemics, supply chain disruption etc. Analyze likelihood and impact.
4. Develop BCM policy that aligns with organizational objectives and risk appetite. Have it approved by senior management and communicated to all staff.
5. Create business continuity plans for critical systems and processes. Document recovery procedures, communication protocols, alternate facilities, etc.
6. Implement redundancy and fault tolerance for key IT infrastructure. Use cloud for scalable capacity. Have offline backups.
7. Provide training to staff on their roles and responsibilities during an incident. Conduct regular awareness sessions.
8. Exercise and test plans regularly to validate effectiveness and identify gaps. Update plans based on lessons learned.
9. Monitor and audit business continuity capability. Track relevant KPIs/KRIs. Report to management on program effectiveness.
10. Review and update BCM policy and plans at least annually and whenever there are significant changes to the environment.

What are some gotchas?

Some key things to watch out for:

• Lack of management buy-in and support for the BCM program
• Outdated or untested continuity plans that don't reflect current environment
• Poorly defined roles and responsibilities leading to confusion during an incident
• Missing key stakeholders and dependencies in planning
• Inadequate redundancy and fault tolerance in IT architecture
• No off-site or offline backups of critical data
• Staff being unaware of plans and procedures

To implement continuity capabilities in AWS, you will need relevant permissions for services like:

• EC2 for deploying redundant servers (docs)
• RDS for database replication and failover (docs)
• S3 for storing backups and replicating data across regions (docs)

What are the alternatives?

Some alternatives and complements to this control:

• Disaster Recovery Plan focused specifically on recovery from a major incident
• Pandemic Response Plan for maintaining operations during disease outbreaks
• Crisis Management and Communication Plan for coordinating response and messaging

Organizations can also outsource business continuity to a third-party provider for additional support and expertise.

Explore Further

• ISO 22301:2019 - Security and resilience — Business continuity management systems — Requirements
• NIST SP 800-34 Rev. 1 - Contingency Planning Guide for Federal Information Systems)
• CIS Control 10 - Data Recovery - Ensure data integrity and availability through regular backup and recovery
• CIS Control 11 - Network Infrastructure Management - Actively manage network infrastructure and connectivity

I hope this comprehensive article gives you a solid understanding of BCR-01 and how to implement it in practice. Let me know if you have any other questions!