CSA CCM BCR-10
Response Plan Exercise

In a world where disasters can strike at any moment, it's crucial for organizations to have a well-rehearsed disaster response plan. The BCR-10 Control from the CSA Cloud Controls Matrix emphasizes the importance of regularly exercising this plan, ideally on an annual basis or whenever significant changes occur. By involving local emergency authorities in these exercises, organizations can ensure they are prepared for the unexpected.

Where did this come from?

CSA Cloud Controls Matrix v4.0.10 - 2023-09-26 [https://cloudsecurityalliance.org/artifacts/cloud-controls-matrix-v4]

The BCR-10 Control is part of the Business Continuity Management and Operational Resilience domain in the CSA Cloud Controls Matrix. This comprehensive framework provides a set of best practices for securing cloud computing environments. For more information on disaster recovery planning, check out the AWS documentation on the subject: [https://aws.amazon.com/disaster-recovery/]

Who should care?

  • Business continuity managers responsible for maintaining operational resilience
  • IT managers tasked with implementing and testing disaster recovery plans
  • Risk managers assessing the potential impact of disasters on the organization
  • Compliance officers ensuring adherence to regulatory requirements for disaster preparedness

What is the risk?

Failing to regularly exercise a disaster response plan can leave organizations unprepared when a real disaster strikes. This can lead to prolonged downtime, data loss, financial losses, reputational damage, and even legal consequences if regulatory requirements are not met. By regularly testing the plan, organizations can identify and address weaknesses before they become critical issues.

What's the care factor?

For organizations heavily reliant on technology and with a low tolerance for downtime, the care factor for BCR-10 should be high. The cost of being unprepared can far outweigh the time and resources required to regularly test the disaster response plan. However, for smaller organizations with less complex IT environments, the priority may be lower.

When is it relevant?

BCR-10 is most relevant for organizations operating in industries with strict uptime requirements, such as financial services, healthcare, and e-commerce. It's also crucial for organizations in regions prone to natural disasters or with geopolitical instability. However, for organizations with a highly resilient, distributed architecture and the ability to quickly spin up new environments, the need for extensive disaster response testing may be reduced.

What are the trade-offs?

Regularly exercising a disaster response plan requires significant time, resources, and coordination. It can be disruptive to normal operations and may require temporary systems downtime. There's also the risk of issues arising during testing that could impact production systems. However, these short-term costs and risks must be weighed against the potential long-term impact of being unprepared for a real disaster.

How to make it happen?

  1. Develop a comprehensive disaster response plan based on a thorough Business Impact Analysis (BIA).
  2. Identify key stakeholders, including IT, business continuity, and senior management, and assign roles and responsibilities for disaster response.
  3. Schedule annual disaster response exercises, involving local emergency authorities where possible.
  4. Design realistic disaster scenarios based on the organization's specific risks and vulnerabilities.
  5. Conduct tabletop exercises to walk through the disaster response plan step-by-step.
  6. Perform live testing of the plan, starting with individual components and building up to full-scale simulations.
  7. Document the results of each exercise, including any issues encountered and lessons learned.
  8. Update the disaster response plan based on the exercise findings.
  9. Communicate the updated plan to all relevant stakeholders.
  10. Repeat the process annually or upon significant changes to the organization or its IT environment.

What are some gotchas?

  • Ensure all necessary permissions are in place for the disaster response team to execute the plan. This may include permissions like ec2:StartInstances for spinning up new instances in AWS. Refer to the AWS documentation for the specific permissions required: [https://docs.aws.amazon.com/AWSEC2/latest/UserGuide/iam-policy-structure.html]
  • Make sure the disaster response plan is securely stored and accessible to the right people during a real disaster. Consider using a solution like AWS Systems Manager Parameter Store to securely store and manage the plan.
  • Be aware of any regulatory requirements for disaster response testing, such as the need for independent auditing or specific testing frequencies.
  • Don't neglect the human factor in disaster response. Ensure all team members are properly trained and prepared to execute their roles.

What are the alternatives?

An alternative to extensive disaster response plan testing is to design systems with inherent resilience and redundancy. This could include using multi-region or multi-cloud architectures, automated failover mechanisms, and real-time data replication. While these approaches can reduce the impact of disasters, they don't eliminate the need for testing altogether. A combination of resilient design and regular testing is often the best approach.

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