Business Continuity Management Framework

Saudi Arabian Monetary Authority
February 2017
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Table of contents

1.1 Introduction to the BCM Framework ................................................................................................. 3
1.2 Definitions .......................................................................................................................................... 3
1.3 Scope.................................................................................................................................................. 3
1.4 Applicability ........................................................................................................................................ 3
1.5 Responsibilities ................................................................................................................................... 4
1.6 Interpretation...................................................................................................................................... 4
1.7 Target Audience.................................................................................................................................. 4
1.8 Review, Changes and Maintenance ................................................................................................... 4
1.9 Reading Guide .................................................................................................................................... 4
2 Business Continuity Requirements ........................................................................................................ 5
2.1 BCM Governance ................................................................................................................................ 5
2.2 BCM Strategy ...................................................................................................................................... 5
2.3 Business Continuity Policy .................................................................................................................. 6
2.4 Business Impact Analysis (BIA) and Risk Assessment (RA) ................................................................ 6
2.5 Business Continuity Plan (BCP) ........................................................................................................... 7
2.6 IT Disaster Recovery Plan (DRP)......................................................................................................... 8
2.7 Cyber Resilience .................................................................................................................................. 9
2.8 Crisis Management Plan ..................................................................................................................... 10
2.9 Testing ................................................................................................................................................ 11
2.9.1 BCP testing....................................................................................................................................... 11
2.9.2 DRP testing ...................................................................................................................................... 11
2.9.3 Executed tests .................................................................................................................................. 11
2.10 Awareness and training..................................................................................................................... 12
2.11 Communication.................................................................................................................................. 12
2.12 Periodic Documents Review .............................................................................................................. 13
2.13 Assurance .......................................................................................................................................... 13

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Introduction

1.1 Introduction to the BCM Framework

Considering the need of 24 x 7 availability of the business operations by financial institutions in the Kingdom of Saudi Arabia, SAMA has developed a Business Continuity Management (BCM) framework for member organizations that would enhance the organizational resilience capability to ensure continuity and availability of their operations and services. The requirements are based on SAMA requirements, industry practices and international standards, such as ISO 22301, ISO 27001, Good practice guidelines from BCI, and Professional practice guidelines from DRII. All Member Organizations are required to comply with these requirements and integrate it formally in their BCM program.

1.2 Definitions

• BCM is a holistic management process that identifies potential threats to an organization and the impacts to business operations those threats, if realized, might cause. It provides a framework for building organizational resilience with the capability for an effective response that safeguards the interests of its key stakeholders, reputation, brand and value-creating activities.
• BCM is part of the overall management system, which includes organizational structure, policies, planning activities, responsibilities, procedures, processes and resources that establishes, implements, operates, monitors, reviews, maintains and improves business continuity.
• IT Disaster recovery (IT DR) is part of BCM which includes policies, standards, procedures and processes pertaining to resilience, recovery or continuation of technology infrastructure supporting critical business processes.
• Maximum Acceptable Outage (MAO) is defined as the time that would take for adverse impacts which might arise because of not providing a product/service or performing an activity, to become unacceptable.
• Recovery Time Objective (RTO) is defined as the period following an incident within which, products or services must be resumed, activity must be resumed, or resources must be recovered.
• Recovery Point Objective (RPO) is defined as the point to which, information used by an activity must be restored to enable the activity to operate on resumption. This can also be termed as "Maximum Data Loss".

1.3 Scope

The BCM framework document defines principles, objectives and control considerations for initiating, implementing, maintaining, monitoring and improving business continuity controls in member organizations. The BCM framework document is applicable to the full scope of the Member Organization, including subsidiaries, employees, subcontractors, third-parties and customers. The BCM framework document has an interrelationship with other corporate policies for related areas, such as enterprise risk management, health, safety and environment (HSE), physical security, cybersecurity (including cyber resilience and incident management).

1.4 Applicability

The BCM Framework document is applicable to following:

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• All organizations affiliated with SAMA ("the Member Organizations")
• All banks operating in Saudi Arabia
• All banking subsidiaries of Saudi banks
• Subsidiaries of foreign banks situated in Saudi Arabia

1.5 Responsibilities

SAMA mandates the BCM framework requirements document to Member Organizations. This document outlines the BCM requirements to be implemented by the Member Organizations. SAMA is the owner and is responsible for periodically updating the BCM Framework document. The Member Organizations are responsible for adopting and implementing the requirements stated in this framework document.

1.6 Interpretation

SAMA, as the owner of the BCM framework requirements document, will provide interpretations of the principles, objectives and control considerations, if required.

1.7 Target Audience

This document is intended for board of directors, CEOs, chief risk officer, senior and executive management, business owners, owners of information assets, CIOs, CISOs, business continuity managers, internal auditors and for those, who are responsible for and involved in defining, implementing and reviewing business continuity controls.

1.8 Review, Changes and Maintenance

This document will be reviewed and maintained by SAMA. SAMA will review this document periodically to determine its effectiveness, including the effectiveness of the framework to address emerging business continuity threats and risks. If applicable, SAMA will update this document based on the outcome of the review.

If a Member Organization considers that an update to this document is required, the Member Organization should formally submit the requested update to SAMA after obtaining approval from the business continuity manager and business continuity steering committee within the Member Organization. SAMA will review the requested update, and when approved, this document will be updated.

Version control will be implemented for maintaining this document. Whenever any changes are made, the preceding version should be retired and the new version should be published and communicated to all Member Organizations.

1.9 Reading Guide

The BCM Framework represents the actual BCM domains and subdomains, principles, objectives, and control considerations.

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2 Business Continuity Requirements

2.1 BCM Governance

Principle
The business continuity governance framework should be defined, approved, implemented and maintained, which should be monitored by senior management. The business continuity structure should be defined and communicated to all relevant employees and third parties.

Objective
To direct, control and evaluate the overall approach to business continuity within the Member Organization

Control Consideration:

1. Board of directors or a delegated executive member should have the ultimate responsibility for the BCM program.
2. The board of member organization, or a delegated member of senior management should allocate sufficient budget to execute the required BCM activities.
3. A BCM Committee should be established and mandated by the board of directors.
4. Senior management, such as CRO, COO, CIO, CISO, BCM manager and other relevant departments should be represented in the business continuity committee.
5. A business continuity committee charter should be developed and should reflect:
   a. Committee objectives b. Roles and responsibilities
   c. Minimum number of meeting participants
   d. Meeting frequency (minimum on quarterly basis)
6. A BCM function should be established.
7. A BCM manager/head should:
   a. Be appointed b. Have appropriate authority to manage the BCM program
   c. Be qualified and have appropriate experience, skills and competencies to implement and maintain the BCM program within the member organization
8. The BCM function should be adequately staffed with qualified team members
9. Cross-functional teams, consisting of strategic, tactical and operations team members should contribute in implementation and maintenance of the business continuity and disaster recovery plans.

2.2 BCM Strategy

Principle
A business continuity strategy should be defined and aligned with the Member Organization's overall strategic business objectives.

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Objective
To ensure that business continuity initiatives are in alignment with the strategic business objectives and embeds BCM as part of the good management practice within the Member Organization, in order to continual improvement in maturity.

Control Consideration

1. The business continuity strategy should be defined, approved, implemented and maintained.
2. The strategy should at minimum define:
   a. Long-term strategic objectives for implementing and maturing the BCM program b. Road map with timelines for achieving strategic objectives
   c. Requirements for continual review and validation of alignment of the BCM program with strategic objectives

2.3 Business Continuity Policy

Principle
A business continuity policy should be defined, approved and communicated to relevant stakeholders.

Objective
To document the Member Organization's commitment and objective of the business continuity program, and to communicate this to the relevant stakeholders.

1. A business continuity policy should be defined, approved, implemented and communicated
2. The business continuity policy should at the minimum identify:
   a. Objectives b. Scope
   c. Responsibilities
3. The compliance with the business continuity policy should be monitored.
4. The effectiveness of policy implementation should be measured and periodically evaluated.
5. Scope exclusions for the BCM should be documented and periodically evaluated. The justifications for scope exclusions should be documented and approved by BCM committee and senior management.

2.4 Business Impact Analysis (BIA) and Risk Assessment (RA)

Principle
The Member Organization should perform a business impact analysis and risk assessment for all relevant activities to determine the business continuity, and disaster recovery requirements and improvements.

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Objective
To ensure that each Member Organization has identified and prioritized their business processes along with key dependencies, and identified adequate controls in order to fulfill their business, regulatory, legal and compliance requirements with regards to business continuity

1. Methodology for BIA and RA should be defined, approved, implemented and maintained.
2. The Member Organization should periodically perform a Business Continuity risk assessment. It should include, but not limited to:
   a. Identify potential internal and external threats, including single point of failures that may cause disruption to critical activities as determined in the BIA considering people, process, technology and premises b. Assess and prioritize potential risks by evaluating potential threats based on their operational impact and probability of occurrence
   c. Select required controls to manage identified risks
   d. Define treatment plan and implement BCM controls
3. The Member Organization should identify and prioritize the activities (i.e., products, services, business functions and processes) by performing BIA to determine the following but no limited to:
   a. The potential impact of business disruptions for each prioritized business function and processes, including but not restricted to financial, operational, customer, legal and regulatory impacts b. The recovery time objectives (RTOs), recovery point objectives (RPOs) and maximum Acceptable Outage (MAO)
   c. The internal and external interdependencies
   d. Supporting recovery resources
4. The BCM committee should endorse the prioritized list, BIA results, RA and the defined RTOs, RPOs and MAOs.
5. Risk assessment results should be communicated to the BCM committee
6. The BIA and RA should be updated annually and when major changes occur (such as change in structure and organization of people, process, technology, suppliers and locations).
7. The risk assessment should include risks associated with overall organization as well as data centers (primary and alternative), which are not owned by the Member Organization (e.g., consider the timeframe needed to relocate to a new site and accordingly, it should include a sufficient timeframe in the contractual agreement)
8. Capability of vendors, suppliers and service providers to support and maintain service levels for prioritized activities during disruptive incidents should be assessed at least on a yearly basis.
9. Member Organizations should ensure that RTOs are adequately defined for payment systems, customer related services, etc. considering the high availability of these operations and minimum disruption in the event of disaster.

2.5 Business Continuity Plan (BCP)

Principle
The Member Organization should define, approve and implement BCP for their critical activities. The compliance with BCP should be monitored, and the effectiveness should be measured and periodically evaluated.

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Objective
To ensure that the Member Organization has the capability to identify and clearly define the actions to be taken, and resources which are needed to enable the organization in managing a disruptive interruption and to come back to a position where normal business processes can resume

1. A BCP should be defined, approved, implemented and maintained in readiness for use during disruptive incidents, to enable the Member organization to continue delivering its important and urgent activities, at an acceptable pre-defined level.
2. The member organization should define, approve and implement procedures for responding to disruptive incidents. The procedures should collectively include:
   a. Key resources (e.g., people, equipment, facilities, technologies) b. Defined roles, responsibilities and authorities for stakeholders
   c. A process to manage the immediate consequences of a disruptive incident and escalation procedures
   d. A process to continue the critical activities within predetermined recovery objectives (RTO, RPO and MAO) e. A process to resume the Member Organization's operations to business-as-usual once the incident is resolved f. Guidelines for communicating with employees, relevant third-parties and emergency contacts g. Process for including relevant cyber security requirements, if any, within the business continuity planning
3. The compliance with the BCP should be monitored.
4. The effectiveness of the BCPs should be measured and periodically evaluated.
5. The BCM Manager and BCM coordinators are responsible to maintain and keep the BCPs and arrangements up-to-date.
6. The Member Organization should have sufficient alternative business workspace(s) where it can relocate the required resources to deliver the critical processes required as per predefined recovery objectives in the BIA.
7. The alternative business workspace(s) should have clear demarcation of the sitting arrangement for different business units.
8. The Member Organization should implement sufficient logical, physical and environmental security controls in order to support the same level of access and security in case the alternative location needs to be activated.
9. For all critical activities, as determined by the BIA, the Member Organization should ensure that the key service providers (if any) have a BCP in place and their plans tested at least on a yearly basis.

2.6 IT Disaster Recovery Plan (DRP)

Principle
The Member Organization should define, approve, implement and maintain a IT DRP for its critical activities and related technology infrastructure.

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Objective
To ensure the Member Organization has IT DRP and up-to-date list of critical activities in place, in case of a disruptive incident

1. An IT DRP to recover and restore technology services and infrastructure components (Data, systems, network, services and applications) should be defined, approved, implemented in alignment with business impact analysis.
2. The Member Organization should establish an alternative data center at an appropriate location. The location should be identified based on:
   a. A risk assessment to confirm that the location does not share the same risks of the main data center (e.g., geographical threat) b. Upon approval from SAMA
3. Data, system, network and application configurations, and capacities in the alternative data center should be commensurate to such configurations and capacities maintained in the main data center.
4. Member Organization should implement the same logical, physical, environmental and cyber security controls for the alternative data center as for the primary data center.
5. The Member Organization should define and implement a backup and recovery process.
6. The Member Organization should have offsite location for storing backups.
7. Formal contracts should be signed with third-parties to ensure the continuity of outsourced services or delivery of replacing hardware or software within the agreed timelines in case of a disaster. Include guidelines to ensure that the contracts signed with external service providers are aligned with the BIA and RA outcomes.
8. The IT manager should be responsible to maintain and keep the disaster recovery plans and arrangements up-to-date with an overall accountability of integration within the BCM Program on the BCM Manager.
9. The compliance with the disaster recovery plan should be monitored.
10. The effectiveness of the IT DRP should be measured and should be evaluated on a yearly basis as minimum.

2.7 Cyber Resilience

Principle
The Member Organization should ensure that critical services, business functions and processes run on reliable and robust infrastructure and software.

Objective
To ensure each that the Member Organization's critical services, business functions and processes are available when required and resistant to disruptions.

1. All changes to the infrastructure and software, which directly support the identified critical services, business functions and processes, should:

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a. Be subject to in-depth risk assessments to ensure the agreed business requirements regarding availability and recovery are met. b. Follow strict development, testing and change management procedures to avoid single point of failures or malfunctioning.  

2. A periodic architectural review should be defined and approved to ensure