RegSol Blog

BCP & Pandemic Response Plans

March 2020

There is no escaping the media frenzy as we watch the world’s response to a pandemic unfold before our very eyes. We at RegSol express solidarity to those affected and our sympathies go out to all who have suffered losses; but especially to those regions most severely impacted, including China and Italy. 

So, what are the practical implications to businesses particularly those that are regulated by the Central Bank? And what does a response plan actually look like? The Central Bank has issued generic communications to firms stating that all necessary arrangements should be put in place and have commented publicly:

“We are closely monitoring developments related to COVID-19 and continue to assess their impact on the economy and the financial system, as more information becomes available.

We expect regulated firms to have appropriate contingency plans in place to be able to deal with major operational events, should they occur, and we are working with the financial sector to ensure that firms are responding effectively to the evolving situation.”

Being mindful that careful planning requires modelling various scenarios, making adjustments throughout the business continuity life cycle during business as usual and on an annual basis, Business Continuity Management Programmes should have already documented:

  • Risk assessments- site and threat analysis
  • Business Impact analysis (BETH-3- building, equipment, technology, human resources and 3rd parties) 
  • Emergency Response and Crisis Management Plans
  • Business Continuity Strategies & Plans
  • Testing & Desktop Exercises, Denial of Access
  • Scenario Analysis (Pandemic, Severe Weather, Fraud, Cyber attack etc)

Businesses must have determined through business impact analyses their critical processes, critical people, systems, equipment and critical outsourced service providers AND what is required to keep these going under stress of severe events such as power outages, severe weather, inaccessibility to the building, etc.  Above all, safety of customers, staff and suppliers should be paramount when determining steps to mitigate the consequences of these events.

During a Pandemic scenario, Businesses may closely monitor HSE, HPRA, ECDC, WHO communications and assume that critical staff, including critical outsourced service providers may not be available and as such take into account rates of infection to properly assess potential impact and strategically plan via a crisis management or incident response team. 

Key is knowing when to activate plans and how to resource critical operations during potential waves, peaks and troughs of infection levels. Maintaining effective communication of critical staff and outsourced service providers or suppliers overlaid by successfully anticipating people outages due to hospitalisation, confinement, school/creche closures based on a sound business continuity approach will ensure survival of:

  • mass absenteeism which could affect as much as 40% of the workforce (Mitigations: sick leave policy, work from home strategies; infection control supplies, cross training of critical processes, employee assistance programs to deal with loss)
  • changing patterns of consumer demand and;
  • interrupted supply chains. 
The below graph is useful in measuring the duration of the outbreak and calibrating your BCP plans:

By Judy de Castro - Regulatory Consultant