Last week, I shared little bits about the new normal – working from home. We looked at the pros and cons of this new normal and various recommendations for those involved, to ensure that the risks are mitigated. I hope it was useful. This week, I am starting a series on more fundamental issues that go to determine the success in the implementation of the new normal, which I will term “Business Unusual”. Anything unusual also brings with it, red flags which risk managers should take note of.
What is a Business Continuity Plan (BCP)?
A business continuity plan is a document that outlines how an organization will continue to function during and after an emergency or event. It involves planning how your key services or products can continue. Ensuring business continuity is paramount at any time but especially during a crisis and every organization should have a basic BCP plan in place to help employees fulfill their roles in the event of a crisis. This plan should also include a methodical system to help identify and prevent threats, and detail how to recover quickly from those threats.
The Difference between a Traditional/Regular BCP and a pandemic BCP
I must say that for most bankers, we associate BCPs with events like fire, earthquakes, flood, breakdown in IT and support systems, etc. In Ghana, most people did not associate BCPs with pandemics, especially the likes of Covid19!.. the invisible enemy.
Traditionally, most business continuity plans focus on what will happen if the building or equipment is damaged. In other scenarios, the plan may assume that people will be able to return to a building after a single event (such as after a storm, or if there is a utility outage). However, in the case of a pandemic like Covid 19 with numerous government directives and partial shutdowns, banks must plan for the workers being unable to report to work for a period of time. These steps will influence how many people may be available to report to work. It is important to plan to have the banks’ core business activities remain operational for several weeks or months with limited staff.
The Need for BCP Re-evaluation
In the midst of the Covid 19 pandemic, Bank of Ghana directed all banks to activate their Business Continuity Plans. (BCPs). This Directive from the central bank was received with mixed feelings, especially when banks now have to deal with an unprecedented event which has no solution or estimated period of elimination, and worst of all, lockdowns. There was a rush for laptops and tools for staff who would be working from home, identification of what services are critical. COVID-19 has reshaped our world and redefined how nearly every organization conducts business. A mass shift of employees from corporate office buildings to home offices in March 2020 caused business owners to re-evaluate human resource and IT policies including work from home, training, travel, sick leave, and many more. Human Resource Directors are working hard to ensure all employees have what they need to work under “business unusual”. No one could have predicted the current economic state, so chances are most business continuity plans did not include a section detailing what steps to take when the office buildings are completely shut down and all employees are forced to work from home. As a result, revisions should be made now to business continuity plans to update them.
The BCP Plan for Remote Workers
One of the immediate effect of lockdown of sensitive geographical areas demanded an immediate activation of banks’ remote working policy to back the closure of some branches and physical outlets. The following critical measures come to play:
- Identification of Essential staff:
Workers who are needed to process and maintain systems for processing financial transactions and services (e.g., payment, clearing, and settlement; wholesale funding; insurance services; and capital markets activities). Workers who are needed to provide consumer access to banking and lending services, including ATMs, and to move currency and payments (e.g., armored cash carriers); and Workers who support financial operations, such as those staffing data and security operations centers.
- Preparation of a Remote Working Policy:
This remote work policy outlines guidelines for employees who work from a location other than the offices. It is to ensure that both employees and the bank will benefit from these arrangements.
Ø Determine who should work from home:
Both employees and managers should consider these elements before asking/approving work from home:
- Is the employee eligible by nature of their job?
- Are there any cybersecurityand data privacy concerns?
- Will collaboration with the employee’s team become difficult?
- Do employees have the necessary equipment or software installed at home?
- What are the conditions of employees’ home or alternative place of work (noise, internet connection)
- Implementation of the Remote Working Policy:
All employees must comply with the terms of this policy. Managers, employees and technical personnel must modify system configurations and procedures, if necessary, to comply with the terms of this policy within the time period. Employees work from home or telecommute when they complete their work at a place located outside of the bank’s premises. Employees may work from home, full-time, on certain days (dividing their schedule between on-site and remote) or every day.
Remote employees must follow the bank’s policies like their office-based colleagues. Examples of policies that all employees should abide by are: Attendance, Social media. Confidentiality, Data protection, Employee Code of Conduct, Anti-discrimination/Equal opportunity, Dress code when meeting with customers or partners.
The Bank must also provide remote employees with equipment that is essential to their job duties, like laptops, headsets and cell phones (when applicable). The bank would require the installation of VPN and bank-required software when employees receive their equipment. It is important for remote workers to know that the equipment that is provided is bank property. Employees must keep it safe and avoid any misuse. Specifically, employees must Keep their equipment password protected, store equipment in a safe and clean space when not in use, follow all data encryption, protection standards and settings, refrain from downloading suspicious, unauthorized or illegal software.
- Staff Training
Training should not stagnate. Personnel who are responsible for staff training should prepare a remote employee training package. The training should include policy, procedure, and compliance. In unusual times, the blame game becomes intense when risks, near misses or losses occur. This is not the time for staff to say they did not know.
- Maintaining Operations during Disaster recovery
Let us not forget the following reminders or to-do-list:
- Prepare and plan for operations with a reduced workforce.
- Regular coordination with suppliers to ensure that the bank can continue to operate and provide services.
- Re-evaluation of the bank’s sick leave policy. There should be an avoidance of penalizing sick employees, thereby encouraging employees who have symptoms to stay home so that they do not infect other employees. It must not be forgotten that employees with ill family members may also need to stay home to care for them.
- Identify possible exposure and health risks to your employees. Are employees potentially in contact with people with illnesses such as in a hospital or clinic? Are your employees expected to have a lot of contact with the public?
- Minimize exposure to fellow employees or the public in the event of a pandemic. Relationship Officers’ work schedule should now concentrate on telecommuting, staggered work shift, and/or increased use of email, telephone and other technology to avoid close person-to-person contact. The use of scheduled skype and zoom meetings should be encouraged to ensure customers continue to have feel a sense of loyalty to the bank.
- Stockpile items such as soap, tissue, hand sanitizer, cleaning supplies and recommended personal protective equipment.
- Make sure that your disaster plan protects and supports your employees, customers, and the public. Be aware of your employees’ concerns about pay, leave, safety and health. Informed employees who feel safe at work are less likely to be absent.
- Identify a central team of people to serve as a communication source during a pandemic so that your employees and customers can have accurate information during the crisis.
I will pause here. Next week, there will be a continuation of the BCP, the need for employee protection, measures to prevent the spread of the virus among staff and customers, as well as enhancing areas that the bank can still maximise returns and continue to be in business.
TO BE CONTINUED
ABOUT THE AUTHOR
Alberta Quarcoopome is a Fellow of the Institute of Bankers, and CEO of ALKAN Business Consult Ltd. She is the Author of two books: “The 21st Century Bank Teller: A Strategic Partner” and “My Front Desk Experience: A Young Banker’s Story”. She uses her experience and practical case studies, training young bankers in operational risk management, sales, customer service, banking operations and fraud.