Business Continuity Planning for Covid-19
3 April 2020
This note outlines the approach taken by Spence to ensuring that our services are affected as little as possible during the current Covid-19 Pandemic.
Everyone at Spence & Partners and has been working at home since 16 March, and our systems and processes are working well. Our services have not been affected and the current configuration can remain in place for an indefinite period.
Inevitably we depend on key service providers and services such as banks, Microsoft Azure etc.
- Spence is in good financial shape with adequate cash reserves and no borrowing.
- As a result of our cloud-based IT infrastructure, staff members can work remotely without any disruption to any normal business processes. There has been no loss of production to date and SLAs have been met.
- A very marginal reduction in our overall production may occur in the coming weeks and months due to a small number of staff reducing hours or accelerating leave to accommodate childcare or elder care. However, there is the potential for this to be partly offset as some staff may cancel scheduled leave. This should have no material impact on our services.
- As a result of early remote working and the achievement of social distancing there is no possibility of cross infection between staff members (save for a small number who reside in the same household).
- We have a young demographic and expect average Covid-19 absences to be relatively short on average.
Current response to Covid-19 Pandemic
Spence has been paperless for internal processing and filing since 2009.
The foundation for our current BCP was established in 2014/2015 when we set a target of November 2019 to migrate all telephony and IT services into the cloud. This was achieved in September 2019 and since then staff have an identical experience working remotely as they would in our offices.
We established a Pandemic Contingency Planning Group on 30 January which has met every weekday since then. All staff have notebook computers and we have a stock of notebook computers and phones held against the contingency of supply chain problems. We implemented secure “Bring Your Own Device” policies for staff who did not previously have work mobiles.
We transport two members of staff on a rotating basis in our Belfast office to deal with incoming and outgoing post and who remain socially distanced from each other within the office. Post from our other locations is redirected to Belfast. These members of staff have been provided with written confirmation that they are “essential workers” based on criteria set out by the Financial Conduct Authority (FCA).
Five members of staff across the three countries within the UK where we have offices appear to have been infected by Covid-19 (and two have recovered so far), but there is no risk that they have infected other members of staff.
We have conducted interviews with over 60 members of staff with young children at home following the closure of schools/day-care.
Actions we have taken include:
- Supply of additional equipment to maximise the effectiveness of staff members’ home working environment e.g. printers, monitors, chairs etc.
- Steps to ensure that our data protection measures remain robust during a prolonged period of the majority of our staff working from home;
- Contacted our service providers to discuss their arrangements with them to ensure any risk to disruption of these services to our business is minimised;
- Encouragement of line managers to manage and communicate proactively through Microsoft Teams both for work and social purposes;
- Weekly remote “Townhalls” led by Brian Spence (CEO) and other key members of staff which are followed by an open forum to allow questions from staff. The vast majority of our staff have tuned in to the three held so far; and
- Recognising it is not the norm, sharing material with staff to help cope with a prolonged period of working from home, including tips on looking after both their physical and mental wellbeing.
- Individual virtual meetings with all staff with responsibilities as carers for children or adults. Most work can be performed at any point during the week, but we have ascertained that a very small number of staff may need to accelerate leave or slightly reduce their hours in order to accommodate childcare responsibilities.
Our Approach to managing material staff absence
With the current remote working having all but eliminated the risk of cross infection among staff, combined with the UK Government’s restrictions on movement, high levels of staff absence are unlikely given the likely duration of absence due to Covid-19 infection. Our team is relatively young which increases our confidence of this.
We have modelled different absence rates and do not realistically envisage a scenario where certain work needs to be given priority as long as the current working from home configuration remains in place. A protocol for giving priority to critical tasks is in place should this situation change.
Subject Access Requests
The only time that we may be reliant on paper files, is in relation to historic pension scheme data. We need to access to this to help us answer detailed questions raised on behalf of members, most often in relation to Subject Access Requests (SARs). Due to the volume of hard copy files that exist for each scheme that we administer, they are stored by a secure document management service off-site from our own physical offices. Given the current restrictions on movement, in some cases we may be unable to meet the 30-day deadline for responding to SARS. Where we can respond using digital information, we will of course do so, within the deadline.
The current Information Commissioner’s Office guidance on this, is that they are aware that the current restrictions may lead to these kinds of delays in responding to SARs, and ask that we deal with each Request individually and contact those who have raised the Requests to inform them of any delay. We will do this on a case by case basis.
We will continue to update you on our preparedness, the fluctuations in investment markets and the general position on your pension scheme as the situation develops.
Please do continue to contact us as normal if you have any questions at all.
I am happy to take calls on my mobile telephone 07802 403013 or emails to email@example.com if you have any urgent concerns.
3 April 2020