January 8, 2009
Contingency Plan
Every stock plan department should build a contingency plan for all essential daily functions into their records management and retention policy. Stock plan management processes are complex and typically involve multiple departments. You need to be confident in how not only your department, but those you work with will respond to situations that range from serious disaster (like floods, fire, blizzards, etc.) to a key employee being unavailable during an essential part of a process.
For your contingency plan, you will want to determine what your team will do in the event of an evacuation as well as in a situation where the entire team (which in some cases is the one stock plan administrator) is unable to return to work. Planning for an evacuation should involve a process for taking all necessary tools, contact information, access codes, licenses, and policies/procedures with you as you go. Preferably, all of this information would be accessible from off-site without the stock team having to physically remove anything from the office.
This will help you also in preparing for an event where the entire team may be unable to physically go to the office. Take, for example, a situation where incremental weather prohibits all employees at your location from going to work (sudden ice, for example) on the day an ESPP needs to be processed or you have a large vesting of restricted stock units. Sometimes you will know in advance when such an event is a possibility and be able to bring home a laptop with a good VPN connection. However, you should have a plan in place that would allow for required daily tasks to be completed remotely at any time without warning.
When allowing remote access to necessary data, you will need to maintain data privacy and data integrity. You will also want to build in redundancy so that your data is saved on servers that are physically in different locations (all important company data should be handled in this way). It’s a good idea to sit down with your IT team to understand and plan for emergency situations. You can work toward building your systems to better accommodate the unforeseen by automating processes, as well.
Once you have your own team plan under control, reach out to other departments and vendors that are essential to any part of your job function. For example, does your broker have a back-up plan for sending you trade information? Do your payroll teams have a contingency plan to get you payroll data on crucial data transfer days (such as contributions to the ESPP)? You should review these plans in regularly scheduled meetings annually to be sure that changes to personnel, location, and stock programs are accounted for in each department’s plan.
The beginning of the year is a busy time for not only the stock plan management team, but also many departments that work closely with them. However, it’s not too early to schedule planning meetings for later in the year to create or review your contingency plans!
Disaster recovery, along with other major data integrity planning and policy issues, is just one of the many topics covered in the NASPP’s fantastic Fundamentals of Stock Plan Administration education program. If you are new to the field and looking to get a solid foundation in regulatory requirements and administrative best practices, register now to take the online course or join us for the live program that will be offered as part of our 2009 NASPP Conference!
-Rachel Murillo
Tags: contingency plans, disaster recovery, work remotely