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Canadian Centre for Occupational Health and Safety

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Business Continuity Plan - Pandemic

On this page, what is a business continuity plan, is a pandemic plan different than a regular business continuity or resumption plan, how many people will be away from the workplace during a pandemic, what are some effects of a pandemic on a business, how do you set priorities for your plan, what are elements that should be included in a business continuity plan for pandemics, using an office setting as an example, how can the office space accommodate physical distancing requirements, what are other good practices to help reduce the spread of infectious diseases, what should we be aware of for covid-19 symptoms.

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.

Please remember... each business is unique – the topics listed in this document are general suggestions. You will need to create a specific plan that best suits your business and operational needs.

This document focuses on creating a business plan for infectious diseases such as a pandemic or severe seasonal outbreak that results from a virus or other agent. It is intended for non-healthcare organizations. Healthcare organizations, as well as other first response agencies (e.g., police, emergency, first aid, ambulance), will require more rigorous infection control measures and workforce plans.

Please see the OSH Answers "Emergency Planning" for information on a general emergency response plan.

In some ways, yes.

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, if there is a serious infectious disease outbreak, such as a pandemic, you must plan for the workers to be unable to report to work for a period of time. During a pandemic, businesses, social organizations, or schools may be required to close by order of health officials to help slow the spread of the illness. These steps will influence how many people may be available to report to work. Other measures may be enacted by governments or recommended by public health officials, such as physical distancing, hand hygiene, travel restrictions, limits to the number of people who can gather at a single location, alternative, use of non-medical masks, etc.

It is important to plan to have your core business activities remain operational for several weeks or months with limited staff like working remotely.

Please see the booklet  Business Continuity Plan: Infectious Diseases  for more information.

It is hard to say with certainty. Every pandemic is different. It will depend on the virus's “viral ability” – that is, how easily the virus spreads and how sick people become. Workers may be away from work for various reasons (e.g., illness, caregiving, school closure).

Also note, as stated by the Government of Canada: “The pattern of disease is different in pandemics than in seasonal influenza. Pandemics may arrive outside of the usual influenza season and typically have more than one wave of illness. The total duration of a pandemic is likely to be 12 to 18 months.”

It will be important to make sure your plan will accommodate staff absences for more than a single period of time.

Possible effects on business from a pandemic can include:

  • reduced labour supply, including your regular workers or availability of contractors or temporary workers
  • reduced business or cancelled customer orders
  • interruption in getting supplies or materials (especially if goods are imported by air or land)
  • change in demands (for example, increased internet use, decreased tourism/travel, alternative methods to conduct business such as curbside pick up or delivery)
  • reductions or restrictions on public meetings or gatherings (including schools, sports, clubs, theatre, community centres, restaurants, religious gatherings, etc.)
  • restrictions on travel (regional, national, or international)
  • reduced availability of health care or home care services
  • reduced availability of child day care services
  • in more severe situations, disruptions in services such as telecommunications, financial/banking, water, electricity, gasoline/fuels, medicine, or the food supply

In general, when creating a business continuity plan, determine what element is critical and how the loss of this element will affect the business.

  • Identify critical processes, operations, and functions.
  • Identify key internal and external dependencies – those things, people, or other businesses you rely on.
  • Identify what else can affect your business.

When planning for your priorities, examine:

  • Personnel – Identify and train backups for essential functions, including chain of command (management). Be sure you have consulted with staff, including any applicable union or collective agreements.
  • Equipment – Make sure the available equipment meets the identified needs.
  • Availability of assets – Make sure that facilities, utilities, computers, machinery, or tools also meet your needs (e.g., access to internal systems by staff working from home).
  • Business commitments – Research legal implications for the level of service arrangements (e.g., for non-performance or late delivery).
  • Accounting – make sure you can continue your payroll, finances, etc.

Elements of a risk assessment process may also be helpful.

How detailed your plan is will depend on the type of business, how complex your organization is, and its size. Allow your plan to be flexible and proportional to match the level of threat that is occurring at that time. As a pandemic evolves, restrictions may be lifted or tightened, as determined by local public health officials. It may also be the case that certain geographical areas have different levels of measures in place. Your plan should include health, safety, human resources, and management elements.

Options include:

  • Document guidelines for management and business decisions – remember, anyone can get sick.
  • Create a pandemic management team that assigns who will do what tasks, establishes a chain of command, coordinates prevention activities, etc.
  • Make decisions about when to stay open, when to close to customers, when to use alternative methods to conduct business, and when to close completely.
  • Assign a person or team, where appropriate, to help assess the health of workers (e.g., if the worker may be coming down with an illness) such as by using screening checklists as provided by public health officials.
  • Cross-train workers to make sure essential functions will continue (e.g., payroll, customer service).
  • Provide handwashing facilities and/or alcohol-based hand sanitizers (of at least 60% alcohol).
  • Have a period of time between shifts to clean touch points and surfaces such as tables, door knobs, handrails, shared telephones and keyboards.
  • Have up-to-date sick leave policies. NOTE: Be aware that doctors may have limited availability to provide sick leave documentation.
  • Maintain an up-to-date list of your staff and your clients (e.g., telephone trees, call-in numbers, hot lines for information, broadcast e-mails)
  • Develop communication methods to reach all staff, especially if staff are working remotely.
  • Develop methods to conduct your business, including using the internet, cloud-based workspaces, phones, video conferencing, etc.
  • Develop methods that allow workers to use flexible work options or telework/work remotely.
  • Increase the distance between people (e.g., install a protective barrier for those working with the public, increase the distance between workstations, use larger meeting rooms, limit the number of users in a common area such as a lunch room or washroom).
  • Consider providing transportation for those staff who use public transportation.
  • Consider psychosocial issues (e.g., financial stress, caregiver burnout, occupational stresses, stigma, or social exclusion).
  • Consider postponing or cancelling face-to-face meetings (including internally) as well as unnecessary travel.
  • Create small working groups or "cohorts" (e.g., a factory may keep the same group of people together on the same shifts).
  • Document which workers were present each day to assist public health with contract tracing if a case is discovered.

There are three key areas to consider:

  • the space and equipment an individual uses
  • the common use spaces, such as meeting areas, social areas, lunch rooms, and equipment rooms, as well as the paths of travel
  • personal measures, such as hand hygiene and respiratory etiquette

The workplace should evaluate who needs to be in the office and how they will function in the space. It may not be possible to allow your normal capacity of people in the building and maintain physical distancing at the same time. Additional factors include “congestion points” such as kitchens, lockers, closets, elevators, stairs, washrooms, and emergency exits.

Public Services and Procurement Canada (2020) have developed a " Guidance and practices for the safe return to workplaces in light of the easing restrictions " document. When assessing the workstation layout, be sure to measure for 2 metres distance in all directions, measured from where the individual would sit.

Public Services and Procurement Canada note that "there is no evidence that partitions provide sufficient safety between occupants, and should not be the first line of defence". Maintaining 2 metres physical distance is preferred. When considering additional partitions or other barriers, also determine if the installation will reduce the effectiveness of the ventilation systems.

Staggered seating or re-arrangement of desks may help. Face-to-face seating is discouraged.

Other measures may include:

  • making sure the ventilation system is working appropriately. Increase air refreshment rates, if possible.
  • allowing workers to work at the same desk each day if seating arrangements would normally be flexible
  • asking workers to maintain a tidy desk to assist with cleaning and disinfecting
  • removing extra chairs from meeting rooms to help avoid overcrowding
  • using wide tables when individuals are sitting face-to-face
  • keeping doors open to assist with air circulation
  • indicating a path of travel in hallways, especially if the hall will not allow persons to pass and maintain physical distancing
  • labelling doors as entry or exit only
  • allowing only 1 person in an equipment room or kitchen at a time
  • if allowing the use of microwaves, fridges, etc, in the office, providing a method to clean the surfaces after use
  • waiting until the other person has left before approaching a locker or coat closet
  • marking spots outside meeting rooms or washrooms where people should wait before entering
  • allowing time between meetings to allow for the air in the room to refresh

Good health habits are important in preventing the spread of infectious diseases. Steps to take include:

  • keeping up to date with vaccinations
  • staying home when sick, even with mild symptoms
  • frequent hand washing with soap and water
  • using alcohol-based hand sanitizers (at least 60% alcohol) when soap and water are not available
  • avoiding close contact with sick people
  • coughing and sneezing into your elbow, or use a tissue (and throw away the tissue immediately)
  • avoiding touching your eyes, nose and mouth
  • using proper hygiene practices , such as cleaning and disinfecting surfaces likely to be contaminated and touched by others

When a person is infected with COVID-19, they may have little or no symptoms, and the symptoms they do show can be easily confused with a cold or seasonal flu.

COVID-19 appears to mainly spread from person to person when people are in close contact with one another (within about 2 metres or 6 feet) and through respiratory droplets produced when a person coughs or sneezes. These droplets can land in the mouths or noses of people who are nearby or possibly be inhaled into the lungs.

It is possible that it can spread from contact with infected surfaces or objects – when you touch a surface or object that has the virus on it and then touch their own mouth, nose, or eyes.

Note that the Government of Canada states that there is evidence which indicates that the virus can be transmitted to others from someone who is infected but not showing symptoms. This transmission includes people who:

  • have not yet developed symptoms (known as pre-symptomatic)
  • never develop symptoms (known as asymptomatic)

Table adapted from: Cold or flu: know the difference / Know the flu facts - Fact sheet, Government of Canada, 2019, and COVID-19: Symptoms, treatment, what to do if you feel sick , Government of Canada, 2020.

  • Fact sheet last revised: 2024-03-20

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Business Continuity Planning

Glossary and abbreviations, 1. background.

Business Continuity Planning (BCP) is a key activity that enables the organization to provide for the continued availability of priority services in the case of disruption.

BCP is a requirement under Public Safety and Emergency Preparedness Canada’s Emergency Management Act and Treasury Board Secretariat’s (TBS) Policy on Government Security. The Departmental Security Officer (DSO) is ultimately accountable for BCP, as part of the broader departmental security program; however, the responsibility for operationalizing BCP at the Office of the Superintendent of Financial Institutions (OSFI) is delegated to the Security and Facilities Services (SFS) division under Human Resources and Administration within Corporate Services.

The TBS Policy on Government Services references TBS’s Operational Security Standard - Business Continuity Planning Program (OSS-BCPP) , which further outlines the requirement of the BCP program, including the following four elements:

  • The establishment of BCP program governance.
  • The conduct of a business impact analysis.
  • The development of business continuity plans and arrangements.
  • The maintenance of BCP Program readiness.

In support of the requirement for establishing a BCP Program governance, OSFI established its Directive on Business Continuity Management (BCM) in February 2014.

At the time of the audit, SFS was in the midst of an OSFI-wide Business Impact Analysis (BIA), as required every 5 years per the OSFI Directive on BCM . BIAs help to identify and prioritize essential operations and are a key driver for the development of divisional business continuity plans and associated investment decisions. The results of the BIA were pending communication to senior management, and corresponding updates to divisional business continuity plans were yet to be revised. Per management, the recent BIA exercise identified a key opportunity for the move towards functional based plans rather than maintaining divisional business continuity plans.

With organizational efforts underway in the area of BIA and respective revisions to the divisional BCPs, the scope of this audit focused on providing assurance that SFS has an adequate governance framework and mechanisms in place to administer, monitor and improve on business continuity planning on behalf of OSFI, as required by the Government of Canada.

An audit of BCP was recommended by OSFI’s Audit Committee and approved by the Superintendent for inclusion in the OSFI 2018-19 Internal Audit Plan.

Provide assurance on the governance framework and key mechanisms in place to support business continuity planning governance objectives, including a review of the Security Policy and associated policy tools for alignment with the Government of Canada guidelines, adequacy of the core processes to support key elements of the policy and tools, including any supporting operational procedures and guidance; roles and responsibilities; training and awareness; and monitoring and improvement mechanisms.

The scope of the audit focused on business continuity planning (BCP) governance elements, specifically policies, training, monitoring and assessment mechanisms in place to support Security Services. The scope of this audit excluded the assessment of the adequacy and effectiveness of the business impact analysis (BIA) and business continuity plans.

Statement of Conformance

The audit was conducted in conformance with the Institute of Internal Auditors’ International Standards for the Professional Practice of Internal Auditing, consistent with the Treasury Board Secretariat (TBS) Policy on Internal Audit and the Internal Auditing Standards of the Government of Canada, as supported by the results of the Quality Assurance and Improvement Program.

2. Results of the Engagement

Security and Facilities Services (SFS) has developed a robust business continuity planning program, which includes various governance tools and procedures in place to execute the program requirements. Although the foundational elements of a strong governance program exist, the program is not operationalized and lacks senior management commitment and oversight for effective functioning. SFS is in the process of updating the Corporate Security Policy , assessing the overall security program, and facilitating the establishment of functional business continuity plans through an ongoing Business Impact Analysis (BIA).

SFS is developing a roadmap for establishing strategic priorities for the improvement of the security program activities. In support of this roadmap and consistent with a recent opportunity highlighted in the BIA exercise, SFS should explore centrally managing high priority business continuity plans to ensure they receive the appropriate consideration to provide a level of confidence for the continued delivery of priority services.

Additional observations and considerations pertaining to updating policy and policy instruments and the establishment of a higher degree of accountability and governance over the BCP program are contained in this report.

3. Management Response

The management team agrees with the findings and recommendations, and recognizes that the recommendations require attention. SFS has a small team of three resources, none of which is dedicated to BCP. Therefore, mitigating these risks and implementing the actions in the near term would present an operational challenge.

As part of this year’s planning exercise, SFS identified the need to invest in the corporate security team in order to mitigate risks. Subsequent to the completion of this audit, the Executive Committee approved additional resources for the Corporate Security team, which includes resources for the BCP program. The timelines in the action plan have been established based on this increased resource level, although still dependent on successfully being able to recruit talent on a timely basis.

SFS would like to thank the audit team for conducting a review of practices and documents as it relates to business continuity management within OSFI.

SFS is proposing that the Operating Committee (OC) provide an oversight function in order to support overall security risk management activities within the Office. This strengthened governance will be an important element in the successful implementation of the action plan.

4. Observations and Recommendations

Medium priority observation #1.

Provide a higher level of assurance on continued delivery of priority services by exploring the feasibility of centrally managing critical business continuity plans.

The Operational Security Standard – Business Continuity Planning requires ongoing review and revision of all business continuity plans to account for changes, as well as regular testing and validation of plans. In line with this requirement, OSFI’s Directive on BCM outlines the requirement for quarterly review, annual validation and update and annual testing of business continuity plans.

SFS has developed a Dashboard for BCP management tracking process as an oversight mechanism for monitoring the activities of the BCPs across OSFI, including BCP updates and testing frequency; however, SFS has noted difficulty in maintaining the Dashboard due to lack of updates provided by the sector leads. This is attributable to low BCP engagement due to competing priorities within sectors, BCP Lead staff turnovers, and a lack of training and awareness.

Without assurance that business continuity plans are being reviewed and monitored on a consistent basis, the risk exists of business continuity plans being outdated and business units not having the awareness and understanding of their BCP processes should an event require plan activation.

Recommendation

Consideration should be given to SFS centrally managing the business continuity plans in order to provide a higher level of assurance for the continuity of priority operations in the event of a disruption. This provides the opportunity for SFS to ensure the accuracy of the business continuity plans as well as the completion of more timely testing and monitoring in order to identify  better practices and lessons learned that could help strengthen plans and practices.

Management Action Plan

Currently, SFS provides an oversight function for business continuity plans. However, SFS is proposing to consolidate existing plans into a single overarching organizational business continuity plan, in collaboration with Sector BCP Leads. We agree that SFS would centrally manage the enterprise level business continuity plan and present it to the Operating Committee for review and approval.

Director, SFS, Completion:

  • Present BIA for approval – Q1, FY 2019/20.
  • Interim review of existing BCPs – Q2, FY 2019/20
  • Present consolidated BCP for approval, Q3, FY 2019/20

Medium Priority Observation #2

Establish monitoring and reporting on the effectiveness of the BCP program to senior management in order to strengthen governance and oversight for the effective management of risk.

As required in the Directive on BCM, the effectiveness of the overall BCP program should be tested with the results reported to the Executive Committee. This measurement and reporting is not currently taking place. Since 2014 OSFI has conducted multiple activities assessing areas of the security program including a division-wide tabletop exercise (2018), a post-mortem following a security incident (2014) and a business impact assessment (2015); however, it was noted that findings/action items, if any, are not reported to a senior management committee for identifying program gaps and any significant risk exposures.

Without monitoring and reporting on the effectiveness of the program and with no formal communication regarding recommendations and/or action items stemming from assessments conducted, senior management risks not being able to execute their governance responsibilities for effectively managing the risk to the organization.

SFS should establish a process for tracking recommendations and action items as a result of BCP assessments/exercises, including a method to track progress against the action plans. Regular reporting on the effectiveness of the BCP program should also be communicated to a decision-making senior management committee to address noted deficiencies and gaps in the program, including recommended costed strategies.

Additionally, regular reporting to a senior management committee will strengthen governance and oversight over the program and aid in raising the awareness of overall BCP initiatives through the organization.

SFS recognizes that enhancing resilience within an evolving risk environment requires a more integrated approach.

In response to these recommendations, SFS will report regularly on the effectiveness of the BCPP to the Operating Committee.

  • Present summary of key findings related to the tornado in the National Capital Region to EC - Q4, FY 2018/19
  • Propose KPIs to OC for quarterly reporting - Q2, FY 2019/20
  • Implement quarterly reporting to OC - Q3 FY 2019/20
  • Develop an Action and Risk register to track progress against action plans – Q3, FY 2019/20

Low Priority Observation #3

Strengthen accountabilities by clarifying, and aligning policy instruments to address inconsistencies in roles and responsibilities and accurately reflecting current practices.

OSFI maintains a Policy on Corporate Security , which is supplemented by policy instruments pertaining to BCP, including the Directive on BCM, BCM Framework and the BCP Communication Framework. OSFI’s BCP policy instruments were generally found to be in line with the over-arching Government of Canada Policy on Government Security and Operational Security Standard – Business Continuity Planning Program (OSS-BCPP).

OSFI’s governance documents communicate roles and responsibilities to BCP Team Leaders as well as outline the requirements of the program to OSFI as a whole. All OSFI governance documents have a requirement to be reviewed every five years. At the time of the audit, the Policy on Corporate Security was under review as part of OSFI’s corporate policy suite renewal.

It was noted that some elements of the policy documents are outdated and not reflective of the requirements and actions taken by the organization in executing its Business Continuity Planning Program (BCPP). Specifically, the following inconsistencies were noted:

Roles and responsibilities

  • The Policy on Corporate Security tasks the Director, Securities and Facilities Services (SFS) with the responsibility of discharging the authorities and requirements of the DSO while in practice the Director, Cyber Security has been delegated this function.
  • The Directive on BCM indicates a requirement for quarterly review of the divisional business continuity plans; however, this is not defined within the sector roles and responsibilities in the various governance documents and is not in alignment with the BCM Framework, which outlines the requirement for annual update and testing.
  • The Directive on BCM and the BCM Framework assigns the Sector Leads with the responsibility for creating Sector Business continuity plans; however, these plans are not currently required to be in place.

Reporting Requirements

  • The BCM framework and the BCP Communication Framework contain governance/communication diagrams illustrating a direct reporting relationship between the BCPC and the Executive Committee, while the Directive on BCM assigns the DSO as accountable for this reporting. In practice the Director, SFS with the BCPC will begin reporting to the Operating Committee on the most recent BIA as of 2018-19.

The inconsistencies between the requirements in the governance documents and actual practices leads to the misalignment in BCP roles, responsibilities and accountabilities risking the effectiveness of the overall BCP program.

In updating the Policy on Corporate Security , Security and Facilities Services (SFS) should review and update the corresponding policy instruments to address the noted inconsistencies with roles and responsibilities in order to clarify accountabilities for the effective functioning of the BCP program. Additionally, the various documents should be reviewed for alignment with current practices while reducing redundancies and ensure effective communication to BCP Team Members and OSFI staff.

SFS will continue its work refreshing internal security policies and ensuring alignment with Treasury Board’s security policy evolution. This work will also include clarification and consistency regarding roles and responsibilities for the overall BCPP, which will be presented to OC for approval.

  • Draft Policy on Corporate Security submitted for approval - Q4, FY 2018/19
  • Prepare BCP Governance document for approval - Q3, FY 2019/20
  • Update subsequent security policy instruments (4) – Q3, FY 2019/20

Low Priority Observation #4

Enhance BCP program effectiveness by reinstating the BCP working group with an expanded mandate to actively engage members in overseeing and integrating BCP activities in the organization.

Public Safety and Emergency Preparedness’ Operational Security Standard – Business Continuity Planning requires that the BCP Coordinator (BCPC) establish working groups and define their roles and responsibilities. In compliance with this requirement, OSFI’s Directive on BCM includes, as part of the roles and responsibilities of the BCPC, the requirement to chair a working group on BCP with the aim of reviewing, monitoring and updating the BCP program. The working group is to include representation from all sectors and corporate, functional and operational areas of OSFI.

OSFI established a BCP working group in 2016, including cross-sector representation, with the responsibility for providing strategic considerations for the enhancement of the BCPP and to aid the BCPC in implementing and monitoring activities to support the program. Sector Leads were responsible for the appointment of participants as well as replacements should those participants vacate their positions. The BCP working group is currently not meeting quarterly per the working group terms of reference.  This lack of engagement has been attributed to resource constraints in SFS and sector member turnover without an appointed replacement. With the BCP working group inactive, SFS is missing the opportunity for employee involvement to aid the BCPC in executing the BCP program.

Securities and Facilities Services should revisit the working group and its membership to include the representation of BCP Team Leaders for business units, and consider revising the mandate to include operational tasks, to help facilitate regular testing, monitoring and training, as well as identifying opportunities for improvement to the program.

SFS will propose updates to the terms of reference of the Business Continuity Planning Working Group (BCPWG) in order to ensure appropriate accountabilities and operational focus. The terms of reference will be presented to the OC for review and approval along with seeking their support for a renewed, engaged and representative membership on the BCPWG.

  • Present updated terms of reference for the BCP working group to OC for approval - Q2, FY 2019/20
  • Reinstate BCP working group – Q3, FY 2019/20
  • Define and propose training and awareness program – Q3, FY 2019/20

Observation Ratings

Observations are ranked in order to assist management in allocating resources to address identified weaknesses and/or improve internal controls and/or operating efficiencies. These ratings are for guidance purposes only. Management must evaluate ratings in light of their own experience and risk appetite.

Observations are ranked according to the following:

High priority - should be given immediate attention due to the existence of either a significant control weakness (i.e. control does not exist or is not adequately designed or not operating effectively or a significant operational improvement opportunity.

Medium priority – a control weakness or operational improvement that should be addressed in the near term.

Low priority - non-critical observation that could be addressed to either strengthen internal control or enhance efficiency, normally with minimal cost and effort.

Individual ratings should not be considered in isolation and their effect on other objectives should be considered.

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BCP Long Form Template & Resources

If you are developing a Business Continuity Plan or trying to prepare your administrative, research, or academic unit to resume essential and  critical functions and services following an emergency, you may benefit from the following tools:

Your BCP in 5 Steps : A Business Continuity Plan (BCP) can be as long or as short as a department, unit or division requires – there is no one size fits all, and not everything listed in the 5 steps will be relevant to your area . Click on the tab at the top of the page to work through your BCP needs in 5 steps (guidance provided).

BCP Template  –  this is a long form, very detailed template for customization by units (includes general information; action items to increase your unit’s readiness; information & strategies for operating during a crisis); a short form guidance site is under construction as of January 2023.

EHS – for information on assessing and mitigating hazards in the workplace, and assistance on occupational health evaluation and related preparation

Access to additional UofT Resources – In cases of extraordinary operational interruptions when divisional resources (e.g., people, expertise, funding) are insufficient to maintain/resume operations in accordance with the University’s mandate, Divisions should submit their intention to request resourcing to [email protected].   Requests must be submitted by the Division Head (i.e. Dean, Campus Principal) with a carbon copy to the Divisional Chief Administrative Officer (CAO). Units can use the process map to determine their route of request.

External Resources:

City of Toronto’s Guide to Business Continuity Planning

Additional sites with useful information:

  • Canadian Center for Emergency Preparedness
  • Canadian Red Cross

NOTE: Public Safety Canada’s Guide to Business Continuity Planning (link disabled following August 2022 Audit of the federal government’s Business Continuity Planning Program which found that “ The 2013 Business Continuity Plan was neither operationally tested nor was it updated to reflect the 2015 assessment of the Department’s critical services.”)

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Build a future-ready resilience program.

Global Crisis and Resilience Survey, Canadian outlook

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A guide to business continuity planning : D82-37/2003E

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This booklet discusses the basics of business continuity planning—planning to ensure that critical operations continue to be available during emergencies, such as natural disasters and power and energy disruptions. It sets out the components of a business continuity plan, how to handle a disruption, and where to find additional information.

Permanent link to this Catalogue record: publications.gc.ca/pub?id=9.648832&sl=0

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Navigating the business continuity regulatory landscape in Canada

Ottawa River and Alexandra Bridge from Ottawa to Gatineau city of Quebec, Canada

Three in every four companies without a business continuity plan fail within three years of a natural disaster. Max Veve assesses Canadian regulation designed to prevent this.

By failing to prepare, you are preparing to fail, said Benjamin Franklin. Two centuries later, this quote continues to resonate with many, especially in the business world. It has, for instance, been estimated that 75% of companies without business continuity planning fail within three years of a natural disaster (see FEMA Grant to Create Economic Recovery Training Program for US Businesses . )

With such a high failure rate, how should one go about preparing its organization for the unexpected? This article aims to answer this question by reviewing Canada’s business continuity regulatory landscape, referencing standards and guidelines in the financial services sector from several of Canada’s federal and provincial regulatory agencies.

Business Continuity Policy

It all starts with a business continuity policy. The Financial Market Authority in Quebec (AMF in French) provides a comprehensive guideline as to what should be included in a “sound and prudent business continuity management” (BCM) policy :

  • Responsibility of the board and senior management : The AMF expects that the board of directors approves the BCM policy and appoints a member of senior management to oversee BCM. This executive should ensure the effectiveness of the program and promote BCM within the organizational culture. He/she should report to the board and participate in the resumption of activities after major business continuity incidents. He/she should also ensure that necessary resources are allocated to the BCM program.
  • Roles and responsibilities (R&Rs) : The R&Rs of all parties involved in the business continuity management process are to be defined and documented. The three lines of defense model developed by the Institute of Internal Auditors provides a framework for this assignment. The first line is composed of business line managers involved in the delivery of products and/or services. The second line, made of business continuity practitioners, is to provide assistance with managing continuity risks. The third line, made of internal auditors, is to provide independent quality assurance of the BCM program.
  • Training and awareness : Employees should be properly trained on their roles as it pertains to business continuity. Employees with primary recovery responsibilities should be trained to develop automatic reflexes and deep understanding of the business continuity process.
  • Testing : The AMF expects “modular testing at various intervals and on a regular basis” of an organization’s business continuity and disaster recovery plans. Such exercises should aim to verify the organization’s capacity to recover its operations and the time required to do so. In this sense, the Montreal Exchange requires that business continuity tests be carried out at least on an annual basis (See Rules of the Montréal Exchange. Article 3,102 ). Moreover, though not mandatory for all financial institutions, it is recommended to participate in industry-wide business continuity testing like the one organized every two years by the Canadian Investment Regulatory Organization ( CIRO ).
  • Risk assessment : The AMF expects that the organization identifies major incidents with the potential for operational disruptions. These incidents are to be assessed based on their likelihood of occurrence and the potential impacts to the organization. Factors to consider when assessing probable incidents include geographical location, potential duration of impacts, predictability, and propagation speed.
  • Business Impact Assessment (BIA) : The BIA is the “foundation for a effective and efficient Business Continuity Plan (BCP) and Disaster recovery plan (DRP).” As explained by Deloitte , the BIA allows the organization to determine its critical activities and gather detailed information about the key resources (facilities, equipment, technology, human resources, dependencies, and vital documents) that support those activities. The business continuity policy is to provide the scope of the BIA, the risk categories to be assessed in the BIA as well as the frequency at which the BIA should be conducted.
  • Business Continuity Plan (BCP) : The BCP provides the recovery strategies and documents the resources needed for resumption following a business disruption. It needs to be practical and updated regularly. Some of the recovery strategies to be considered in the development of the BCP include establishing a business recovery site to be used in the event of a loss of access to the business’s primary work facilities. Additionally, a disaster recovery site where core IT infrastructures can be failed over to, in the event of a loss of the primary data center, is to be considered. A succession plan with a skills matrix also needs to be developed to address potential human resources risks especially during pandemics situations. The business continuity policy ought to provide the general framework upon which the BCP is to be built.
  • Crisis Communication Plan : The BCP policy should reference a communication plan that is to accompany the business continuity plan during a crisis. The communication plan sets guidelines in interacting with the media, emergency services, partners, and suppliers.

Third Party Risk Management (TPRM) Policy

The Office of the Superintendent of Financial Institutions (OSFI) in its B-10 guideline published in April 2023, provides a comprehensive framework of the continuity risks that are to be monitored as part of the organization’s TPRM policy.

  • Pre-contractual due diligence : OSFI expects the business continuity and disaster recovery plans of third parties to be examined before any relationship agreement. These plans must be checked for quality and the frequency at which they are tested. The goal is to assess whether the third party has the capability to provide critical services following a disruption. Moreover, the continuity risks stemming from the third party’s subcontractor relationships must also be monitored. It is to be determined whether these relationships provide any concentration risks for the organization. Depending on the criticality of the service, joint design and testing of continuity plans must also be considered.
  • Ongoing due diligence : The third-party risk management process must not stop after the signing of the contract. Ongoing due diligence is required to ensure that the third party maintains its business continuity capabilities. Contractual agreements should, therefore, require at minimum that the third party’s continuity and disaster recovery plans be tested regularly. The results of those tests along with plans to address any material deficiencies must be promptly communicated and reviewed.
  • Recovery & Exit Strategy : In addition to ensuring that third parties have sound continuity plans, organizations must ensure that their own business continuity plans address scenarios where critical third parties could become unavailable during extended periods of time. The organization must also document exit strategies providing information about alternative suppliers, potential cost, and timeline for replacement.

In summary, to prepare for operational disruptions and unexpected business events, an organization needs at least a sound and prudent business continuity management policy supplemented by a third-party risk management policy.

The business continuity policy provides the general framework that helps the organization in identifying its critical activities and documenting the resources and strategies needed to keep the organization afloat during periods of operational disruptions. The third-party risk management policy provides a framework to manage and minimize continuity risks stemming from third party contractual arrangements.

As shown by the COVID 19 pandemic, only organizations who prepare for the unexpected fare well during times of crisis. Quoting Benjamin Franklin, diligence indeed is the mother of good luck.

This article is geared toward business continuity practitioners and people with working knowledge or interest in the industry. This publication is made in my name and is not endorsed by any organization or institution that I may be affiliated with.

Max Veve is a certified business continuity professional with experience in Business Continuity Management, Disaster Recovery, and Third Party Risk Management in the financial and extractive industries (Oil & Gas and Mining).

He is currently the Business Continuity Manager for Societe Generale’s Canadian division.

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Business Continuity Certificate

While an organization cannot predict the next big disruption such as a fire, flood, cyberattack, or pandemic that may occur, building capacity to be able to continue to meet its operational goals is vital to its resilience and long-term viability. An effective Business Continuity Management Program (BCMP) can minimize business disruption and increase organizational resiliency.

• Create practical frameworks for creating and maintaining a BCMP. Establish a business continuity policy defining how the program should be implemented and maintained including strategies that ensure an organization can thrive through disruptive events.

• Develop a Business Impact Analysis that identifies the critical activities involved in implementing time-sensitive processes and requirements when responding to disruption. This is one of the most important aspects of a BCMP as functions consist of inter-related tasks and processes; interruption to one impacts others.

• Create effective Business Continuity Plans that ensure a business can continue to operate throughout a disruptive event. Strategize and implement continuity options based on risk impacts and recovery requirements.

• Develop Continuity of Operations Plans to address essential and zero-down-time processes and functions. Identify essential services of a business and the resources required to provide those functions during an emergency or disruption.

• Changes are inevitable and have the potential to invalidate the effectiveness of a well-designed BCMP. Develop program sustainment processes to ensure the BCMP is current, complete, continuously improved, and that those implementing the program are ready.

Our instructors are industry experts with real-world continuity and crisis management experience. Learn from experienced professionals and enhance your business continuity skills.

The Business Continuity Certificate of Achievement is comprised of four micro-credentials: • Designing and Implementing a BCMP (CDEM302); • Risk Assessment and BIA (CDEM303); • BCP Development and Strategies (CDEM304 and CDEM305); • BCMP Sustainment (CDEM306)

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Earn NAIT Micro-credentials in Business Continuity

A  micro-credential  represents recognition of employer-valued competencies and skills. They are sharable on your social channels and prove upskilling to prospective or existing employers and managers.

After successfully demonstrating competency through  assessments based on real world situations, you will accelerate your professional development and earn NAIT micro-credentials in the area of study.

Designing and Implementing a BCMP

This micro-credential is awarded upon completing CDEM302 - Designing and Implementing an Integrated Business Continuity Program.

Risk Assessment and BIA

This micro-credential is awarded upon completing CDEM303 - Business Impact Analysis for Continuity Planning.

BCP Development & Strategies

This micro-credential is awarded upon completing CDEM304 - Building a Business Continuity Plan and CDEM305 - Continuity of Operations.

BCMP Sustainment

This micro-credential is awarded upon completing CDEM306 - Business Continuity Management Program (BCMP) Sustainment.

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While an organization cannot predict the next disruption, building capacity to continue to meet its operational goals is vital. Business Continuity can minimize disruption and increase resiliency.

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  • Blended: Where: Mixture of in-person & online components.  When: Course is scheduled at a specific time for students to attend. Combination of face-to-face and online components at specific times. Some online components may be accessed online anytime.
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Planning Update: Tax and Benefit Administration and the COVID-19 Pandemic in 2020–21 

Introduction.

Each year, the Canada Revenue Agency (CRA) prepares a Corporate Business Plan (CBP) and Departmental Plan (DP). The Summary of the CBP and DP are tabled in Parliament and are important tools to inform Canadians of how the CRA intends to use its resources to fulfill its core responsibilities of administering tax and benefit programs. The CRA ’s CBP and DP for fiscal year 2020–21 with perspectives to 2022–23 were developed prior to the COVID‑19 pandemic.

This planning update describes the impact of the COVID-19 pandemic on the CRA ’s previously reported plans for fiscal year 2020–21. It provides the most current information available as of September 2020. As the pandemic continues, it may have additional impacts on the CRA ’s plans.

The pandemic required the CRA to rapidly launch new programs to deliver on the Government of Canada’s Economic Response Plan. The CRA ’s work in recent years to transform into a client-centric, digital organization positioned it well to respond to the pandemic and support Canadians in this difficult time. However, the magnitude of the effort and the need to adapt to the changing public health and economic circumstances have impacted our operations this year. Moreover, in an environment where cybercriminals and scammers continue to use more sophisticated means against the CRA and our clients, we will continue to adapt our practices to protect our clients’ personal information and build their trust in us.

Contextualizing our priorities

The CRA and its Board of Management remain committed to the following five priorities:

  • Providing a seamless service experience
  • Maintaining fairness in Canada’s tax and benefits administration
  • Strengthening trust, transparency and accountability
  • Enabling innovation
  • Empowering our people to excel

These priorities will continue to guide the delivery of the CRA ’s core responsibilities. They have proven to be essential to the CRA ’s operations during the pandemic and responding to the evolving needs of Canadians. As the CRA continues to deliver emergency measures, it has placed service and empathy at the forefront in all of its interactions, while continuing to provide accurate information and promote compliance to ensure the tax and benefits administration remains fair for all Canadians. 

We recognize maintaining this fairness, particularly in the administration of emergency measures, is fundamental to Canadians’ trust in us. Despite the CRA ’s actions to combat scams, identity theft happens every year, and cyber incidents are a regular occurrence. Scammers acquire taxpayers’ personal information through a variety of means, such as phishing scams and data leaks or breaches stemming from organizations outside the CRA . As scammers adapt their practices, so does the CRA . We routinely monitor accounts for suspicious activity to detect, prevent and address potential instances of fraud and identity theft, whether or not this activity is related to cyberattacks. The CRA works to quickly notify individuals whose accounts may have been compromised and offers credit protection services free of charge to help prevent fraudulent activity. Additionally, we will continue to work diligently to identify threats to the security of information and improve cyber security, to prevent and detect fraud and the misuse of information. 

Finally, the CRA is ensuring that the workplace—whether at home or in office—is healthy and safe, and employees have the tools and support they need to continue to deliver emergency measures and provide service to Canadians. 

A primary focus of the CRA this year will be to ensure that the new and essential COVID‑19 emergency measures are effectively implemented and managed to support Canadians and businesses facing hardship as a result of the pandemic. The COVID‑19 pandemic has impacted the 2020 tax filing season and is expected to affect the CRA ’s overall performance and delivery of commitments to Canadians outlined in corporate plans for 2020–21, with potential impacts in 2021–22 as well. We will provide a full account of these impacts in future departmental results reports. The CRA will also continue to track and report online on the delivery of emergency measures.

Administering emergency measures in response to the COVID‑19 pandemic

The COVID‑19 pandemic has had an unprecedented impact on the lives of Canadians. The CRA ’s vision of being trusted, fair and helpful by putting people first has guided our actions to support clients during this pandemic. As part of Canada’s COVID‑19 Economic Response Plan, the CRA took action to help clients facing hardship, while ensuring that any privacy implications were reviewed, mitigated, and addressed when required. A complete catalogue of  changes to CRA services, due dates and programs affected by the pandemic is available on the CRA and COVID-19 web page.

In response to the pandemic, the CRA is administering the following emergency measures:

  • the Canada emergency response benefit (CERB), to provide income support for people facing unemployment, who are sick, quarantined, or in directed self-isolation
  • the Canada emergency student benefit (CESB), to provide funding for post-secondary students and graduating high school students who do not qualify for the CERB
  • the Canada emergency wage subsidy (CEWS), to support employers and protect jobs
  • a one-time special payment through the goods and services/harmonized sales tax (GST/HST) credit, to provide additional income support for low income individuals
  • the temporary wage subsidy (TWS), to support eligible employers by reducing the amount of payroll deductions required to be remitted to the CRA
  • a one-time payment increase of an extra $300 for each child, under the Canada child benefit (CCB), to deliver additional support for families with children already receiving the CCB
  • support to the provinces and territories by providing assistance to deliver additional tax credits or benefits

To add integrity to the administration of the CERB and CESB and to guard against instances in which individuals may be defrauded, the CRA increased its requirements for applications. This will help the CRA complete applications securely. 

The CRA is also providing flexibilities to help clients through the pandemic, including:

  • extension of certain filing and payment deadlines that may pose unnecessary strain on individuals, businesses, trusts and charities
  • continuation of benefit payments, such as GST / HST credit and CCB , until September 2020 for those who are unable to file their tax return on time
  • temporary waiver of interest on existing tax debts related to individual, corporate, and trust income tax returns to ensure existing tax debt does not continue to grow through interest charges during this difficult time
  • focus on higher dollar audits first, audits close to completion and prioritizing actions that are beneficial to the taxpayer or where taxpayers have indicated there is an urgency to advancing their audit
  • deferral of other CRA actions that might pose a burden on clients, including suspending collections activities on all debts, except for high‑risk cases
  • temporary administrative policies to reduce or eliminate unintended tax effects of COVID‑19 travel restrictions on individuals and corporations
  • alleviation of cash flow pressures on businesses, including processing scientific research and experimental development tax credits and issuing payments
  • flexibility in the use of communication methods where an interaction with the taxpayer has already been initiated for audit and complex special election returns processes

The CRA is continuing to offer tax and benefits administration services while adjusting to respect public health advice where required. This includes:

  • adapting the Outreach Program and Liaison Officer Program, traditionally available in person, to be accessible over the phone to provide urgently needed information for clients, including small businesses and self-employed individuals
  • supporting free virtual tax clinics hosted by community organizations, by videoconference or phone, through the Community Volunteer Income Tax Program (CVITP) and the Income Tax Assistance – Volunteer Program in Quebec
  • implementing the new Individual Tax Filing Assistant Project to help certain clients file their tax returns, such as clients eligible for the CVITP
  • accepting electronic signatures on forms to authorize a representative to file income tax returns electronically on behalf of individuals or corporations, to meet the evolving expectations of taxpayers and electronic filers and to reduce administrative burden
  • continuing to deliver critical services, such as processing requests by clients that result in issuing refunds or tax credits or benefits, adjustments and clearance certificates

The CRA will continue to engage stakeholders to ensure its approach remains world-class and communicate clearly as the pandemic evolves. Specifically, we will:

  • work with international partners, such as the Forum on Tax Administration (FTA), to share guidance and best practices on tax administration responses to the COVID‑19 pandemic, including the implementation of fiscal measures, and ensuring business continuity
  • engage provincial and territorial tax administrations to keep them informed and, where appropriate, coordinate activities
  • communicate regularly with members of the tax community, including industry associations, to provide updates and clarity regarding  measures being taken to help clients

Ensuring the continuity of business and employees’ connectivity

In response to the COVID‑19 pandemic, the CRA implemented a national COVID‑19 Business Continuity Plan to ensure the delivery of critical services. During the initial phase of the plan, we implemented timely measures to ensure the connectivity of all employees. The actions the CRA has taken have been in collaboration with the unions. This relationship has been key in supporting workforce agility throughout the pandemic.

The CRA will continue to foster a thriving workforce by supporting employees, the majority of whom are now working remotely, through technology and processes, including:

  • increasing secure remote access (SRA) infrastructure to enable more users to connect to the CRA network remotely, and providing more bandwidth for those connections
  • providing equipment and changing paper processes to make them digital, to ensure the ability to work remotely
  • reviewing and adapting various internal mechanisms, policies, guidelines, and procedures to ensure they are relevant and able to support the CRA ’s response to the COVID‑19 pandemic

Resuming business during the COVID‑19 pandemic

The CRA ’s plans for resuming business during 2020–21 will be strategic and incremental, taking into account employee safety and readiness, program readiness, compliance risks, public awareness and opinion, tax policy priorities, and our clients’ resilience. We will focus on the areas that are most important in terms of service, and address the most egregious cases of non-compliance.

Employees’ and clients’ health and safety are the CRA ’s primary concern. In this regard, we have based our health protocols on guidance from the Public Health Agency of Canada and Health Canada, as well as local public health authorities. It is expected that most employees will work remotely for the foreseeable future. CRA buildings will continue to follow health guidelines so that CRA worksites can be kept safe for employees who have continued to work from or need to return to them. Similarly, the CRA has developed protocols and risk mitigation procedures for exceptional cases where in-person interaction with clients is needed.

The CRA will also continue to support employee psychological health through the use of the Employee Assistance Program and as guided by our well-being strategy.

Our business resumption is rooted in our core values and beliefs as an organization. The CRA ’s vision of being trusted, fair and helpful by putting people first is at the core of our approach to resumption, especially with so many individuals and businesses still facing the impacts of the pandemic. This means supporting our clients facing hardship and assisting them to meet their tax obligations. Since spring 2020, we have progressively resumed compliance operations, and by the fall, we expect to have in place a more focused version of all of our compliance programs. Our audit efforts will be focused on the highest risk cases. It is important, now more than ever, that we prioritize an empathetic approach as we resume regular activities.

Clear, up to date, consistent and frequent communications on all decisions regarding business resumption will be essential. The CRA will use national, regional and local messages to communicate with employees and external stakeholders.

Seizing opportunities as we adapt

The need to adapt quickly and in some instances, assume the responsibility of delivering new programs, has demonstrated the resilience of the CRA and its employees. While the pandemic continues to be a challenge, it also provides the opportunity for innovation as the CRA resumes its business and adapts to the changing circumstances of a low-contact and physically-distant reality.

Our response to the pandemic allowed us  to accelerate our digital transformation while maintaining clients’ privacy at the centre of our preoccupations. Our digital transformation is driven by our priorities to provide seamless service to Canadians; to strengthen trust, transparency and accountability in the CRA ; and to enable innovative ideas and ways of working.

In 2020–21, the CRA will continue to accelerate its digital program to integrate modern technology and practices in the following areas:

  • delivering high quality interactions across all channels and programs
  • collaborating with clients, industry, and other government entities to drive shared innovation as well as improvement in tools, services and mindsets
  • modernizing practices and approaches to enable greater organizational flexibility
  • preparing the organization to realize the potential of digital transformation

The CRA has identified and enhanced measures to empower our people as they work. The CRA has sharpened its focus on enabling a workforce that will predominantly be working remotely. To this end, the CRA will continue to equip employees and explore technology and tools to help them be more effective in their role, while supporting their physical and psychological health and safety. We will also consider our traditional approach to the geographic scope of staffing exercises in light of the realities of working more remotely and the opportunity to employ a workforce that best meets the needs of our transformation.

Increased worldwide attention on systemic racism gives additional impetus to our ongoing efforts to foster a workforce that represents Canada’s diversity, while continuously creating an environment where individuals are safe to be themselves. The CRA will enhance efforts to eliminate systemic discrimination, and harassment.

Working remotely has the benefit of reducing greenhouse gas (GHG) emissions from employee commuting while restrictions to travel and the use of technology to participate virtually in meetings will reduce the GHG emission from business air travel. The increased digitization of paper processes is also expected to decrease our consumption of paper. These results align with the CRA Departmental Sustainable Development Strategy 2020 to 2023.

The pandemic has inspired us to intensify our transformation to a more people-centric organization. Although the pandemic may continue to require physical distancing, we must continue to keep people at the centre of how we deliver programs and services in this changing environment. It is ultimately people who have been impacted by the pandemic, and we will increase our efforts to be empathic as we deliver emergency measures alongside our tax and benefit programs.

The way forward

The CRA demonstrated its agility in responding to the pandemic. We mobilized people and allocated resources to key priorities and were open to accepting more risk in favour of faster delivery of projects. We will learn from this experience and challenge ourselves to apply this knowledge in different situations.

One of the lessons that we will take forward is the resilience of our priorities even during moments of great change and uncertainty. When the need arose for thousands of CRA employees to deliver new programs to Canadians, providing seamless service and sincere empathy emerged as the most important considerations. Maintaining fairness informed the CRA ’s decision to be flexible in helping people affected by the pandemic. We continue to prioritize transparency and accountability to ensure that trust remains strong. We are delivering the programs identified in the GC Economic Response Plan by cultivating an environment that enables innovation and ultimately, empowers our people to excel.

The CRA will continue to conduct all of its activities with the utmost integrity. In 2020–21, we will carefully verify the eligibility of our clients for the new programs launched during the pandemic, focusing on compliance actions to address issues such as misuse and fraud. We will apply a respectful approach, even when investigating fraudulent claims for emergency benefits.

A key concern of Canadians is the constant threat of increasingly sophisticated cybersecurity threats. As noted in the CRA Privacy Management Framework, the CRA is committed to upholding the trust that Canadians place in our organization. To meet their expectations, the CRA is continuously enhancing its security controls, and managing a wide range of security risks in a fast-changing and sophisticated threat environment. We will continue to make investments in security to protect data, information assets, and information technology structure from these threats.

As stated in our Corporate Business Plan, innovation is the positive change that is required to adapt to current challenges and changing circumstances. Our organization’s innovative mindset has been essential to delivering the Government of Canada’s response to the pandemic. As we move forward with resuming our regular business, this mindset will continue to play an important role, as we consider how the lessons learned during the pandemic can drive innovation. It is, furthermore, the resiliency of our people and their ability to handle the shifts in focus that made managing the pandemic possible and will continue to be essential in managing the way forward. Our people are fundamental as we strive to be a world class tax and benefit administration that is trusted, fair and helpful by putting people first.

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