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Balancing remote working with compliance in the financial services sector.

Business Continuity Expo And Conference : 31 March, 2008  (Technical Article)
Graham Chick of GemaTech details the options available to financial services companies for providing home working flexibility whilst remaining compliant.
Following the Financial Services Authority's (FSA) recent six week exercise into the potential affects of a flu pandemic, there is a growing awareness that the industry needs to introduce more flexible ways of working. If business as usual is to be in any way possible during times of restricted travel, closed schools and offices, organisations need to enable staff to work remotely.

However, for many financial services companies, working remotely has been deemed impossible in a climate of escalating compliance requirements. How, for example, can an organisation ensure calls are recorded - both re-directed in-bound calls and outbound calls between home working colleagues?

Without such robust, proven solutions in place, remote working is simply not an option. So just how can the financial services sector balance its compliance strategy with the clear need outlined by the FSA for a flexible working strategy to deal with a major crisis, asks Graham Chick, Chief Executive, GemaTech

According to the government's own chief medical officer, Sir Liam Donaldson, it is a matter of when, not if, a flu pandemic develops over the next few years. And the affects of that pandemic will be far reaching - and long lasting. According to Professor Lindsey Davies, National Director of Pandemic Influenza Preparedness, between 25 to 50% of people in the country will have symptoms. At the peak of the pandemic, 15 to 20% of people will be absent from work. It has also been estimated that there will be up to 700,000 deaths and over one million could need hospital care - although it is readily accepted that there will be nowhere near one million hospital beds available.

The key message to minimise the spread of the disease: stay at home. And yet in the government's own 'Pandemic Influenza - checklist for businesses' it states that current planning assumes that domestic travel will not be restricted. Is it any wonder that UK businesses are struggling to ascertain the best business continuity plans?

It was to highlight some of the potential problems facing the financial services industry that the FSA undertook a six week market wide business continuity exercise on behalf of the Tripartite Authorities (Bank of England, HM Treasury and FSA). The exercise assessed how prepared the Tripartite Authorities and the financial services sector would be in the event of a flu pandemic. Around 70 firms took part, including the major participants in the financial services sector, the providers of key financial infrastructure such as payments, clearing and settlements and the main exchanges.

Over the six weeks of the exercise the scenario simulated the first five weeks of a flu pandemic. Participants assessed how organisations would cope as the pandemic grew progressively worse. One of the main issues to be highlighted by the exercise was the practicality of relying on home-working for key staff.

Whilst a significant number of the 70 or so participants decided, to a greater or lesser degree, to adopt flexible working, the FSA was surprised that the participants did not utilise home working more extensively. Indeed, from week two of the exercise, organisations experienced the impact of sudden absenteeism due to transport disruption and school closures. And by week five this had been made worse by bereavement issues as the death toll mounted.

There is absolutely no doubt that as and when the UK becomes embroiled in a flu pandemic, employees will make their own decisions about where they feel safest working, if they feel fit enough to work at all. Many will have no option but to work from home to care for family members who may be incapacitated by the virus, or, where schools have been forced to close, to look after children.

However, as the FSA exercise revealed, discussions on home working highlighted concerns over effective compliance and controls. And this is the challenge: if financial institutions are to embrace flexible working there are some serious issues to be addressed. To meet compliance requirements not only must incoming calls be automatically rerouted to the remote/home worker but both inbound and outbound calls must also be recorded.

In the rush to achieve a remote working strategy, there is also a danger that organisations will make rash assumptions about the viability of broadband technology for the transmission of both voice and data especially with its near ubiquity across the UK. In reality, Internet Telephony (VoIP) delivering voice calls to remote/home workers over the public internet will not be capable of delivering an acceptable quality of service during a pandemic. Whilst the technology itself is evolving, becoming more resilient and more secure, the broadband connectivity over which it travels is simply not up to the job.

The carrier/ISP standard offerings have up to 50:1 contention ratios. This means that each subscriber 'shares' the available bandwidth with up to 49 other subscribers who will all be trying to work remotely, causing time delays. Whilst a delay is probably tolerable when it comes to sending and receiving emails, during a telephone conversation this is simply unacceptable.

Nor does such technology deliver the robust voice recording solution required by the financial services industry. However, specialist telecoms vendors are now able to seamlessly recover 100% of incoming calls to office based individual geographical DDIs by intelligently re-routing them to any other number, or series of numbers, anywhere in the world, in a simple to use, cost effective manner. This means customers can continue to use the standard telephone number at any time during the pandemic, ensuring a better chance of achieving business as usual.

Using such solutions, the organisation is provided with the ability to voice record the re-routed inbound calls to employees who are working remotely. In addition, any subsequent outbound calls that may be made by the remote worker to any recipient can also be recorded - all using reliable, tried and tested and secure traditional fixed line telephony: the PSTN.

Furthermore, every recorded call can be automatically tagged and linked to the remote worker's data entries made on a remote PC, underpinning the compliance requirements. Voice records can be easily searched and accessed via the web - enabling compliance officers to continue to monitor behaviour and activity irrespective of location.

As the FSA exercise revealed, there is no question that financial institutions will have to implement flexible working strategies in order to ensure business as usual, should the flu pandemic take hold in the UK. And compliance is no longer a barrier. There is secure, reliable technology available today that meets the requirements of financial institutions, enabling employees to work seamlessly from home that also meets the increasingly stringent compliance requirements. Isn't it time for the industry to take remote working seriously?

Gematech (UK) will be exhibiting at the Business Continuity Expo and Conference held at EXCEL Docklands from 2- 3rd April 2008 - the UK's definitive event for managing risk, resilience and recovery. This event will explore the solutions and best practice to ensure operational continuity and protect a company's interests before during and after an incident.
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