BUSINESS CONTINUITY PLAN
Summary and objectives:
Provident Investment Management Inc. (“the Company”) has developed this plan to ensure, to the best of its ability, that it will restore reasonable functionality in the event of emergency. This document spells out the Company’s policies and procedures in the event of loss of use of physical premises, computer equipment and communications capabilities.
I. Emergency declaration and initial contact
In the event of an emergency, Scott Horsburgh as President and Chief Compliance Officer, will declare an emergency and serve as the primary contact. Scott will attempt to make initial contact with every employee. Should any material impairment in the Company’s capabilities occur and Scott not make contact, Dan Boyle, Miles Putnam, or James Skubik may also assume such a role if they have not been contacted within one business day of an apparent emergency.
The attached emergency contact list will be updated as necessary. All employees must report changes of address, phone number, cell phone number or primary email address to Scott.
If broad-scale interruptions prevent us from locating each other, all personnel should contact Schwab Advisor Services at 855-950-4603.
II. Events of emergency
a. Fire
In the case of a fire, be it in the office of Provident or in the building in which Provident maintains its offices, provided the building is safe to enter, all files, records and computers will be transported to the home of Scott Horsburgh until new office space is secured. This residence is capable of supporting business and has phone and internet access. The phone of Provident would be forwarded to the temporary location of the business and all clients would be notified via phone of the situation and our method of response. All communication with vendors takes place via phone and internet in our current offices and would be the same in the case of a residence.
If the building were not safe to enter and all equipment and files were lost, the physical copies of all account agreements are stored on our server. Temporary office space would be secured. New computer equipment would be purchased.
b. Power Outage
In the case of a power outage, the same procedure outlined in the case of a fire would be used if the outage was local or site specific to our offices. If the outage was regional, we would be forced to move our equipment to a location that had power and internet access in order to run the business.
c. Phone/Internet Service Failure
Provident utilizes a phone and Internet service provider utilizing always-on, high-speed, connectivity. This technology allows all methods of communication to be on one line and under the responsibility of one vender. If there was an outage, employees would use cellular phones and instruct our telephone vendor to forward the main number to one of the phones. As long as we have phone and/or internet service, we are able to make trades and manage portfolios.
d. Theft
All information and documents of a confidential nature are maintained in the office of Provident and locked on a daily basis when the offices are closed. Building management does not have a key to the room. Our server is in the process of being retired with all data already migrated to “the Cloud,” maintained by Microsoft. Until such time as the server is retired, the server that contains confidential information is only accessible by password. In the event that the server was stolen, it could be replaced and uploaded with the data within one business day.
III. Restoration of functionality
a. Scott and all available personnel will assess the degree of impaired functionality and determine the next course of action. This section outlines the plans established to deal with a variety of impaired functions.
b. Alternative premises
i. In the event of loss of use of the current office, Scott’s home will be the initial gathering location.
ii. The post office and custodians of client assets need to be notified of the new address.
c. Critical functions:
i. SharePoint/OneDrive files
ii. Tamarac Reporting
iii. Tamarac portfolio management and trading
iv. Highrise client contact manager
v. Client trading and cashiering functions (Schwab)
vi. Capital IQ Pro from S&P Global
vii. Securities analysis (BetterInvesting Online Tools, STKVAL spreadsheet)
viii. Office functions (computers, inbound communications, internet connection, corporate accounting)
d. Alternative provisions
i. SharePoint/OneDrive is in the cloud and accessible at alternate locations.
ii. Tamarac is in the cloud and accessible at alternate locations
iii. Highrise is in the cloud and accessible at alternate locations
iv. Client trading and cashiering functions (Schwab)
Client trading and cashiering can be accessed via the internet www.SchwabInstitutional.com. In the event of further loss of functionality, trading and cashiering can be handled through any Schwab branch or by phone (see attached sheet with Schwab phone numbers)
v. Capital IQ is in the cloud and accessible at alternate locations
vi. Securities analysis functions and tools are available in the cloud
vii. Office functions (computers, inbound communications, internet connection, corporate accounting)
1. Computers – we own and maintain a laptop for emergency use; this laptop contains necessary software to run the mission-critical functions identified in II.c. For temporary use, the Horsburgh household has four computers with basic functionality, including internet connections
2. Inbound communications – clients will be instructed to use our 800 number after declaration of emergency. This number is on the letterhead used in all client communications, on our business cards and our web site. Our ADV has been amended to include directions to use our 800 number in the event of emergency. Our telephone carrier will be instructed to port the 800-449-6970 number to an alternative number.
3. Corporate accounting - corporate books are kept on Quickbooks, an off-the-shelf bookkeeping program which is accessible in the cloud.
viii. We have been assured by our IT consultant, N2M Technology, that basic functionality can be restored within 24 hours using established backup/restore procedures.
IV. Data backup and Recovery - Our server is in the process of being retired with all data already migrated to “the Cloud,” maintained by Microsoft. Until such time as the server is retired:
a. Provident employs “Mirroring” technology on each data server(s). “Mirroring” implements an additional storage drive that mirrors - a complete copy and duplicate in real-time of each and every action - the main drive and creates a real time on-site backup. If the primary storage drive should fail, the machine will be able to switch to the mirror (additional) storage drive and use it as the primary. This allows for no loss of data and more importantly minimal interruption of business.
b. As a secondary backup, Provident employs the services of a secure, internet based, off-site data backup. This automated backup technology uses a secure internet connection to create a backup of our data server(s) off-site on an ongoing basis throughout each day. This removes the risk associated with fire or theft destroying the data and also allows for data restoration at another location should a disaster occur that requires such a restoration.
c. Finally, Provident has a redundant server prepared to assume the workload should any of the primary server(s) fail. This will allow Provident to continue to operate while any primary server(s) are repaired. These redundant systems allow for Provident to resume essential business operations with little to no interruption of daily business activities.
V. Re-establishment of communications with clients.
a. Personnel not required to handle securities analysis, portfolio management and client needs will contact all clients as soon as possible and by any means possible. We may not have sufficient telephone connectivity at a backup location, and personnel may need to use cell phone or home telephones. Each client will be given alternative contact information, including the cell phone or home phone number of at least two Company personnel.
VI. Other key contacts:
Building management:
On-site management – John Brien
Insurance – Meg Spinale Insurance Agency (State Farm) – 248-647-4870
N2M Technology (technology and telephone support vendor) 248-247-2626
Email help@n2mtech.com to open a N2M service request
Tamarac: 844-322-2855
Envestnet Tamarac – 800-528-9595
Nextiva : 800-285-7995