MP289 'BCDR Engagement'

The Data Communications Company (DCC) approach to Business Continuity and Disaster Recovery (BCDR) Testing has evolved since SECMP0029 ‘Business Continuity and Disaster Recovery Testing Amendments’ was implemented in 2018. The DCC feels that the current requirements do not take the DCC approach to testing into account and, as a result, the current Smart Energy Code (SEC) Party engagement requirements are no longer appropriate in every instance of BCDR testing.

Some testing does not impact DCC Users or services. For example, desk-based exercises like discussion-based, scenario and/or simulation testing, as well as tests which run in parallel to other activities. Furthermore, some BCDR testing is completed as part of Planned Maintenance and the SEC requires the DCC to notify SEC Parties 20 Working Days before the start of the month where there is Planned Maintenance activities scheduled rather than 60 Working Days in advance.

To complete engagement and notification activities efficiently, the DCC consults and notifies for a full calendar year of BCDR Testing. Therefore, the planning for BDCR Testing starts many months in advance. Which this is efficient, it can increase the likelihood of amendments needing to be made and further engagement being required.

It should also be noted that SEC Parties currently have no formal visibility over how the DCC approaches its BCDR Tests in terms of the assessment on, and the approach to, testing.

The Proposer is seeking to amend Section H “DCC Services” 10.12A and H10.12B so that engagement and notification requirements only apply where BCDR testing is expected to impact the provision of DCC services.

For the avoidance of doubt, the DCC will continue to include all BCDR testing in its annual consultation as it does now. However, not applying the notification and engagement requirements for BCDR tests that are not expected to impact the provision of services will allow greater flexibility for change throughout the year if needed for these tests.

The Proposer is also looking to add new Section H10.12C to include requirements on the DCC to formalise the production and availability of the DCC BCDR Testing Approach document, these requirements include:

• The DCC publishing the BCDR Testing Approach Document on the DCC website, for information purposes;
• Ensuring the document is kept under review and updated as may be required from time to time;
• Ensuring the document includes, as a minimum, the following information:
  • BCDR Testing approach (planning, execution, post-test reviews and testing of new services before go-live);
  • Future considerations for opportunities to reduce the impact to Service disruption; and
  • Engagement approach with Parties and notifying them of BCDR testing.

For the avoidance of doubt, the DCC has not sought a review of (or made any amendments to) the current approach to BCDR testing as part of this Modification and have only sought to make available more detailed information about the approach.