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Version: 2018-001 July 24, 2018
1
Where are we now 3/3
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Planned or Unplanned Absence Course
Where are we now 3/3
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By failing to prepare, you are preparing to fail.
Benjamin Franklin
Where are we now 3/3
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This course is designed to:
1. Detail what is required in the event of a planned or unplanned absence
2. Demonstrate how to develop a comprehensive Contingency Plan
3. Encourage RCICs to apply risk assessment strategies to their Business Continuity Plan
Course Description
Version: 2018-001 July 24, 2018
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Where are we now 3/3
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� This course consists of two modules:
1. Planning for an Absence
2. Business Continuity Planning
� Networking opportunities
Course Overview
Where are we now 3/3
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Course Schedule
Module Content/Learning
Objective
Time
Allotted
Morning
Session
Afternoon
Session
Registration Networking Opportunity 15 mins 8:45-9:00 1:15-1:30
Opening Welcome and Course
Overview
10 mins 9:00-9:10 1:30-1:40
#1 Planning for an Absence 90 mins 9:10-10:40 1:40-3:10
BREAK Networking Opportunity 10 mins 10:40-10:50 3:10-3:20
#1 Planning for an Absence 35 mins 10:50-11:25 3:20-3:55
#2 Business Continuity Plan 60 mins 11:25-12:25 3:55-4:55
Closing Wrap-up 5 mins 12:25-12:30 4:55-5:00
Where are we now 3/3
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� Course completion
� Attend entire course
� Contribute to learning process
� Member feedback
� Questions are encouraged
� Learning environment
� Interactive
� Undivided attention
� Mutual respect
� Respect diversity
Course Expectations
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1. Do you own a consulting practice (e.g., sole proprietorship, corporation, etc.) or work for an immigration agency?
a. Yes
b. No
Activity
7
Poll
2. How many active clients do you currently have?
a. More than 20
b. 7-20
c. 1-6
d. None
Activity
8
Poll (cont’d)
MODULE 1: PLANNING FOR AN ABSENCE
9
Version: 2018-001 July 24, 2018
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Module 1: Client Records Requirements
At the end of this module, participants will be able to:
� Identify ICCRC’s requirements with respect to various types of
planned and unplanned absences
� Describe the impact of the Planned or Unplanned Absence Regulation on the Code of Professional Ethics and
Regulations
� Relate ICCRC’s Contingency Plan requirements to their current practice and set goals to assist in meeting the requirements
10
Module 1 Objectives
Module 1: Client Records Requirements
At the end of this module, participants will be able to (cont’d):
� Identify scenarios for selecting an Authorized Representative
and/or Responsible Person
11
Module 1 Objectives (cont’d)
3. A Planned or Unplanned Absence means:
a. Voluntary closure of practice, death
and incapacity
b. Suspension or revocation
c. Leave of absence, missing person,
or extended travel outside of the
country in which the RCIC
ordinarily resides and/or works
d. All of the above
Activity
12
Poll (cont’d)
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Module 1: Client Records Requirements
“Planned or Unplanned Absence” means voluntary closure of practice, death, Incapacity, suspension or revocation,
leave of absence, Missing Person, or extended travel outside of the country in which the Member ordinarily resides
and/or works
s.3.2.r, PUA Regulation
13
Planned or Unplanned Absence Regulation (cont’d)
4. A RCIC who owns an immigration/citizenship consulting practice is required to adhere to the Planned or Unplanned Absence Regulation
a. True
b. False
Activity
14
Poll(cont’d)
Module 1: Client Records Requirements
A Member who owns an immigration/citizenship consulting practice (e.g., sole proprietorship, corporation,
etc.) and a Member working as an employee for an immigration agency is required to adhere to this Regulation
s.4.1, Planned or Unplanned Absence Regulation (PUA Regulation)
15
Planned or Unplanned Absence Regulation
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5. Only RCICs who own a consulting practice are required to ensure that client interests are protected in the event of a planned or unplanned absence from the consulting practice
a. True
b. False
Activity
16
Poll (cont’d)
Module 1: Client Records Requirements
All Members are to conduct Client matters in accordance with the Code of Professional Ethics and associated
Regulations and ensure that Client interests are protected in the event of a Planned or Unplanned Absence from the
consulting practice
s.4.2, PUA Regulation
17
Planned or Unplanned Absence Regulation (cont’d)
Prepare for a planned/unplanned absence by:
1. Ensuring you are aware of ICCRC’s
requirements, and
2. Informing your staff about these
requirements
Activity
18
Activity
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Module 1: Client Records Requirements
Planned/Unplanned Absence PUA Reg
4. Official leave of absence for:
� Family reasons
� Medical reasons
� Full-time studies
� Working for government
� Unemployment
or travel outside of the country in which RCIC resides
and/or works for more than 30 days, during which
time the RCIC does not intend to perform the usual
duties of his/her consulting practice
� s.4.2
� s.4.4.e
� s.7.1
� s.7.2
19
Planned or Unplanned Absences
Module 1: Client Records Requirements
Planned/Unplanned Absence PUA Reg
5. Voluntary Closure of consulting practice � s.4.2
� s.5.1
� s.5.2
� s.5.3
� s.5.4
� s.5.5
6. Suspension � s.4.2
� s.6.1
� s.6.2
� s.6.3
� s.6.4
20
Planned or Unplanned Absences (cont’d)
Module 1: Client Records Requirements
Planned/Unplanned Absence PUA Reg
7. Incapacity � s.4.2
� s.4.4.e
� s.9.2
8. Missing Person � s.4.2
� s.4.4.f
� s.9.2
9. Death � s.4.2
� s.4.4.f
� s.9.2
21
Planned or Unplanned Absences
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Consider the impact of the Planned or Unplanned Absence Regulation on the Code of Professional Ethics and Regulations
Activity
22
Activity
You just received word that you have been accepted to volunteer abroad with refugees. Internet access will be very limited. You leave next month for a six-week placement.
What steps do you need to take
between now and then to ensure that
your consulting practice is well managed while you are away?
Activity
23
Activity/Discussion
Actively listen to Chetna Vishav’sexperience with a planned absenceActivity
24
Planned Absence
Story
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What lessons can be learned from the RCIC’s experience with a planned absence?
Activity
25
Activity/Discussion
Module 1: Client Records Requirements
Winding down versus Succession
Questions to consider when resigning/retiring:
� What is the value of the consulting practice?
� Will the consulting practice be wound down or sold?
� What will happened to staff/employees?
26
Voluntary Closure
You are in a severe car accident, which renders you unconscious for two weeks and unable to move/speak for another four weeks
How would you rate the impact of such an absence on your consulting practice (e.g., office processes and client files)?
□ Minimal to no impact
□ Some impact
□ Significant impact
□ Severe impact
Activity
27
Activity/Discussion
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Actively listen to the re-told experience with an unplanned absence
Activity
28
Unplanned Absence
Story
What lessons can be learned from this experience with an unplanned absence?
Activity
29
Activity/Discussion
What is a Contingency Plan?Activity
30
Discussion
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Module 1: Client Records Requirements
What is it?
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Contingency Plan – What
…a written set of instructions that details what steps will be taken either by the Member, and/or by the Member’s Authorized
Representative(s), and/or by the Member’s Responsible Person,
in the event of a Planned or Unplanned Absence, which would allow for the maintenance or winding down of the Member’s
consulting practice s.3.2.j, PUA Regulation
Module 1: Client Records Requirements
Why is it needed?
� Protects:
� Clients� Staff/Employees
� RCIC’s Family
� RCIC
� Addresses what will occur with RCIC’s consulting practice in
the event of a planned or unplanned absence (s.4.4, PUA Regulation)
32
Contingency Plan – Why
Module 1: Client Records Requirements
Who must have one?
� RCICs who own a consulting practice and RCICs working as
an employee for an immigration agency are required to create
and maintain a Contingency Plan (s.4.1, s.4.4, PUA
Regulation)
33
Contingency Plan – Who
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Module 1: Client Records Requirements
I. Steps for Sole Owner
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Contingency Plan – How
Step 1: Research
Step 2: Document
Step 3: Plan
Step 4: Designate
Step 5: Prepare
Step 6: Review
Module 1: Client Records Requirements
� Requirements of financial institution for allowing Authorized Representative to access client account (s.4.4.d, PUA
Regulation)
� Process for establishing legal documents, for example: � Power of Attorney (POA) for Personal Assets and POA for
Consulting Practice
� Continuing POA for Personal Assets and Continuing POA for
Consulting Practice (Mandate in Québec)� Last Will and Testament (Will)
� Needs and options for additional insurance coverage
35
Contingency Plan – How (cont’d)
Step 1: Research
Module 1: Client Records Requirements
� Office Procedure Manual
� How client files are created/stored/closed/destroyed
� What reminder systems are used
� Methods of communicating with clients
� Billing processes (s.4.4.b, PUA Regulation)
� See Toolkit for: � Office Procedure Manual Checklist
� Office Procedure Manual Template
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Contingency Plan – How (cont’d)
Step 2: Document
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Module 1: Client Records Requirements
Create Contingency Plan (s.4.4, PUA Regulation), including:
A. System to address emergencies arising on client files in event of planned/unplanned absence (s.4.4.a, PUA Regulation)
� Who will address emergencies?
� How will that person be notified?
� How will client consent be obtained?
� How will emergencies be prioritized?
� What information must be made accessible (e.g., active client list, deadlines, etc.)?
� How will that information be made accessible?
37
Contingency Plan – How (cont’d)
Step 3: Plan
Module 1: Client Records Requirements
Create Contingency Plan (s.4.4, PUA Regulation), including
(cont’d):
B. Accurate and up-to-date information on office procedures
(s.4.4.b, PUA Regulation)
� Review office procedures to maximize efficiency and accessibility
� Update Office Procedure Manual
38
Contingency Plan – How (cont’d)
Step 3: Plan (cont’d)
Module 1: Client Records Requirements
Create Contingency Plan (s.4.4, PUA Regulation), including (cont’d):
C. Accurate and up-to-date information on consulting practice (s.4.4.c, PUA Regulation), including location of and access to:
� Active and closed client files
� Current list of active clients
� Bookkeeping records (e.g., current client liability account and client list, etc.)
� Important contacts (e.g., accountant, landlord, software and technology used, etc.)
39
Contingency Plan – How (cont’d)
Step 3: Plan (cont’d)
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Module 1: Client Records Requirements
Create Contingency Plan (s.4.4, PUA Regulation), including
(cont’d):
D. Steps taken to facilitate the stepping in of Authorized
Representative/Responsible Person, including:
� Create checklist for maintaining the operation of the consulting practice
� Confirm financial institution’s requirements
� Ensure sufficient funds available to cover office expenses for period of time (s.4.4.d, PUA Regulation)
� Draft letters to notify clients and seek direction
40
Contingency Plan – How (cont’d)
Step 3: Plan (cont’d)
Module 1: Client Records Requirements
Create Contingency Plan (s.4.4, PUA Regulation), including (cont’d):
E. Process to notify ICCRC and seek leave of absence in event of incapacitation or medical condition (s.4.4.e, PUA Regulation), including:
� Notifying Registrar of contact information (name, primary and secondary address, telephone number, e-mail address) of Authorized Representative/Responsible Person
� Detailing who notifies ICCRC
� Detailing what triggers the notification process
41
Contingency Plan – How (cont’d)
Step 3: Plan (cont’d)
Module 1: Client Records Requirements
Create Contingency Plan (s.4.4, PUA Regulation), including
(cont’d):
F. Process to notify ICCRC in event of death or declaration of
missing person (s.4.4.f, PUA Regulation), including:
� Notify Registrar of contact information (name, primary and secondary
address, telephone number, e-mail address) of Authorized Representative/Responsible Person
� Detailing who notifies ICCRC
� Detailing what triggers the notification process
42
Contingency Plan – How (cont’d)
Step 3: Plan (cont’d)
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Where are we now 3/3
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Break
Assess your current Contingency Plan and identify gaps and goals
See Toolkit for: � Contingency Planning
Questions� Contingency Plan Template
Activity
44
Activity
Module 1: Client Records Requirements
� Select and approach Authorized Representative and/or Responsible Person(s) (s.4.5, PUA Regulation)
� Identify the needs of your consulting practice—consider key
responsibilities and tasks
� Determine who is qualified and able to address these needs in an
emergency
45
Contingency Plan – How (cont’d)
Step 4: Designate
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Module 1: Client Records Requirements
What is an Authorized Representative?
What is a Responsible Person?
46
Authorized Representative/Responsible Person
Means an individual who can offer immigration/citizenship advice and/or service for a fee or other consideration. An Authorized Representative
includes a Member in good standing with a Canadian provincial or territorial law society (including paralegals within their authorized scope of
practice), the Chambre des notaires du Québec or ICCRC. s.3.2.b, PUA Regulation
Means an individual over the age of majority who has immediate access to the jurisdiction where the Member’s office is located. The Responsible
Person is not an Authorized Representative and as such, must not perform tasks which may only be performed by an Authorized Representative.
s.3.2.u, PUA Regulation
When would you designate an Authorized Representative for your consulting practice?
When would you designate a Responsible Person for your consulting practice?
Activity
47
Discussion
Module 1: Client Records Requirements
� Select and approach Authorized Representative and/or Responsible Person(s) (s.4.5, PUA Regulation)
� Identify the needs of your consulting practice—consider key responsibilities and tasks
� Determine who is qualified and able to address these needs in an emergency
� Consider:
� Ability to communicate well with your clients/ICCRC/other parties
� Availability—business and family commitments
� Accessibility—location of candidate
48
Contingency Plan – How (cont’d)
Step 4: Designate (cont’d)
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Module 1: Client Records Requirements
� Review Contingency Plan and responsibilities with Authorized
Representative and/or Responsible Person(s) (s.4.8, PUA
Regulation)
� Sign Designation of an Authorized Representative or
Responsible Person Form (Designation Form)
� Complete separate Designation Form for each appointed Authorized Representative and Responsible Person (s.4.6-4.7,
PUA Regulation)
49
Contingency Plan – How (cont’d)
Step 4: Designate (cont’d)
Module 1: Client Records Requirements
� Submit Designation Form to Registrar by e-mailing [email protected]
� Existing RCICs: by May 1, 2018
� New RCICs: within 90 calendar days of being registered as an RCIC
� Confirm this information annually (July 1) via compliance audit
s.4.6-4.7, PUA Regulation
� Consider signing an additional agreement with Authorized Representative to detail expectations and compensation
50
Contingency Plan – How (cont’d)
Step 4: Designate (cont’d)
Module 1: Client Records Requirements
� Ensure surplus funds available to cover overhead expenses and compensation for a period of time
� Ensure Contingency Plan and Office Procedure Manual are
accessible to relevant parties
� Create POA, Continuing POA and Will
51
Contingency Plan – How (cont’d)
Step 5: Prepare
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What is the value of preparing a Power of Attorney for consulting practice?
What is the value of preparing a consulting practice Will?
Activity
52
Discussion
Module 1: Client Records Requirements
� Regularly review and update Contingency Plan
� Confirm commitment of Authorized Representative and/or
Responsible Person(s) at least annually (s.4.6-4.7, PUA
Regulation)
53
Contingency Plan – How (cont’d)
Step 6: Review
Module 1: Client Records Requirements
II. Steps for Multiple Owners
54
Contingency Plan – How (cont’d)
Step 1: Research
Step 2: Document
Step 3: Plan
Step 4: Designate
Step 5: Prepare
Step 6: Review
• RCIC partners designated as Authorized Representatives, consider
need for Responsible Person(s)
• Obtain input from all RCIC partners
• Ensure all RCIC partners have access to client account
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Module 2: Record Keeping SYstems
� Closing Down your Consulting Practice Checklist
� Voluntary Closure of Consulting Practice Checklist
� Sale of Consulting Practice Checklist
� Succession Planning Questions
� Suspension Checklist
� Client Account Office Procedures Sample
� Client Files Office Procedures Sample
� Sample Letter to Client Informing of Unplanned Absence
55
Toolkit
Module 2: Record Keeping SYstems
� Sample Letter to Client Announcing Planned Succession of Consulting Practice
� Sample Letter to Client in the Event of Death of RCIC
� Topics to Discuss with Authorized Representative Checklist
� Facilitation of Transition to Authorized Representative Checklist
� Authorized Representative’s Checklist
� Will and Power of Attorney Checklist
� Sample Continuing Power of Attorney for Consulting Practice Property
� Sample Last Will and Testament for Consulting Practice
56
Toolkit (cont’d)
Where are we now 3/3
57
Questions
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20
MODULE 2: BUSINESS CONTINUITY PLANNING
58
Module 2: Record Keeping SYstems
At the end of this module, participants will be able to:
• Assess the level of risk in specific situations and prepare a
Business Continuity Plan to address these risks
59
Module 2 Objective
There is a forced evacuation and you are unable to return to your home and/or office for four weeks
How do you rate your current level of
preparedness to manage your
consulting practice?
□ Exceptionally well prepared
□ Mostly prepared
□ Somewhat prepared
□ Not at all prepared
Activity
60
Activity/Discussion
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21
Actively listen to Sue Donovan’s experience with a dramatic eventActivity
61
Dramatic Event Story
What lessons can be learned from the RCIC’s experience with a dramatic event?
Activity
62
Activity/Discussion
Module 2: Record Keeping SYstems
What is it?
A Business Continuity Plan (BCP) helps RCICs:
� Respond quickly
� Formalize tasks so they are not forgotten
� Ensure clients are not prejudiced
� Recover quickly
63
Business Continuity Plan — What
A written set of procedures that would enable a Member to respond to routine or dramatic events (e.g., natural disasters, extreme weather
conditions, prolonged power or communication failure, robbery or
criminal activity, civil unrest, terrorist acts, etc.) that would threaten to hinder or stop normal office processes (s.3.2.c, PUA Regulation)
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22
Module 2: Record Keeping SYstems
Why is it needed?
� Protect:
� Clients
� Staff/Employees
� RCIC’s Family
� RCIC
� A Member shall develop a Business Continuity Plan to deal
with events that would stop normal office processes as a result
of either routine or dramatic events… (s.4.10, PUA Regulation)
64
Business Continuity Plan — Why
Module 2: Record Keeping SYstems
Routine events may include:
65
Business Continuity Plan — Why (cont’d)
Disruption of phone/internet service Work action/stoppage
Illness of staff/employee Vacation of staff/employee
Loss of data Loss of clients
Loss of staff/employees Loss of suppliers/delivery services
Human error Other
Module 2: Record Keeping SYstems
Dramatic events may include:
66
Business Continuity Plan — Why (cont’d)
Gas leak Prolonged power failure Civil unrest
Sabotage Epidemic Structural failure
Natural disaster (fire, earthquake, flood)
Terrorist act (bomb threat, biological/nuclear/chemical)
Explosion
Criminal activity (theft, vandalism, espionage,
bribery)
Fire (internal/external) and/or smoke damage
Utilities (water main break, sewage, electrical,
communications)
Extreme weather (windstorm, tornado,
snow storm, ice storm, drought)
IT Infrastructure (system/application software,
hardware, virus, hacking, network connectivity, third
party failure)
Other
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Module 2: Record Keeping SYstems
Developing a BCP:
67
Business Continuity Plan — How
1. Prevent
2. Prepare
3. Respond
4. Recover
Module 2: Record Keeping SYstems
� Identify and prioritize your essential services, including
supporting resources
� Identify and mitigate risks to those essential services
68
Business Continuity Plan — How (cont’d)
Module 2: Record Keeping SYstems
� Prioritize risks to essential services, consider impact on:
1. People - health and safety; required skills
2. Premises - physical assets and client files
3. Processes - activities which generate the essential service
4. Providers – government agencies; ICCRC
69
Business Continuity Plan — How (cont’d)
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24
Module 2: Record Keeping SYstems
� Document immediate actions to be taken in response to likely
incidents, including:
� Activate evacuation procedures
� Activate BCP (what are the triggers?)
� Manage staff/employee’s concerns
� Set up recovery office (temporary offsite location)
70
Business Continuity Plan — How (cont’d)
Module 2: Record Keeping SYstems
� Document actions to be taken to quickly recover from
incidents with minimal disruption
� What does “business as usual” look like?
� How long can you go without an essential service before quality
of service is compromised?
71
Business Continuity Plan — How (cont’d)
Module 2: Record Keeping SYstems
Additional considerations:
� Share BCP with everyone affected
� Provide training, as needed
� Conduct disaster drills to test BCP
� Assess results of training and drills
� Revise BCP, as needed
� Review and update BCP regularly
Works consulted:Alberta Emergency Management Agency. (2002). Risk Assessment. Business Continuity Templates. Retrieved from
http://www.aema.alberta.ca/business-continuity-templatesGovernment of Alberta. (2014). Business Continuity Guide. Retrieved from
http://www.aema.alberta.ca/documents/Business_Continuity_Guide_2014_-_Final.pdfIFAC. (2012). Guide to Practice Management for Small- and Medium-Sized Practices, Third Edition. Retrieved from
https://www.ifac.org/publications-resources/guide-practice-management-small-and-medium-sized-practicesLaw Society of Alberta. (n.d.). Safeguarding Your Practice. Retrieved from http://www.lawsociety.ab.ca/docs/default-source/practice-
advisors/safeguarding-your-practice.pdf
72
Business Continuity Plan — How (cont’d)
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25
Module 2: Record Keeping SYstems
� Business Continuity Planning (BCP) Questions
� Business Continuity Plan (BCP) Checklist
� Essential Services Worksheet
� Critical Activities Template
� Risk Mitigation Strategies Resource
� Risk Assessment Table
� Risk Assessment Worksheet
� Consulting Practice Impact Analysis Worksheet
� Loss of Technology Template
� Recovery Process Template
73
Toolkit/Workbook
Module 2: Record Keeping SYstems
� Incident Response Checklist
� Incident Recovery Checklist
� Business Recovery: Priority for Resumption of Consulting Practice
� Recovery Plan Template
� Review of Recovery Plan Template
� Business Continuity Table of Contents Sample
� Business Continuity Plan Sample
� Business Continuity Plans for Information and Communication Technology Sample
� Important Information List
� Contact and Communications Checklist
74
Toolkit/Workbook (cont’d)
Module 2: Record Keeping SYstems
� External Services Contact Details Template
� Staff Emergency Contact Details Template
� Roles and Responsibilities List Template
� Relocation or Evacuation Supplies Checklist
� Emergency Kit Contents
� Alternate Locations
� Resource List (Appendix A—Workbook)
75
Toolkit/Workbook (cont’d)
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26
Activity
76
Group Activity
Conduct a risk assessment and address the identified risks through the BCP
What does the PUA Regulation require?
77
Final Summary
Create and maintain
contingency plan
Review contingency
plan with each designate
Sign Designation
Form with each
designate
E-mail signed Designation
Form(s) to records-documents @iccrc-crcic.ca
What does the PUA Regulation require? (cont’d)
78
Final Summary (cont’d)
Create and maintain
business continuity plan
Review business continuity plan
with each affected
individual
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27
Where are we now 3/3
79
Let our advance worrying become advance thinking and planning.
Winston Churchill
Questions
80
Member Feedback Survey
� Feedback for ICCRC on course and instructor
� Online survey – link e-mailed to you today
� Anonymous – be honest and constructive
81
Wrap-up
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28
Webinar Invitation
� Optional
� Online session – audio and data
� Headset with built-in microphone required
� E-mail questions on planned or unplanned absence in advance
82
Wrap-up (cont’d)
Member Support
� E-mail your instructor with PME course-related questions
� [email protected] for all other queries
83
Wrap-up (cont’d)
Module 3: Shared practice
Thank you!
84
©2018 Immigration Consultants of Canada Regulatory Council. No part of this publication may be used or reproduced in
any manner whatsoever without the prior written permission of the Council, except in the case of non-commercial use
of brief quotations accompanied by proper citation.