Company Profile

• Industry: Accounting & Financial Services

• Size: 50 employees, serving SMEs across the UK

• Critical Dependencies: Cloud-based financial software, client data security, regulatory compliance

• Risk Exposure: Cyber threats, third-party IT providers, data loss, regulatory penalties

 

1️⃣ Third-Party Risk Assessment (TPRA)

🔍 Scenario: The firm relies on a cloud-based accounting platform (e.g., Xero, QuickBooks) and an outsourced IT provider for cybersecurity.

• Risk Assessment Findings:

  • The IT provider has no formal cybersecurity certifications (e.g., ISO 27001).

  • The cloud-based accounting platform stores sensitive financial data but lacks contractual guarantees on uptime.

  • Client data handling processes are unclear with third-party software integrations.

• Actions Taken:

  • Require the IT provider to implement multi-factor authentication (MFA) for all staff logins.

  • Review and update the Data Processing Agreement (DPA) with the cloud provider to ensure GDPR compliance.

  • Develop contingency plans for alternative accounting software in case of a system outage.

• How It Feeds Forward: Identified risks inform the BIA by highlighting supplier dependencies and security gaps.

 

2️⃣ Business Impact Analysis (BIA)

💡 Scenario: What happens if the accounting firm’s cloud software is unavailable for 48 hours?

• Critical Functions Identified:

  • Tax filing and compliance reporting for clients

  • Payroll processing for client businesses

  • Client consultations and financial advisory services

• Impact Assessment:

  • Cloud software downtime → Inability to file taxes → Client non-compliance fines

  • Payroll processing failure → SMEs unable to pay employees → Reputation damage

  • Data breach → Potential GDPR violation → ICO fines & client lawsuits

• Prioritization:

  • High Priority Recovery: Tax filing access, payroll processing

  • Medium Priority: Internal email, client meeting scheduling

• How It Feeds Forward: BIA findings shape the BCP, ensuring focus on client-critical services.

 

3️⃣ Business Continuity Plan (BCP) Development

🛠 Scenario: The firm drafts its BCP based on identified risks and impact levels.

• Key Actions Defined:

  • Alternative Workflows:

    • If the cloud accounting software is down, use locally stored backups to process payroll manually.

    • Implement a backup system (secondary provider) for tax filing.

  • Cyber Incident Response Plan:

    • Report data breaches to ICO within 72 hours per GDPR.

    • Notify affected clients immediately with risk mitigation advice.

  • Communication Protocols:

    • Pre-drafted emails and SMS alerts for clients in case of IT outages.

    • Dedicated crisis response team for urgent regulatory issues.

• How It Feeds Forward: The BCP provides the foundation for testing via a crisis simulation exercise.

 

4️⃣ Crisis Simulation Exercise

🚨 Scenario: A simulated ransomware attack locks access to cloud-based accounting software during a peak tax filing period.

• Exercise Steps:

  • IT team attempts data recovery using backup systems.

  • Accountants manually process payroll using alternative software.

  • Communications team sends client alerts, guiding them on alternative solutions.

  • Management notifies the Information Commissioner's Office (ICO) to stay compliant with GDPR.

• Findings & Adjustments:

  • Recovery took 4 hours longer than expected → Backup processes need streamlining.

  • Some staff lacked knowledge of manual workflows → Additional training scheduled.

  • Client communication was delayed → A real-time alert system is now being implemented.

 

Final Takeaways & Continuous Improvement

✅ Lessons Learned:

• The TPRA correctly flagged cybersecurity risks with IT vendors.

• The BIA helped prioritize critical functions like payroll & tax filing.

• The BCP provided clear recovery workflows for cloud software failures.

• The Crisis Simulation exposed operational weaknesses, leading to improved response times.

🚀 Result: The firm is now better prepared for cyber incidents, regulatory compliance breaches, and third-party failures.