Catastrophic Events Policy

SCOPE:

This Catastrophic Events Policy applies to all ICOM locations. This plan describes actions that will be taken to activate continuity operations within 12 hours of significant disruption and sustain continuity operations for up to 30 days. The Catastrophic Events Policy also covers program, location, and campus permanent closure requirements. This policy does not apply to short-term disruptions of service, including minor technology systems or power outages, or any other scenarios where essential services can be readily restored.

The ICOM Office of the President maintains this plan. For further information, contact Darren Blagburn (dblagburn@icom.edu)

1. President's Office - Determines policy and makes policy decisions as needed. Provide communications to and from the Board of Trustees. Provide strategic guidance for campus recovery.

2. Director of Campus Security - All emergency operations shall be coordinated by the Director of Campus Security or his/her designee until relieved by the Meridian Police and/or Fire-Officer- in-Charge (FOIC) or his/her designee. The coordination of the CERT is the responsibility of the Director of Campus Security.

Specific details related to emergency operations may be found in the Emergency Action Plan (not available for public view due to sensitive information).

Communication

The ICOM Crisis Communication Plan is intended to serve as a guide to the College so that it may quickly and thoughtfully respond to a crisis in an effort to mitigate any potential negative effects. The College's crisis response strives to:

• demonstrate transparency

• build trust before, during, and after a crisis

• communicate in a way that upholds our mission

• provide timely and accurate crisis communication to appropriate stakeholders.

At the direction of the President (or designee), ICOM’s Vice President for Marketing and Communications alerts the Crisis Communication Team appropriate for the nature of the crisis.

Specific details related to crisis communication may be found in the Crisis Communication Plan (not available for public view due to sensitive information).

Guiding Principles

Continuity of operations focuses on restoring essential services and/or supporting students who may be impacted by changes to ICOM’s operations. This plan incorporates the following supportive principles:

• Apply orders of succession and delegations of authority;

• Establish communication with supporting and supported organizations and stakeholders;

• Perform essential services (infrastructure, academic, research) in order of prioritization;

• Manage human capital;

• Acquire space and equipment as necessary for essential services;

• Establish means for accessing vital records, files, and databases;

• Prepare for the reconstitution of essential services.

A. Orders of Succession / Delegation of Authority

In order to maintain operations and appropriate decision-making, divisions should define orders of succession for key positions when respective leadership is unable to execute their duties during or after an emergency.

Delegations of authority specify who is authorized to perform specific tasks or act on behalf of leadership personnel regarding a particular function. Succession pertains to overarching guidance; delegations are task- specific. Planning for delegations of authority involves the following:

• Identifying which authorities can and should be delegated to whom;

• Describing the circumstances under which the delegation would be exercised, including when it would become effective and terminated;

• Identifying limitations of the delegation;

• Training designees to perform their essential services.

The College provides prioritization for the continuity and recovery of essential services. In the event of an emergency and subsequent recovery, essential services will be evaluated and prioritized based on the situation and re-evaluated as necessary during the recovery or as the incident progresses. This serves as an operational guide to facilitate the allocation of resources in the event of a significant disruption so that the most critical operations are recovered with priority.

Initial continuity priorities are identified as Emergency Support Functions (ESF) and have immediate recovery time objectives. These Emergency Support Functions are required for life safety, critical infrastructure, and core College operations and carry a common goal of the timely restoration of the academic learning environment.

See Table 2 for a list of Emergency Support Functions.

Table 2.

D. Human Resource Guidance

Essential Services are defined as those services that are critical to the functioning of the College and the well- being of students, faculty, staff, and facilities. Essential Services support the mission-essential functions of the College and each department and unit (e.g., research and teaching). Essential Services can be a regular and ongoing need (utility services, safety and security, IT, medical needs, or equipment) or can be situation-specific (peak periods of the year, academic semester, day of the week). It is ICOM's goal to maintain these Essential Services even when the normal operating status of the College is modified or suspended.

Employees who work in areas that have been identified as essential service functions by supervisors, Campus Security, or College Administration or who possess specialized training relevant to the immediate need will be required to report to work

These employees will be required to report to work as required. It is the responsibility of the employee’s supervisor to contact the employees regarding the status of College operations. Employees from throughout the College may be reassigned to provide support in these areas to the extent they are qualified and available.

Flexible Work Options (remote work)

Departments should identify which employees can conduct work from home or other remote locations. Departments should, in collaboration with IT, take into consideration whether laptops or employees' own computers will be used, whether there are available internet connections, and what mechanisms are available to protect proprietary information and compliance with sensitive/confidential data policies. Individuals not normally eligible for remote work due to position responsibilities may be eligible in emergency situations when agreed upon with the supervisor.

Leave and Return to Work Authorization

Standard operating procedure during leaves, such as Family Medical Leave and Short-Term Disability, normally requires documentation to substantiate such leaves and return to work. However, the College recognizes the need to be flexible with deadlines for the forms in a disruptive event. Supervisors must make the best effort to keep leave and pay records for their staff and to reconstruct them where necessary in order to make adjustments to pay and employment status when the College returns to full operations.

Leave Accruals

Employees who were not scheduled to work during a change in operating status due to time off (e.g., vacation, health, and personal leave) that was pre-approved and unrelated to the anticipated or actual public health emergency will be charged leave time regardless of the operating status of the College.

Sick Employees

It will be important that ill employees stay home.

E. Continuity Locations

Each department recognizes that normal operations locations may be disrupted, and there may be a need to perform essential services at a continuity location. The potential costs for securing a continuity location when needed can be significant. Due to the criticality of the continuity location and the possible costs associated with that site, it is important that the affected units partner with CERT to evaluate the viability of continuity location facilities.

• Utilize alternate workspace locations pre-established in the unit continuity plan

• Utilize alternate workspace controlled by the unit

• Utilize alternate workspace controlled by the affected location

• Utilize alternate workspace controlled by the College (partner with Facilities).

• Pool resources among Schools/locations/divisions to acquire space for a continuity location;

• Co-locate and combine resources with another department/location to increase efficiency;

• Essential services are prioritized at the continuity location;

• Provide virtual office options (telecommuting).

F. Critical Resources

Critical resources are the staff, equipment, and systems required to support essential services. During the planning process, key personnel evaluate each of the essential services and list the critical resources required to re-establish each function, including unique space and specialized equipment.

G. Vital Files, Records, and Databases

Vital records are necessary to carry out essential services, and if damaged or destroyed, would disrupt operations and information flow and require replacement or re-creation at considerable expense or inconvenience. The ICOM Department of Information Technology (IT) maintains the operational continuity of IT systems.

H. Records Protection Agreement

In the event that ICOM experiences a catastrophic event that closes the college, for the most part, the College’s Student Records are cloud-based and do not require additional support agreements. Those that do will be stored and backed up in compliance with federal and state requirements.

I. Financial Operations

A disruptive incident may result in significant financial challenges for the College. The financial risks and exposures will vary significantly depending on the timing and extent to which the College progresses through the disruptive event; losses may drive significant increases in other costs and may be ongoing.

Although estimates can be developed to evaluate the potential financial impact, actual available resources cannot be estimated in advance of the disruptive event. Financial resources will be managed prudently to support ICOM's disruptive event planning principles while ensuring the long-term financial health of the College.

Individual operating units and/or locations may face out-of-the-ordinary expenses in preparation for a disruptive event. For extraordinary expenses which cannot reasonably be funded through unit budgets or which should be considered for College funding to ensure important health and safety standards are met, funding may be requested as part of the annual budget process or through the Vice President for Finance & Administration and Chief Financial Officer (CFO).

In the event that ICOM cannot continue operations, the CFO will ensure that each student receives the services for which they paid or reasonable financial compensation for those not received. A model for financial compensation for students will be created on a case-by-case scenario taking into account the timing, duration, and specifics of the disruption. Reasonable compensation will be provided from business insurance proceeds, College quasi-endowment, or College operations.

J. Reconstitution and Recovery

Reconstitution includes the process of returning essential services from the response and continuity environment back to the normal working environment. The reconstitution process begins as soon as the Catastrophic Events Policy is executed and all essential services have been restored.

Implementation actions associated with reconstitution include:

• Instructing personnel on how to demobilize resources and resume normal operations;

• Supervising an orderly return to the normal operating facility, a move to another temporary facility, or a move to a new permanent operating facility;

• Verifying that all systems, communications, and other required capabilities are available to allow operations of essential services at the new or restored facility;

• Conducting an after-action review of the effectiveness of this plan, identifying areas of improvement, documenting identified areas of improvement in a corrective action plan, and developing a remedial action plan as soon as possible after reconstitution.

Through these actions, we strive to improve the efficiency and effectiveness of recovery operations across the entire College to make for a more resilient community.

Recovery is an ongoing process. The type and breadth of recovery activities will vary based on the nature and scope of the emergency. However, the goal of the recovery phase is to restore the academic learning environment, including physical and structural recovery, business recovery, and psychological and emotional recovery.