Continuity strategy and plans

To meet the continuity strategy and plans requirement in ISO 22301, you must define how prioritized services will continue (or recover) through disruptions, document those strategies in actionable plans, and keep them current with testing and change control. Auditors will look for clear service priorities, recovery objectives, owned runbooks, and evidence the plans work. 1

Key takeaways:

  • Document a continuity strategy per critical service, then convert it into executable recovery plans and runbooks. 1
  • Tie plans to service priorities and recovery objectives, and keep them current through tests, incidents, and change management. 1
  • Evidence matters: approvals, versions, test results, lessons learned, and third-party dependencies must be retained and traceable. 1

“Continuity strategy and plans” is where business continuity stops being a policy statement and becomes an operational capability. ISO 22301 expects you to define and maintain continuity and recovery strategies for critical services, then document those strategies in plans that teams can execute under pressure. 1

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing this requirement is to treat it as a closed loop: identify prioritized services, choose feasible continuity and recovery strategies, translate them into role-based procedures, and continuously validate them through exercising and change control. The most common audit failure is not that an organization lacks a plan, but that the plan is not clearly mapped to the services that matter most, depends on unstated assumptions (people, systems, third parties), and has no recent proof of execution.

This page gives you requirement-level implementation guidance you can hand to service owners, IT/engineering, facilities, security, and third-party management. It focuses on what to build, how to govern it, and what evidence to retain so you can demonstrate that continuity strategies and plans exist, are maintained, and are credible in real disruptions. 1

Regulatory text

Provided excerpt (framework overview summary): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” 1

Requirement summary (operator view): Define and maintain continuity and recovery strategies for critical services. 1

What the operator must do:

  • Identify which services are “critical” (or prioritized) for continuity planning, and document the basis for that prioritization. 1
  • Define continuity and recovery strategies that are feasible for those services, given people, process, technology, facilities, and third-party constraints. 1
  • Publish plans that turn strategies into step-by-step actions, with named roles, triggers, dependencies, communications, and recovery steps. 1
  • Maintain those strategies and plans through governance, change control, and validation activities (exercises, tests, incident learnings). 1

Plain-English interpretation (what auditors mean)

Auditors and certifiers generally read this requirement as: “Show me that you know what must stay up, how you will keep it running or restore it, and proof you can execute the plan.” Under ISO 22301, “plans” are not a single PDF. They are a set of controlled documents and records that cover:

  • Service continuity intent (what you’re trying to preserve),
  • Recovery approach (how you’ll do it),
  • Execution instructions (who does what, in what order, using which tools),
  • Validation results (what happened when you tested it and how you improved it). 1

Who it applies to

In-scope entities

  • Critical service operators and service organizations that rely on continued delivery of products or services through disruptions. 1

In-scope operational context

You should treat the requirement as in scope wherever disruption would prevent delivery of prioritized services, including:

  • Technology outages (cloud region failure, identity outage, ransomware containment actions).
  • People unavailability (pandemic impacts, labor actions, key-person dependency).
  • Facility loss (fire, flood, access denial).
  • Third-party failures (payment processor outage, key SaaS downtime, telecom disruption). 1

What you actually need to do (step-by-step)

Use this sequence to operationalize quickly without over-engineering.

Step 1: Define “prioritized services” and owners

  1. Create a list of services you deliver (external customer services plus internal enabling services).
  2. Assign a service owner for each.
  3. Classify which are prioritized for continuity planning and record the rationale (customer impact, safety, regulatory commitments, contractual SLAs, financial/operational dependence). 1

Practical tip: If teams argue over definitions, pick a working definition and document it. Auditors penalize ambiguity more than imperfect labels.

Step 2: Set recovery objectives and minimum service levels

For each prioritized service, document:

  • Recovery time objective (RTO) as a target timeframe for restoration (your internal target is acceptable if you can justify it).
  • Recovery point objective (RPO) for data loss tolerance (if applicable).
  • Minimum viable operations: what “degraded but acceptable” service looks like (manual workarounds, read-only mode, limited geography). 1

Hangup to avoid: Teams often define objectives but don’t connect them to dependencies (identity, DNS, key APIs). Document the dependency chain in the same record.

Step 3: Choose a continuity/recovery strategy per service

Select a strategy that matches the objectives and constraints. Common strategy categories:

  • Redundancy/failover (active-active, active-passive, warm standby).
  • Restore from backup (with validated backup integrity and restore steps).
  • Manual workaround (paper process, alternate tooling, limited scope service).
  • Reciprocal/alternate site (for facilities or operational teams).
  • Supplier-provided continuity (third-party’s DR capability as part of your strategy). 1

Document the “why” behind the strategy choice: feasibility, costs, staffing, third-party commitments, and residual risk accepted by leadership.

Step 4: Write executable plans (not narratives)

Convert each strategy into plans that work at 03:00 during an incident. Minimum structure:

  • Activation criteria: what triggers plan execution and who can declare.
  • Roles and responsibilities: incident commander, service owner, IT ops lead, communications lead, third-party liaison.
  • Dependency checklist: systems, credentials, access methods, vendor contacts, contracts, and runbooks.
  • Step-by-step procedures: ordered actions with decision points and rollback steps.
  • Communications plan: internal escalation, customer messaging, regulator/client notifications where applicable.
  • Reconstitution: how you return to normal operations and retire workarounds. 1

Practical tip: Put the plan where it will be reachable during an outage (for example, an offline export or a controlled emergency-access repository). Test access, not just content.

Step 5: Integrate third-party dependencies

For each prioritized service, identify third parties that must function during disruption:

  • Cloud providers, critical SaaS, payments, telecom, managed security, logistics.
  • Contractual support channels and escalation paths.
  • Any shared-responsibility assumptions (what they restore vs what you restore). 1

Then align your plan to third-party capabilities: if your recovery strategy assumes the third party restores within your RTO, you need evidence from due diligence and ongoing monitoring that this assumption is reasonable.

Step 6: Validate plans through exercises and tests

Run at least one validation activity per plan type as appropriate:

  • Tabletop exercise for decision-making and communications.
  • Technical recovery test for restore/failover.
  • Call-tree/notification test.
  • Third-party recovery coordination drill for critical suppliers. 1

Capture results in a controlled record: what was tested, what failed, what changed, and who approved the remediation.

Step 7: Maintain plans with change control

Define maintenance triggers:

  • Major system changes (architecture, identity, networking).
  • Supplier changes (new cloud region, new payment provider).
  • Incident learnings (real outages, near misses).
  • Org changes (new on-call rotation, reorg, facility move). 1

Attach plan updates to your normal change management workflow so plan currency becomes routine, not a yearly scramble.

Required evidence and artifacts to retain

Keep artifacts in a controlled repository with version history and approvals.

Core documents

  • Continuity strategy document mapped to prioritized services. 1
  • Service-level continuity and recovery plans/runbooks. 1
  • Service dependency maps (systems, data stores, identity, network, third parties). 1
  • Roles/responsibilities matrix and escalation paths. 1

Operational records (proof of maintenance)

  • Exercise/test plans, scripts, and scenarios.
  • Test results, logs, screenshots, ticket references, and after-action reports.
  • Corrective action tracking (issues, owners, due dates, closure evidence).
  • Management approvals for strategy choices and residual risk acceptance. 1

Third-party evidence

  • Due diligence records relevant to continuity (BCP/DR attestations, SOC reports if available, outage communications process).
  • Contract excerpts for availability/support commitments and escalation. 1

Common exam/audit questions and hangups

Expect auditors to ask:

  • “Show me your prioritized services list and the criteria you used.” 1
  • “For this service, where are the RTO/RPO and how were they determined?” 1
  • “Walk me through the recovery steps. Who declares? Who executes?” 1
  • “When was this plan last tested, and what changed because of the test?” 1
  • “Which third parties are required for recovery, and how do you know they can meet your timelines?” 1

Hangups that slow audits:

  • Plans exist but aren’t tied to service priorities or objectives.
  • Runbooks assume access to tools that may be unavailable during outages.
  • Tests occurred but results are not documented or do not drive corrective actions.

Frequent implementation mistakes (and how to avoid them)

Mistake Why it fails in practice How to avoid it
One generic “BCP plan” for everything Doesn’t translate to executable steps for specific services Build a plan per prioritized service with a shared template and service-specific runbooks. 1
Recovery objectives set without dependency analysis You cannot meet the target if a hidden dependency has a slower recovery Maintain dependency maps and review them during architecture and supplier changes. 1
Plans stored in systems that fail during incidents Teams can’t access procedures when they need them Maintain emergency-access copies and test access pathways. 1
Third-party continuity treated as “their problem” Your service still fails if their recovery fails Make third-party continuity part of your service strategy, contracts, and testing. 1
Tests are “check-the-box” No improvement loop means the plan degrades Require after-action reports and track corrective actions to closure. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. The operational risk still shows up in audits and customer due diligence as a credibility test: if you cannot demonstrate a maintained continuity strategy and plans for prioritized services, you risk certification issues, contractual friction, customer escalations, and prolonged outages when real disruptions hit. 1

Practical 30/60/90-day execution plan

Days 0–30: Establish scope, owners, and baseline artifacts

  • Assign executive sponsor and continuity program owner.
  • Inventory services and name service owners.
  • Publish prioritized services list and document prioritization criteria.
  • Draft continuity strategy options for each prioritized service and identify major gaps (missing backups, single points of failure, unowned dependencies). 1

Deliverables: prioritized services register, ownership map, draft strategy matrix, repository structure with version control. 1

Days 31–60: Build plans that can be executed

  • Set recovery objectives per prioritized service and document assumptions.
  • Write service-level plans using a standard template, with role-based procedures.
  • Add third-party dependency sections (contacts, escalations, contractual hooks).
  • Conduct at least one tabletop exercise for the most critical service and document findings. 1

Deliverables: approved plans for top services, initial exercise record, corrective action log. 1

Days 61–90: Validate technically, close gaps, and operationalize maintenance

  • Run technical recovery tests where feasible (restore tests, failover tests, access tests).
  • Close top corrective actions or document risk acceptance with management approval.
  • Integrate plan maintenance into change management (required review on major releases and supplier changes).
  • Prepare the audit pack: index of plans, latest approvals, latest tests, evidence map from service to plan to test. 1

Deliverables: test results and after-action reports, closed remediation tickets, maintenance SOP, audit-ready evidence binder. 1

Where Daydream fits (practical, non-disruptive)

Most teams lose time chasing evidence across ticketing tools, wikis, and shared drives. Daydream can act as the system of record for mapping prioritized services to continuity strategies, plans, test evidence, and third-party dependencies, so you can answer audits with a single traceable evidence set rather than assembling it under deadline pressure.

Frequently Asked Questions

Do I need a continuity plan for every system?

Focus first on prioritized (critical) services, then document dependencies that must recover to restore those services. Add additional systems as scope expands, but keep the service as the unit of accountability. 1

What’s the difference between a continuity strategy and a continuity plan?

The strategy states the chosen approach (for example, failover, restore, or workaround) and the assumptions behind it. The plan is the step-by-step procedure with roles, triggers, communications, and technical runbooks. 1

How do we handle third-party outages in our plans?

Treat third parties as dependencies with explicit contacts, escalation steps, and known limitations. If your recovery targets depend on a supplier’s recovery, document the assumption and retain due diligence evidence that supports it. 1

What evidence is strongest for auditors?

Recent tests/exercises with recorded results, after-action notes, and tracked corrective actions usually carry more weight than a polished document alone. Pair that with clear ownership and version-controlled approvals. 1

Can a tabletop exercise count as validation?

Yes for decision-making, communications, and process readiness, but it won’t validate technical recovery steps like restores or failovers. Match the validation method to the risk in the service and the chosen strategy. 1

How often should we review and update continuity plans?

Review whenever a significant service, dependency, or supplier changes, and after disruptions or exercises that reveal gaps. Also schedule a periodic review cadence so plans don’t drift out of date. 1

Related compliance topics

Footnotes

  1. ISO 22301 overview

Frequently Asked Questions

Do I need a continuity plan for every system?

Focus first on prioritized (critical) services, then document dependencies that must recover to restore those services. Add additional systems as scope expands, but keep the service as the unit of accountability. (Source: ISO 22301 overview)

What’s the difference between a continuity strategy and a continuity plan?

The strategy states the chosen approach (for example, failover, restore, or workaround) and the assumptions behind it. The plan is the step-by-step procedure with roles, triggers, communications, and technical runbooks. (Source: ISO 22301 overview)

How do we handle third-party outages in our plans?

Treat third parties as dependencies with explicit contacts, escalation steps, and known limitations. If your recovery targets depend on a supplier’s recovery, document the assumption and retain due diligence evidence that supports it. (Source: ISO 22301 overview)

What evidence is strongest for auditors?

Recent tests/exercises with recorded results, after-action notes, and tracked corrective actions usually carry more weight than a polished document alone. Pair that with clear ownership and version-controlled approvals. (Source: ISO 22301 overview)

Can a tabletop exercise count as validation?

Yes for decision-making, communications, and process readiness, but it won’t validate technical recovery steps like restores or failovers. Match the validation method to the risk in the service and the chosen strategy. (Source: ISO 22301 overview)

How often should we review and update continuity plans?

Review whenever a significant service, dependency, or supplier changes, and after disruptions or exercises that reveal gaps. Also schedule a periodic review cadence so plans don’t drift out of date. (Source: ISO 22301 overview)

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