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One way that employers may measure your time management skills at interview is via an in-tray exercise. You are most welcome to link to these pages but should not use content in other ways without our permission. The Ontario Mass Evacuation Plan is a supporting plan to the Provincial Emergency Response Plan (PERP).
For more information on the legislative framework and authorities, see the PERP available on the EMO website. This plan supports the agreement between the Governments of Ontario and Canada (through the Department of Aboriginal Affairs and Northern Development Canada) to provide emergency response support to First Nation communities in the province.
An EMO planning team in consultation with non-governmental organizations, provincial and federal partners developed the plan. This plan is meant to be used to respond to a request for a partial or complete evacuation from one or more communities to one or more host communities. Provincial coordination will involve the evacuating community, host communities, relevant Ontario ministries, federal departments, non-governmental organizations, and others, as required.
This plan is for Ontario’s far north, encompassing municipalities, unorganized territories2 and First Nation communities. This is an overarching plan for carrying out mass evacuations and as such, many aspects are general in nature4. The Far North of Ontario spans the width of the province, from Manitoba in the west, to James Bay and Quebec in the east. The far north is subject to several hazards covered under Ontario’s Hazard Identification and Risk Assessment. The geography of the far north may complicate evacuations or efforts to manage or suppress the hazard.
Maintain family and community unity, which is integral to maintaining community cohesion and supports. Potential threats to the communities and emergency responders are critical in determining the urgency of the evacuation and for planning resource mobilization. Real-time threat assessment should be ongoing and coordinated among partners, particularly ministries with relevant OIC responsibilities and the community(ies) at risk.
An OIC ministry or the PEOC may recommend evacuation, or that it is safe to return, based on a real-time threat assessment. The availability, duration, type, and location of host community facilities affect planning for the evacuation. Consideration should be given to maintaining the readiness of host communities for future hosting. Evacuating communities should identify Community Evacuation Liaisons for each host community.
The decision to deploy is typically based on requests from impacted communities, the mandate of the organization deploying staff, and staff member’s level of expertise. Depending on the scale and complexity of the operation, a senior provincial official may be deployed to coordinate the provincial response and to liaise with community and other deployed officials.
Situational awareness requires continuous coordination to help collect, collate, evaluate, and disseminate information. When planning for the return of evacuees, the number and location of host communities, and the distance to evacuated communities are key planning considerations. Roles and responsibilities may pertain to transportation hubs, host communities, support from ministries or the federal government, or responsibilities of evacuating communities. Determine the financial and legislative roles and responsibilities for the evacuation and comply with applicable policies, agreements, procedures, etc. Emergency information needs to be coordinated among the affected communities, province, and federal government.
Once it has been decided that a community needs complete or partial evacuation, the parties involved must establish who the evacuees are, where the host locations are, and what the means of evacuation will be.
Following the judgement of the authorized entity that it is safe for evacuees to return, the order of return and the methods of transportation must be established using an inclusive planning process that involves affected communities, provincial and federal partners, and other partners (i.e. Real-time threat assessment is a critical component of evacuation operations and should be ongoing.
All responders involved in managing the hazard or participating in the evacuation must regularly communicate situational awareness information to those conducting real-time threat assessments and must report a changing situation as soon as feasible.
OIC ministries are responsible for assessing the threat for the types of emergencies they have been assigned.
EMO is responsible for real-time threat assessments for hazards that have not been assigned to an OIC ministry.
The PEOC is responsible for assessing the threat based on the real-time threat assessment and characteristics of the community(ies) or region under threat. During routine monitoring, the PEOC duty officer performs the function of real-time threat assessment. OIC ministries routinely monitor conditions in the province according to their assigned type of emergency. Uncertainty in real-time threat assessment is unavoidable, which is why persons with appropriate knowledge of the threat causing the emergency should be involved in the assessment. During emergencies, the PEOC links with the local community and the OIC ministry acting as provincial lead to coordinate real-time threat assessment information. Emergency managers must understand the makeup of the population who are to be evacuated before they can make key decisions about transportation modes, route selections, hosting destinations, and the many other elements of an evacuation. Medevac is used for those individuals receiving home care or residing in a health-care facility in the evacuating community that qualify for medical transfer as per the Ambulance Act (evacuation by emergency medical services (EMS) or Ornge). This stage is typically orchestrated through the existing health procedures used in the community. This includes persons with disabilities, seniors, children, pregnant women, and those with medical conditions. Among these, some require attendant care, which means both the caregiver and the Stage 1 evacuee they care for should be on the Stage 1 evacuation list.
The designation of evacuees into the different stages will be determined by the First Nation Chief and Council, Head of Council, or appointed person, with the assistance of the on-site health care organization. Different types of hazards may dictate variations in the criteria for these categories (e.g.
The decision to evacuate a community is the responsibility of the First Nation Chief, Head of Council, or appointed person.
For First Nations communities, AANDC and PS approve federal assistance to support an evacuation. The urgency of an evacuation is determined based on the immediacy of the threat to the community (life, safety, health, and welfare), the resilience of the community, and (depending on the nature of the threat) the availability of resources for evacuation or shelter-in-place10. Evacuations may take place prior to (pre-emptive), during, or after an incident has occurred. Given adequate warning about a hazard, adequate resources, and the likelihood of the threat actually impacting a community, it is advisable to conduct pre-emptive evacuations. If adequate resources are not available to conduct a pre-emptive evacuation, it may still be possible and necessary to carry out an evacuation even while a threat is already affecting a community.
If recommending enhanced monitoring or activation of the PEOC, consider what positions must be staffed to conduct the evacuation.
Alert PS of the situation and advise them if Government of Canada support may be required to assist.
Establish a regular information cycle and contact for evacuating communities, host communities, and other parties assisting with the evacuation.
Consider requesting additional host communities stand-by to receive evacuees if the situation appears likely to escalate rapidly. Establish the PEOC Command, and if it is an area or unified command, consider including additional organizations in the command meetings to better inform and coordinate the response. Determine financial accountabilities in consultation with partners and communicate the information. Determine at the outset of the operations which organization will be responsible for information management and the manner in which information will be shared. Initiating media contacts or directing the appropriate position to do this according to established plans and procedures (e.g. Adopting an extended operational cycle in which extra positions are staffed beyond the normal working day. Alerting other emergency responders in the province, including non-governmental organizations, that they may be requested to provide assistance.
Marshalling transportation resources, including the recall of deployed resources in preparation for redeployment. Collecting and analyzing the data necessary to fully understand the potential impact and threat. Weather, resource availability, and the scale of an incident can significantly affect the time required to mobilize resources.
Emergency information is primarily the community’s responsibility, but may be supplemented by the province according to the provisions of the Provincial Emergency Information Plan. Communications between the field and the PEOC, between the PEOC and partners, and within the PEOC is critical. The PEOC (or other EOC) may request deployments to fulfil specific incident management functions, as needed (e.g. Where the scale of the incident, evacuation timeline, or availability of staff prevents the physical deployment of staff, relevant incident management functions may be performed remotely using available technology.
Information technology in the far north is not universally accessible and may be further compromised by the nature of the emergency. All partners (but with specific reference to PEOC) should recognize the potential limitations to information technology in these regions of the province.
The priorities for evacuation will be determined by the Chief and Council (for a First Nation), the Head of Council (for a municipality), or an authorized entity. Transportation planning for the evacuation will be undertaken by a joint planning team as described in Annex 7. The evacuating community should identify community evacuation liaisons at each of the host community sites to support evacuees.
If an evacuation involves a First Nation community, the JEMS Service Level Evacuation Standards provides a sample flight manifest.
Service Level Evacuation Standards11 are in place for hosting First Nations community members in the event of an evacuation. Through the PEOC, EMO works with the evacuating First Nation to identify a host community or communities for its evacuees. The selection and preparation of host facilities should be driven by the needs of the evacuees. Another key consideration is the availability of personnel and other resources to support the host facilities. Potential conflicts with the longer-term use of accommodations in the host community should be considered and mitigated if possible (e.g. The PEOC should begin contingency planning with partners for longer-term evacuations if it appears likely that evacuees will be displaced from their community for longer than the period discussed below. When evacuees are members of a First Nation, the use of any facility that was used as, or could evoke comparisons to, residential schools should be avoided. Communities considering acting as a host community during an evacuation should identify emergency shelter facilities.
Short-Term Basic Shelter Services: for a period of 1-14 days, in arenas, gymnasiums, recreation halls, etc. Special Accommodations: to address the requirements of medically vulnerable individuals or those with special needs. Host communities may be limited in the types of accommodations that they are able to provide.
Planning for hosting evacuees builds on information already available (typically from the manifest). Host communities are responsible for registering evacuees that are entering into their care. Registration records should only be shared with organizations providing services to the evacuees (e.g. Before the return of evacuees, the evacuated community should be in a safe and ready state. Services have resumed and are sufficient to support returning evacuees – for example, power, water, sanitation, security, food and essential supplies, and medical services. If a community was completely evacuated it may be advisable to begin the return of evacuees with essential workers to restart systems and assess the readiness of the community to receive other returning evacuees. Once approval has been given for all or a part of the population to return home, community leaders, working with community evacuation liaisons, will develop priorities and manifests for the return flights.
Ground transportation arrangements may be made by the host community or the provincial government. The evacuated community will take the lead for communicating re-entry procedures, with assistance from partners as required. What media sources can evacuees use for the most up-to-date information on re-entry procedures? Following a regional evacuation, multiple communities may decide at the same time that they are ready to return evacuees. The PEOC and partners will commence demobilization as host communities are cleared of evacuees. The Quick Reference Guide is a condensed version of the Ontario Mass Evacuation Plan Part 1: Far North.
Any major disaster could temporarily overwhelm Police, Fire and Ambulance and First Responders.
There are many daily conveniences that we all take for granted; running water, electricity, gas, telephones, getting cash from an ATM machine, or even running to the grocery store to pick up milk and bread. All of us face the possibility of natural disasters, accidents, power outages or intentional acts to disrupt our daily lives. Preparedness is a continuous cycle of planning, organizing, training, equipping, exercising, evaluation and improvement activities to ensure effective coordination and the enhancement of capabilities to prevent, protect against, respond to, recover from, and mitigate the effects of natural disasters, acts of terrorism, and other man-made disasters. In the preparedness phase, emergency managers develop plans of action to manage and counter their risks and take action to build the necessary capabilities needed to implement such plans.
Proper maintenance and training of emergency services, including mass human resources such as Community Emergency Response Teams.
Learn how to prepare for your family and at your workplace, explore many links to resources and see what to do for your pets.
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The subject of hedge fund operational due diligence is one that has risen to the forefront for both hedge fund managers and investors in recent years. Historically, there has been a general lack of transparency within the hedge fund industry; larger funds, in particular, often balked at investor inquiries. Due diligence, as a process, did not gain significant importance until just a few short years ago. Hedge funds managers and investors are now taking due diligence seriously and making conscious steps to maintain open communication and increase information-sharing. Operational excellence has become one of the most important factors to hedge fund investors today as they determine where to allocate their money. What service providers are you engaged with and how do you determine their quality of service?
Investors need to understand why hedge funds have made each of their operational choices, including when it comes to technology.
Investors have become much more aware of technology and how important a role it plays in the day-to-day operations of a hedge fund. Hedge funds should be prepared to recover from both short- and long-term disasters and be prepared to outline their processes and procedures (in writing!) to investors. Hedge fund operational due diligence is an opportunity and a marketing exercise – one that funds should undertake with educated personnel and a willingness to be open and transparent.
Show investors that you have a 3+ year budget for working capital without any performance fees. Make sure to properly allocate expense and investment opportunities if you decide to launch a single investor fund or separately managed accounts. When it comes to seed arrangements, pick the right partner and put parameters around potential issues that could arise. Become familiar with the changing expectations on the cybersecurity front, from both investors and regulators. The Cybersecurity Interpretive Notice applies to all membership categories--futures commission merchants, swap dealers, major swap participants, introducing brokers, forex dealer members, commodity pool operators and commodity trading advisors. But whatever approach is taken, the Cybersecurity Interpretive Notice requires Members to adopt and enforce an information systems security program (ISSP) appropriate to its circumstances.
Description of ongoing education and training related to information systems security for employees.
NFA recognizes that some Members may face a significant challenge implementing ISSPs by the March 1, 2016 effective date, and any programs that are adopted will be refined over time. Eze Castle Integration’s Cybersecurity Practice Team is available to create Written Information System Security Programs for firms.
Operating capital may be limited in the first few years after your launch, so careful budgeting and long range planning will serve your firm well.
Governmental oversight of the financial industry has evolved dramatically in the last decade. Apart from registration, you should also determine if there are any legislative implications for your new firm.
Since 2014, cybersecurity preparedness is also a critical area of focus for regulatory bodies. Cloud services offer more flexibility than traditional infrastructure models and, beyond cost-savings, can reap rewards for new launches. Of course, one of the greatest benefits to using an outsourced cloud service is professional management and monitoring.
Beyond infrastructure safeguards, it is critical that firms implement policies and procedures to protect firm and client assets.
While the list of considerations is surely long for new hedge fund managers, we've whittled it down to 10 Keys to Launching a Hedge Fund Successfully - a guide for new startups to use when setting off on their new journey. We at Eze Castle Integration have identified the top four reasons why backups are critical to not only a firm’s growth, but also their survival.
The Securities and Exchange Commission (SEC) has instituted regulations on the storage of financial records and electronic communication, and financial industry regulatory agencies such as FINRA now provide standards and guidance information on potential threats.
The reasoning behind these recommendations is the volume of things that can go wrong with your data storage solution. Regulatory and compliance organizations recognize the necessity of data security and advocate for firms to have a comprehensive backup solution in place. As reported by Gartner in the 2015 Gartner MQ Report for Enterprise Backup Software and Integrated Appliances, by 2017, the number of enterprises using the cloud as a backup destination will double, growing from twelve percent (12%) today. Consider the impact to your business if you lost the data held in your CRM, financial, or reporting systems.
Backups should be an integrated part of not only the IT department, but of the overall business strategy.


Businesses invest large amounts of time, money and resources into their operations; however, most are lacking a plan to protect this hard work. Because the security of data is imperative, it’s critical that firms choose the right provider to maintain tight control and visibility over business critical information. Communicate – It is important to let your employees know as soon as possible that they will no longer be able to get to work.
Technology – Technology has facilitated the ability for an employee to work remotely during a storm, but there are still some considerations to think through. Hunker Down –During severe storms employee safety should be at the top of the priority list. Set Workload Expectations – As an employee, a storm can be disruptive to their normal work day.
Updates – As a consistent theme throughout BCP, communication is key, and continued updates will keep the employee centered on their work and allow them to respond to changes quickly such as the reopening of the office building. The key to a successful business continuity plan lies in understanding the impact a disaster situation could have on a business and creating policies to respond to any such impact. The final critical element of a BCP is ensuring that it is tested and maintained on a regular basis. Or contact Eze Castle Integration to speak with one of our certified business continuity planners about best practices or to learn about why leading hedge funds rely on Eze Business Continuity Planning Services. We spend a lot of time educating our clients about security best practices and encouraging them to implement comprehensive security policies and procedures to mitigate risk and protect both the firm and its employees.
While companywide policies should reflect long-range expectations and corporate best practices, they should also include tactical recommendations that employees can follow to ensure they are complying with the company’s overall risk strategy.
Provide information such as login IDs, passwords, social security numbers, account numbers, etc. It is no surprise that the investment industry landscape is becoming more and more competitive. A comprehensive DDQ covers a wide range of topics, from assets under management to audited financial statements and investment strategies.
So, to help you get started, we have compiled the following list of some frequently asked DDQ questions. Does the firm have established, documented service level agreements in place with its technology partners to ensure a stable computing environment?
Is the policy regularly reviewed to determine whether the controls are operating as intended? Do the appropriate management officials approve the policy and any changes that may be made? Does the firm’s IT staff (or technology partner) ensure appropriate access control to applications and sensitive company data? Is a solution in place to ensure mobile devices and laptops are secure in the event of loss or theft? Has the firm established a dedicated location to retain backup copies of all critical data? Has a secondary working location been established to which employees should report in the event of a disruption or outage? Is a comprehensive disaster recovery solution in place to provide system redundancy and ensure protection of critical data in the event of a disaster or system failure?
Has the firm determined its crucial recovery point objectives (RPOs) and recovery time objectives (RTOs)? Resolution 2: Conduct a Security Assessment or if you rely totally on a cloud solution, make sure your provider has conducted a recent vulnerability assessment and request a copy of the report.
Resolution 4: Ensure Your Business Continuity Plan (BCP) and Written Information Security Policies (WISPs) are current and accurately reflect your business operations and the evolving risk landscape. These factors may seem to support the belief that public clouds and free file sharing services would suffice for a business’s basic infrastructure and file sharing needs. While there are several popular services which enable file sharing among small groups of people, they are not easily scalable to support small businesses, and can quickly become clumsy and inefficient as the firm grows. While some free public cloud services are slightly more robust, these tools are not nearly as feature-rich as a dedicated private cloud system and are much more challenging to integrate with other systems or applications. Additionally, most free public cloud tools do not support integration with CRM, OMS or other third-party systems which firms will require as they grow.
For investment management firms, uptime is crucial to operational efficiency and profitability. Having a comprehensive disaster recovery solution in place helps protect your fund’s data as well as its reputation. Institutional investors will likely not be comfortable having their information shared via a public file sharing service.
The financial services industry continues to face compliance pressures and increased regulation. Comprehensive enterprise private cloud services can easily integrate with archiving tools to help ensure that all emails, IMs and attachments are indexed and easily retrievable. A component of Disaster Recovery that deals with the restoration of business system software and data, after the operating system environment has been restored or replaced. A pre-identified group of individuals that is reponsible for maintaining and executing the recovery process.
A system of planning for, recovering and maintaining both the IT and business environments within an organisation regardless of the type of interruption.
A collection of information on a wide range of areas from recovery assumptions and critical business processes to interdependencies and critical staff that is then analysed to assess impact a disaster may have.
The process of restoring and maintaining the data, equipment, applications and other technical resources on which a business depends.
A disaster recovery hot site is a remote physical location where you can maintain copies of all of your critical systems, such as trading applications, data, and documents. A computer system or application that is essential to the functioning of your business and its processes. In the context of a primary and secondary site, the primary site contains the original data that cannot be recreated.
The RTO is the duration of time and service level within which a business process must be restored after a disruption in order to avoid unacceptable losses. The RPO is the point in time to which a firm must recover data as defined by the organisation.
A system of using multiple sources, devices or connections so that no single point of failure will completely stop the flow of information.
The identification and prioritisation of potential business risk and disruptions based on severity and likelihood of occurrence. The secondary site contains information and applications that are built from the primary repository information. If regular testing is a critical component of an effective DR solution, why do many firms fail to do so? Here at Eze Castle, we strive to educate our clients on different testing methods so that they find an option that best meets their unique business requirements. As we continue to educate our hedge fund and investment firm clients on disaster recovery testing methods and the available options, we have seen a drastic increase in the number of clients that elect to implement regular testing procedures. A: Users should verify that they have the functionality needed to work successfully from the DR site during a disaster. A: If a firm fails to test its DR systems, they run the risk of the DR site not meeting current business requirements during a disaster. Q: Will testing our disaster recovery site disrupt our production site (and therefore normal business operations)? Whether it’s emails, admin or politics, there will always be something that seems so much more important than the actual task. Some people constantly talk about the things they are going to do but then keep procrastinating. In addition, this plan references the Service Level Evacuation Standards1 developed by the Joint Emergency Management Steering (JEMS) Committee. Updates to the plan will be undertaken as required based on lessons learned from exercises and incident responses.
It is a provincial coordination plan outlining how Ontario would coordinate its response and collaborate with federal and municipal governments, First Nations, non-governmental organizations, and ministry partners. It is not intended for internal evacuations of one part of a community to another part of the same community. This plan does not replace a community’s own emergency response plans, which should contain provisions for evacuations if they consider evacuations likely. A detailed action plan that addresses the specific scenario, hazard, and threat will still be required. Evacuations are most frequently caused by forest fires and flooding (most often from spring break-up along the James Bay coast).
Communities in the far north may be located significant distances from communities with road access or from regional centres where services may be available (e.g.
Damage to property or the environment may also trigger an evacuation if it poses a risk to the safety, health, and welfare of people. It also dictates what level of activation, and how many and what type of resources will be required for the evacuation. If the evacuation is for one or a few communities, planning may be restricted to movements within the same general geographic area. Therefore, planning should include post-hosting needs, such as financial reconciliation, demobilization support, and reports on issues to be resolved before hosting evacuees in the future. This allows the incident management team, and all partners, to take informed, effective and consistent actions in a timely manner. However, as the level of activation increases, the PEOC duty officer transfers this function to a technical specialist or team, if available. These ministries have processes in place for transferring the responsibility for real-time threat assessment to specialists within their ministry when required. All activities and efforts should be focused on moving these people from the at-risk area to places of safety in a timely manner. This list should contain the names of persons needed to restart systems that must be in place before evacuees can return home (e.g.
If an authorized entity decides on a partial or complete community evacuation, the community should declare an emergency. A pre-emptive evacuation may be undertaken when it is clear that if delayed, conditions (weather or other hazard) would impede evacuation. Evacuations of this nature are done when life safety is at extreme risk and a rescue becomes essential. For example, evacuations of large populations to one or more host communities may require logistics support to secure modes of transportation from a receiving aerodrome or transportation hub to the host community.
Communities are encouraged to make the decision to evacuate as soon as a significant or imminent threat is identified. In widespread evacuations, emergency information may need to be coordinated amongst all involved partners.
To assist with streamlining communications, an operational cycle should be established and communicated by the PEOC to partners so they know when they are expected to provide updates on the situation from their perspective. Partners should have back-up technologies available, particularly for their deployed staff. It is preferable to host community members together, even if it means hosting them farther away from their home community. Evacuation liaisons represent the needs of evacuees when attending meetings with the host community and other agencies. If the information is not collected on the manifest, registration services can collect and provide this more detailed information. Depending on the scale of the incident, and the numbers and locations of persons to be evacuated, the needs may exceed the capacity of available resources.
The Standards provide guidance on allowable expenditures, hosting arrangements, health services, emergency social services, etc. If requested, the PEOC could assist other communities in identifying potential host communities. It is worth noting that community health services and hospitals in the host community may experience an increased demand for their services. Representatives from provincial (through the PEOC) and federal organizations may be available to assist a host community in providing services to evacuees. It is generally understood that time of year may affect the host community’s ability to provide accommodations during an evacuation. This allows the host community to better coordinate services and seek reimbursement for expenses incurred due to hosting. The recommendation and the decision to return should be based on the results of the ongoing real-time threat assessment, plus a determination that the home community is ready to support the returning evacuees. This may involve the coordination of an advance team that is given sufficient time and other resources to return the community to a pre-evacuation state. It is critical that at the end of an evacuation, there is a full accounting of the operation in the form of after-action and financial reports. Both the Red Cross and FEMA recommend that you try to be self-sufficient for at least 72 hours (3 days) following a disaster. Power outages can close grocery stores, put ATM machines out of order and prevent you from doing simple things like putting gasoline in your car. We cannot control the weather or prevent disasters from happening, but there are steps you can take to minimize risks from known hazards. Professional emergency workers are rapidly overwhelmed in mass emergencies so trained, organized, responsible volunteers are extremely valuable. Its comprehensive articles, meant to help growers start building a risk management plan, is a cooperative effort between RMA, the Economic Research Service, and Farm Futures magazine.
The UPS Store is equipped to handle all of your copying, faxing, printing, binding, packaging, and shipping needs, as well as support you with office and exhibitor supplies, office equipment rentals and internet access. Morial Convention Center is an essential component of what makes the city’s major business events so successful. The world-famous attractions of the French Quarter lay just steps away from the convention center, while the historic St. Prior to the economic downfall in 2008 and high-profile investment scandals made infamous by Bernard Madoff and others, hedge fund due diligence was viewed as an unnecessary assignment. They figured there would never be a shortage of investors, so there wasn’t a need to spend extra time satisfying their needs. In the past, the responsibilities associated with hedge fund due diligence would often fall under the role of a CFO, CCO or other executive – someone who had very little time to devote specifically to due diligence. There has, undoubtedly, been a significant increase in the number of due diligence inquiries by hedge fund investors, and the questions they are asking are much more relevant and involved - that rings true across business and operations functions, technology departments and the investment side of the business. They want more information, more transparency and more assurances that fund managers have done their own due diligence in assembling and managing their infrastructure and overall businesses. Small-scale disasters, such as winter weather scenarios, and larger incidents like the Madoff scandal have initiated a real shift in the hedge fund industry and highlighted the need for hedge funds to have robust technology solutions in place and systems and procedures to keep them operational at all times. During the due diligence process, they often ask to see systems at work, the processes through which data is transmitted and stored, and how testing procedures work. Explain the designs and processes of your operations, particularly when it comes to your technology.
If you do not have an in-house IT staff, you can ask your technology service provider to do this for you. You will score points with investors if you are up front about everything and don’t attempt to hide anything.
Hire a consultant to help you with this – it is the single easiest way to prepare for a real investor review. Test your disaster recovery system frequently (at least twice annually), and show the results to investors. Investors want to see that funds are serious and that they value operations and technology as vital aspects to their businesses. It does not begin when an investor comes in for a meeting and end when they walk out the door. Not only must emerging managers evaluate traditional deployment strategies, but consider current factors influencing the financial landscape. There was quite a bit of content discussed during the 1-hour event, so we’ve pulled out some key takeaways. Target those who have a history of being receptive to founder share class and who may offer lower management and performance fees.
Recognize where the private cloud has an edge: high-touch, industry-specific service and support, scalability and application integration, and security and compliance.
Value is derived from knowledge of the application, knowledge of business, and having a dedicated support team. The NFA's Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49 entitled Information Systems Security Programs requires Member firms to adopt and enforce written policies and procedures to secure customer data and access to their electronic systems.
Executive-level participation and annual review of the information security program is expected.
NFA expects to devote appropriate resources, such as providing additional guidance, to assist Members as they develop and implement their ISSPs. Don't forget to visit Hedge IT on Thursday as we reveal the last of our key considerations for starting a hedge fund. Hedge funds, private equity firms and registered investment advisers now operate in a world where they are beholden to regulatory bodies with growing expectations and requirements. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which redefined the registration requirements for hedge funds, also set forth new reporting requirements and standards for safeguards.
With the prevalence of cyber threats and attacks, the SEC’s Office of Compliance and Examinations (OCIE) has incorporated cybersecurity into its examination targets.
Firms can add users nearly instantly – a welcome benefit for startups looking to ramp up quickly. You can do this by conducting employee awareness training to keep all users informed and educated about the cyber environment and the threats that may arise. And be sure to come back to Hedge IT later this week when we'll be sharing an excerpt from our brand new whitepaper on the same topic! Regulatory agencies and investors now expect businesses to have backup solutions and comprehensive record-keeping practices. In addition, international regulators such as the FCA, a financial regulatory body in the United Kingdom, are also demanding firms to have a data backup solution. From hardware failure, software corruption, virus or network security breaches, to natural disasters and human error, the threat to your data is endless.
Businesses that demonstrate that their data is secure and backed up have a competitive edge when security questions inevitably come their way.
And by 2017, seventy-five percent (75%) of organizations will have replaced their remote-office tape backup with a disk-based backup solution that incorporates replication, up from forty-five percent (45%) today. A SMB Disaster Preparedness Survey by Symantec found that downtime costs small businesses an average of approximately $12,500 per day and medium businesses $23,000 per day. Eze Castle partners with KeepItSafe, a leading provider for managed online backup and recovery, to deliver our Eze Vault services. For example, what exactly will your employees need to fulfill their functions remotely and are they trained to do so?
Therefore, if the storm seems to be impassable it is best to allow employees to work remotely. In addition to providing employees with security best practices they should follow, don’t forget to also include a list of actions they should not.
Over the past few years, as regulations have changed and investors increasingly seek transparency, hedge funds are spending more time than ever preparing for the due diligence process. As this trend continues, investors are raising their expectations and looking towards hedge funds that display the highest levels in operational excellence. One major area of focus is the hedge fund’s IT and accompanying cybersecurity policies and procedures.


Are steps being taken to ensure visitors do not have the ability to observe or access sensitive employee systems and documents? Have appropriate training and documentation been established and shared with all personnel?
So here’s a list of the top 4 IT resolutions that will help keep your hedge fund safe and sound in 2016. Everything and everyone is going cloud so take some time to explore what a cloud solution could bring to your firm. The goal here is to gauge the level of security in place to protect against external threats and cyber-attacks. With investors and regulators asking to review these polices, they are no longer just nice-to-haves. Because infrastructure costs are spread across all users who are employing the service, each individual client is able to operate at a low cost. However, upon closer examination, it is clear that there are a number of areas in which these tools fall drastically short of meeting the crucial business needs of investment management firms. Once your firm expands to the point of requiring additional applications such as a CRM, OMS and accounting tools, a free file sharing provider’s capabilities will no longer be enough to support your needs. For instance, although Gmail or Hotmail may be able to handle basic email needs, they will not provide the full business email experience as is attainable via Microsoft Exchange, and they are lacking many of the features and capabilities that Exchange provides. They also lack integrated voicemail capabilities, which means users cannot manage voice messages easily from their PC.
Free public cloud services are not accompanied by dedicated, vertical-specific IT support that is incorporated with quality private cloud infrastructures. It also instills confidence with investors and other stakeholders while providing a competitive advantage. These tools have earned a negative perception due to their lack of effective security precautions. In addition to the IT infrastructure, it covers people, facilities, workplaces, equipment, business processes, and more. High availability can be implemented into a firm's IT infrastructure by reducing any single points of failure using redundant components. In working on the Eze Disaster Recovery team, I have heard a variety of reasons from clients as to why this is the case.
Current technologies allow IT providers to overcome just about any objection users may have with regards to DR testing. We often find that firms grow, evolve, and change their production environments as they develop and expand their businesses.
At Eze Castle, we typically recommend that users think about their daily workflow when testing to help ensure all critical applications and data are available in the event of an outage. Typically, DR solution agreements will include regular testing as part of the service package, and we strongly recommend all firms take advantage of this component. However, the reality is that many disaster recovery solutions (including Eze Castle’s!) can be tested in a manner that avoids any disruption to the production environment.
Even just a few moments of downtime could be extremely costly, so it is essential that firms implement sound business continuity procedures.
More often than not, people will get caught up with the nice to have activity rather than the critical work which creates more value for the business.
As many of the communities in the far north are First Nations, coordination with the federal government is crucial. Two communities falling within the focus area have road access (Mishkeegogamang and Pickle Lake) and there is a rail link to one municipality (Moosonee). However, the evacuation of multiple communities due to an area-wide emergency is likely to require out-of-area movements for hosting, particularly when the goal is to keep families and communities together. The size and demographics of the population are significant factors in determining how to conduct an evacuation. This would include: scheduling such that staff do not become overly fatigued by the operation and providing as much advance notice of scheduling as is possible given the nature of the incident.
In addition, up-to-date contact lists should be maintained by all organizations for use in an emergency. Alternate technologies that may be utilized in an evacuation include satellite phones and amateur radio. They should also be identified to the host community as resources that may be called upon to assist evacuees. This mitigates the risk of families being separated and makes the return of evacuees less complicated. Evacuation liaisons also assist with creating manifests and determining the order of the return of evacuees in consultation with the Chief, Head of Council, or appointed person from the home community.
Once a flight manifest is prepared, it should be sent to the PEOC, which can in turn forward it to other organizations that require the information.
Receiving the information in advance can help ensure that needed services are delivered quickly. In this situation, evacuations may need to be prioritized and contingency plans implemented. While the Standards provide guidance on hosting First Nations, they may also be applied to municipal or unorganized territory evacuations as they pertain to hosting arrangements. While agreements may exist between EMO and a host community, the community retains the option of not hosting during a particular evacuation.
Emergency planners should assess proposed facilities based on location, capabilities, capacity, accessibility, and resources, as well as how they would route evacuee traffic.
Municipal departments involved in the development of the host facility plan may be able to provide resources to support the set-up and operation of a host facility. Registration involves creating a municipal record, which is covered under municipal privacy legislation.
Since the degree of damage will likely vary within the affected area, it might be beneficial to initiate a phased re-entry process.
In most instances, people are returned in the reverse order of when they were evacuated (i.e. As with the initial evacuation, numerous resources, especially personnel and transportation related resources will be required to return evacuees to their home community.
It also shows the various partners likely to be involved in an evacuation, broadly reflecting the actions that fall within their jurisdiction. Organizations like Community Emergency Response Teams and the Red Cross are ready sources of trained volunteers. And you know in New Orleans, we like to DREAM BIG and make Meeting Planning EASY on our Customers.
But as the hedge fund industry has evolved over the last several years, so has the need and desire for operational excellence.
You can also compile a comprehensive presentation or simply have an open question and answer session with your potential investors. Due diligence is an ongoing process that can continue to improve and evolve as investors and fund managers open the lines of communication and maintain an open dialogue. Prepare an institutional set of documents up front if you are looking to attract institutional money versus high net money.
They include risk assessment, governance, training, access control, vendor management, and information sharing. Additionally, firms must provide employees training during the onboarding processes as well as periodically during employment. For example, system safeguards such as data protection, disaster recovery measures and email archiving are requirements under Dodd-Frank.
Having released two extensive questionnaires and several risk alerts focused on security, the SEC has made it clear to investment firms that they will be investigating the practices employed at firms and increasing expectations for the future. Startups have a variety of options when it comes to settling on their technology infrastructure. Users can gain access to email, file services and applications from virtually anywhere, and built-in disaster recovery provides confidence that everything is protected from the inside out. Users should understand how security threats may present themselves (phishing schemes, social engineering, etc.) as well as how they can become cybersecurity assets to your firm. Successfully operating a new startup beyond the first year is a feat many managers struggle to accomplish, therefore it's critical for emerging managers to gain a full understanding of the industry that awaits them and the hurdles they should expect to face. Understanding the need and importance of implementing a backup solution can add instrumental value to your business.
With today’s financial services companies managing exponentially growing volumes of sensitive data, the risk of loss grows as well.
If something were to happen to the data center where your production system lives, you can resume operations in DR. Having a third-party backup solution provides geographic diversity of data assets, which is key for a complete business strategy. Recently, KeepItSafe highlighted the success of a backup and recovery case when a company’s servers crashed, and with it, so too did their records of billing history, accounts receivable and accounts payable. With these unprecedented levels of snow, New York City was forced to halt public transportation and implemented a mandatory restriction on private transportation as well. One must also consider licensing, infrastructure, security, and employee comfort as working from home will be a change for them.
If essential functions are unable to meet their workload demands from home, then temporary office space with redundant power is always an option. It is always important to review your business continuity plan and make sure employees are aware of their roles if an issue were to occur. In today's landscape, however, investors and regulators alike expect and demand that firms implement preparedness plans for disasters and cyber-attacks.
Take a look below and discover a vast range of security tips and tricks from email encryption to proper security measures for protecting computers and mobile devices. One important way to ensure your firm meets these high standards is to complete a due diligence questionnaire (DDQ) that can be shared with potential investors. At Eze Castle, we frequently assist our hedge fund clients in completing DDQ questions on technology, and we often see the same types of questions popping up. In addition, a great resource for conducting due diligence on a hedge fund's service providers is the 200 question document published by the Alternative Investment Technology Executives Club (AITEC).
From enhanced security and disaster recovery to resiliency and extensive application sets, a cloud solution may be a game changer for your firm. It is not uncommon for firms to change their production environments as they grow and evolve, but it is critical that DR remains an exact mirror so users have a seamless experience should activation occur. Beyond having Business Continuity and Information Security Plans, you also need to appoint a Chief Information Security Officer and have an incident response playbook.
Public cloud tools are typically larger in scale than private enterprise clouds, which provide users with seamless, on-demand scalability.
While this tool may be suitable in helping your firm get off the ground with minimal upfront costs, it is not a viable long-term solution. In fact, several of these providers have experienced outages in recent years, some of which have lasted for hours or days at a time. In a business setting, this could mean that sensitive company or client data is exposed externally.
Public cloud tools may not include a built in disaster recovery solution, so this is a significant additional cost that your firm will have to consider. The SEC currently advises that funds retain all internal and external email and IM business communications, a perspective that is shared by the majority of investors as well. Be sure to read our articles on the difference between DR & BCP and preparing for a worst case scenario. Additionally, we are hearing from a growing number of hedge fund clients whose investors now require them to test their DR solutions and report on the results from those tests. In turn, the DR site needs to evolve and change simultaneously in order to continuously meet business requirements. Results should be documented and provided back to your DR provider so that they can assist you with resolving any issues that may have arisen during the course of the test. Regular testing helps to capture the ever-changing requirements of a business, so that gaps or issues can be addressed in advance of a disaster.
Being ruthlessly focused means you have the ability to cancel out this noise and focus on what is important. This plan supports the activities being undertaken related to mass evacuation planning for ministry and community emergency management programs.
There are two municipalities that fall within the focus area (Moosonee and Pickle Lake) plus more than 30 First Nation communities. This is facilitated through liaison that may be in place between OIC ministries and federal departments - for example, between the Ministry of Health and Long-Term Care, Health Canada and Local Health Integration Networks (LHIN). Alternatively, the Chief of the First Nation, Head of Council, or an appointed person may decide to conduct a complete or partial evacuation based on an assessment of the threat to area residents. This approach minimizes potentially having people in harm’s way and enables a more controlled evacuation and optimization of resources. Where possible, identify the positions, rather than individuals who may be involved in the operation. Notwithstanding this recommended practice, a host community’s capacity may be such that it is unable to accommodate an entire community. In the event that the list of potential host communities is insufficient for the size of evacuation pending, the PEOC will solicit additional host communities. Details on the set-up and operation of the shelter should be provided in the community’s emergency response plan.
Each municipality has the responsibility for managing the record in accordance with the applicable legislation and their municipal policies.
The Chief of a First Nation, Head of Council of a municipality, or appointed person, will decide when to allow evacuees to return to the community. Everyone is simply excited to be in one of the world’s most storied and culturally rich destinations. The excitement of New Orleans transforms an obligatory business trip into an unexpected experience.
Hedge funds should continue to take the time to understand where the real risks are within their businesses and work to instill confidence with their investors. Regardless of the assets your firm is launching with, you will be expected to have sophisticated and comprehensive policies and procedures in place from day one to combat cyber threats. With the birth of cloud technology, firms can save on upfront capital expenditures and host their infrastructure in the cloud – providing flexibility within those startup budgets. A reputable cloud services provider not only provides world-class infrastructure and resiliency; it also assumes responsibility for the management and daily maintenance of your cloud environment. Investors also have high expectations, and before they will even consider allocating money to your firm, they want to understand what protections you’ve put in place to protect their assets. However, if something is deleted in the production environment, that action is typically mirrored, thus deleted in DR as well. DR allows the rapid recovery of IT operations while cloud backups provide another layer of protection by leveraging a third-party vendor to secure your data in an alternative location. Jonas proved to be kind in the fact that the majority of the impact fell on the weekend but many firms can recall more disruptive storms occurring during regular business hours leaving many employees feeling stranded.
Just as importantly, if an outage does occur, there is no way to effectively communicate with an IT support expert to address and resolve the issue in a timely manner.
Also, because security measures are typically much more lax than with an enterprise-grade private cloud service, emails and other communications may be susceptible to interception by hackers. With a top quality private cloud infrastructure, disaster recovery is built directly into the offering and is seamlessly integrated to ensure your data is protected at all times. Public cloud and free email tools do not contain effective archiving and recovery capabilities, and could put your firm at risk of compliance violations should an issue arise. This trend is putting more pressure on firms to participate in regular testing than ever before. By regularly testing their DR sites, firms can ensure all of these needs are met and they will be fully prepared to continue operations should a disaster occur.
This requires less coordination with user groups, and therefore has minimal impact on the firm’s daily operations. It draws linkages to various hazard management plans and procedures developed by ministries.
The exact population at any one time is difficult to report as people who are recorded in the census may be away from the community and some who are not recorded may be in the community.
Unorganized territories, fly-in lodges and camps, and mining operations also fall into the plan area.
The seasonal roads cannot be relied on for evacuation operations given the short and sometimes unpredictable length of time that they are available.
Local populations often provide the best information on the threat to their community and the region. Emergency responders may require personal protective equipment, as responder safety will be critical. Where an entire community may not be hosted together in close proximity to the home community, and if the situation allows, the community’s preference should be discussed with the Head of Council, First Nation Chief, or appointed person. The primary reason for returning the most vulnerable people last is to help ensure that support services are in place when they return. Traditional, old-time jazz music enlivens the soul, the cuisine is incomparable, and the city’s charm captivates.
Disaster recovery, business continuity planning and cybersecurity preparedness should all be viewed as full business exercises, not solely technology ones. Be sure to enable your firm’s processes to comply with SEC recommendations including risk assessments, infrastructure practices, policy documentation, etc.
With hackers savvier than ever and financial firms as known targets, it’s critical that firms establish a comprehensive approach to security to not only meet investor and regulatory demands but also to protect firm assets and mitigate business risk.
Backups, on the other hand, create an offline copy of your data which is not accessible except to restore, sometimes utilizing a third-party vendor to store that data in an alternate location.
The importance of protecting this data is interconnected to the importance of the overall operations of the business. To alleviate the stress incurred during winter storms, we sat down with our own Business Continuity Analyst, Matt Donahue, who creates, writes, and audits hedge fund’s business continuity plans. As far as specific remote access technologies, Matt recommends Virtual Private Networks (VPN), Citrix or Outlook Web Access (OWA), depending on a user’s specific needs. These tests do not need to be elaborate, for example, a work from home day or a call tree run through might suffice. With premier private cloud providers, your solution is accompanied by 24x7x365 help desk support equipped with the knowledge and resources to resolve technical issues quickly. For example, there may be people staying at fly-in lodges that do not report year-round population. If not forthcoming, you may open up your firm to serious regulatory and criminal prosecution.
Your cloud services provider should act as your trusted technology adviser and, as such, give you the flexibility and time you need to focus on your investment priorities without worrying about security updates and patch controls. If access to a file was lost in both production and DR, backups grant the ability to recover the data and continue business as usual.
This is an example of a successful case; however, many businesses lacking a backup solution are not so lucky. Matt spoke with us about different BCP scenarios and provided tips to keep your firm operational during the worst of storms. Similarly, there may be community events that draw tourist and other visitors to the community.



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