[BCM] [BIA] [ISO22301] [P6] Vital Records

Part 6: Vital Records (Aligned with ISO 22301 BCMS)

Introduction

As part of the Business Impact Analysis (BIA) and the broader Business Continuity Management System (BCMS), Part 6: Vital Records focuses on identifying and protecting information and records that are essential to the organisation's continued operation and recovery following a disruption.

In accordance with ISO 22301:2019, organisations are required to determine and maintain documented information necessary for the effectiveness of the BCMS (Clause 7.5) and to ensure that information required to deliver priority activities is available and recoverable within required timeframes (Clauses 8.2 and 8.4). Vital records form a critical component of this requirement.

This chapter supports the organisation in identifying records indispensable to legal compliance, operational continuity, decision-making, and recovery, and in ensuring that these records are appropriately protected, backed up, and accessible during an incident.

The outcome of this exercise directly informs continuity strategies, recovery planning, and information security controls.

Objectives of Part 6: Vital Records (ISO 22301 Enhanced)

The objectives of this section are to:

1. Identify vital records required to perform priority activities, as determined through the BIA, in line with ISO 22301 Clause 8.2 (Business Impact Analysis).

2. Ensure availability and integrity of critical information needed during disruption and recovery, supporting Clause 8.4 (Business Continuity Plans and Procedures).

3. Assign clear ownership and accountability for the protection, maintenance, and accessibility of vital records, consistent with Clause 5.3 (Organisational Roles, Responsibilities and Authorities).

4. Determine storage, backup, and retrieval arrangements that meet defined recovery time and recovery point requirements.

5. Support compliance obligations, including legal, regulatory, contractual, and evidentiary requirements, as required by Clause 4.2 and Clause 8.2.2.

6. Enable effective incident response and decision-making by ensuring continuity teams have timely access to accurate, reliable information.

Content and Guidance for Completing the Template

When completing Part 6: Vital Records, the focus should be on records that are critical, unique, and not easily replaceable within the required recovery timeframe. The following fields should be completed carefully:

1. Business Function and Function Code

This field links each vital record to the relevant business function identified in earlier BIA sections. This alignment ensures traceability between priority activities and the information required to support them, as required by ISO 22301.

2. Description of Vital Records

Provide a clear description of each vital record, including documents, data sets, registers, or databases that are essential for:

• Continuing operations

• Meeting legal or regulatory obligations

• Supporting recovery and restoration activities

Examples include:

• Contracts, agreements, and SLAs

• Licences, permits, and regulatory approvals

• Financial records and statutory filings

• Policies, procedures, and standard operating manuals

• Customer, employee, or supplier records

• System configuration files and critical reference data

3. Media Type

Indicate the format in which the record exists, such as:

• Paper documents

• Electronic files

• Databases

• Cloud-based repositories

• Backup tapes or removable media

Understanding the media type is essential for determining protection, backup, and recovery methods, as well as assessing vulnerabilities across different disruption scenarios.

4. Location

Specify where the record is stored, including:

• On-site physical storage

• On-premise IT systems

• Offsite storage facilities

• Cloud or third-party service providers

Where applicable, both primary and backup locations should be documented to demonstrate compliance with ISO 22301 requirements for availability and resilience of information.

5. Custodian / In Whose Care

Identify the role or individual responsible for maintaining and safeguarding the record. This supports:

• Accountability and governance

• Controlled access to sensitive information

• Efficient coordination during incidents and recovery

Custodians should be aware of their responsibilities within the BCMS and recovery arrangements.

ISO 22301 Considerations and Good Practices

When completing this section, organisations should:

• Focus on records essential to priority activities, rather than attempting to catalogue all information.

• Ensure backup arrangements align with defined RTOs and RPOs identified during the BIA.

• Consider confidentiality, integrity, and availability when determining storage and access arrangements.

• Ensure records held by third parties or in the cloud are covered by appropriate contractual and recovery assurances.

• Periodically review and update vital records information as part of BCMS maintenance and change management (Clause 10).

Part 6: Vital Records plays a critical role in ensuring that the organisation’s most important information assets remain protected, accessible, and recoverable during and after a disruptive incident.

By systematically identifying vital records and aligning their protection with business continuity requirements, the organisation strengthens its ability to sustain priority activities and meet its obligations under ISO 22301.

The outputs from this section provide essential input into business continuity strategies, recovery plans, and incident response procedures, while also supporting governance, compliance, and organisational resilience.

When properly maintained and regularly reviewed, the Vital Records Register becomes a foundational element of an effective and auditable Business Continuity Management System.