[BCM] [MOM] [E3] [PD] [CBF] [2] Foreign Workforce Management

Business Continuity Recovery Procedure

CBF-2: Foreign Workforce Management

The Critical Business Function (CBF-2) for Foreign Workforce Management is central to maintaining the operations of businesses across the country that rely on foreign labour, as well as safeguarding the well-being of foreign workers themselves.

This document outlines the Business Continuity Recovery Procedure for CBF-2, detailing how the Ministry can ensure a seamless and resilient response to disruptions affecting the management of foreign workforce processes.

The procedures cover the pre-crisis preparation, immediate resumption after a crisis (T+24 hours), and full recovery beyond 24 hours.

CBF-2 Foreign Workforce Management Overview

Sub-CBF Code and Sub-CBF for CBF-2:

• Sub CBF-2-1: Policy & Planning
• Sub CBF-2-2: Work Pass Application & Issuance
• Sub CBF-2-3: Arrival, Onboarding & Deployment
• Sub CBF-2-4: Monitoring, Compliance & Enforcement
• Sub CBF-2-5: Renewal / Transfer / Exit Management
• Sub CBF-2-6: Support Services & Well-being

These sub-functions ensure the proper management of foreign workers throughout their lifecycle, from application and entry into the country to their well-being, compliance, and eventual exit.

WHAT: Description and Importance of CBF-2

CBF-2 Foreign Workforce Management is the backbone of the Ministry of Manpower’s operations related to managing foreign workers in Singapore. The criticality of CBF-2 lies in:

• Economic Impact: Foreign workers are integral to key industries, and disruptions in their management can lead to severe economic consequences.
• Compliance and Legal: Strict regulations govern work passes, entry, and deployment, making effective management critical to national security and compliance with immigration laws.
• Worker Welfare: Ensuring foreign workers are onboarded, supported, and monitored is key to their well-being and productivity.

In the event of any disruption, the Ministry must implement an immediate recovery plan to mitigate negative impacts on workers, businesses, and the country’s economy.

Pre-Crisis: Preparation and Readiness

The Pre-Crisis phase focuses on the proactive measures that the Ministry of Manpower (MOM) must implement to ensure that the organisation is prepared for any potential disruptions affecting CBF-2 Foreign Workforce Management.

These steps aim to minimise the impact of a crisis and enable a swift and efficient response when a disruption occurs. Proper preparation will also ensure that recovery can be achieved more rapidly.

Here’s an expanded breakdown of the Pre-Crisis readiness measures for CBF-2 Foreign Workforce Management:

Risk Assessment and Crisis Identification

• Ongoing Risk Identification:

• Conduct regular assessments to identify emerging risks to the foreign workforce management system. This includes risks related to cyber threats, natural disasters (e.g., earthquakes, floods), pandemics, power outages, supply chain disruptions, and geopolitical tensions that may affect foreign labour mobility.
• Engage external experts and partners (e.g., immigration authorities, cybersecurity firms, public health agencies) to ensure that all potential risks are accounted for, and their likelihood and impact are properly evaluated.

• Scenario-Based Planning:

• Develop crisis scenarios specific to the foreign workforce management function. These scenarios should cover various types of disruptions (e.g., system failures, mass worker arrivals, political unrest) and their cascading impacts on the sub-functions (work pass issuance, compliance enforcement, worker support services, etc.).
• Test scenarios with simulations to identify weaknesses in current processes and systems, and update crisis management protocols accordingly.

• Crisis Categorisation:

• Classify risks based on severity (e.g., critical, high, medium, low) to prioritise response actions. Focus on those scenarios with the potential to disrupt critical sub-functions, such as Sub CBF-2-2 (Work Pass Application & Issuance) and Sub CBF-2-3 (Arrival, Onboarding & Deployment).
• Maintain a Risk Register that captures the potential impact of each risk and assigns responsibility for mitigation.

Establishment of Crisis Management Team (CMT)

• Team Formation and Responsibilities:

• Designate a Crisis Management Team (CMT) with key personnel responsible for managing the various aspects of a disruption. The team should be cross-functional, including representatives from:

• Policy & Planning
• IT & Systems
• Compliance & Enforcement
• External Stakeholders (e.g., Immigration Authorities)
• Human Resources
• External Communications

• Assign clear roles and responsibilities to each team member, ensuring that each sub-CBF is covered under the CMT's operational framework.

• Crisis Management Team (CMT) Training:

• Provide CMT members with training on crisis management protocols, including escalation procedures, resource allocation, and communication strategies.
• Regularly run tabletop exercises and crisis simulations to test the team’s readiness and to familiarize them with their specific roles during a crisis. Ensure that these exercises are as realistic as possible, involving not only internal team members but also key external stakeholders such as other government agencies, labour unions, and employers.

• Succession and Backup Plans:

• Ensure that the CMT has designated backups for each critical role, with clear succession planning in case key personnel are unavailable. This ensures continuity in leadership and decision-making.

Business Continuity Planning (BCP) Development and Documentation

• Comprehensive BCP for CBF-2:

• Develop a detailed Business Continuity Plan (BCP) for each sub-function of CBF-2. The plan should outline step-by-step recovery actions for each critical process, including Sub CBF-2-4 (Monitoring, Compliance & Enforcement) and Sub CBF-2-5 (Renewal / Transfer / Exit Management), which are crucial for maintaining the legal standing of foreign workers.
• Ensure that all business continuity documentation is easily accessible, regularly updated, and tailored to the specific needs of foreign workforce management.

• Integration with Organisational BCP:

• Integrate CBF-2-specific BCPs into the overall Ministry of Manpower’s organisational business continuity framework. This will ensure that recovery efforts align with MOM's broader crisis management strategies.
• Include escalation triggers, impact tolerance thresholds, and pre-identified recovery objectives (RTO and RPO) for each critical function.

• Resource Identification

• Identify and document all critical resources required for the recovery of each sub-function. These resources may include:

• Personnel: Ensure that key staff members are trained and available to resume operations in a crisis scenario.
• Technology: Identify critical IT systems, data, and infrastructure, including remote access solutions, backup systems, and cloud services.
• Suppliers and Partners: Maintain a list of key suppliers, contractors, and external stakeholders who may be called upon for assistance during a crisis.

IT Systems and Data Protection

• Data Redundancy and Backup Systems:

• Ensure that critical data related to foreign workforce management (e.g., work pass applications, compliance records, worker health and welfare data) is backed up regularly and securely. Implement automated backup solutions that occur at predefined intervals (e.g., daily, weekly).
• Establish off-site backups and cloud storage to ensure that data can be accessed in the event of a disaster that impacts physical systems or locations.

• IT System Recovery and Redundancy:

• Set up IT redundancy systems to guarantee continued operations in case of hardware failure or cyberattacks. Ensure that all key systems are supported by disaster recovery plans and can be restored within the defined Recovery Time Objectives (RTO).
• Develop remote working capabilities for all critical staff, ensuring that they can continue performing their duties from alternative locations if office access is limited.

• Cybersecurity Measures:

• Implement robust cybersecurity protocols to protect sensitive foreign workforce data from cyberattacks or breaches. This includes regular vulnerability assessments, employee awareness training, and disaster recovery procedures specifically for IT systems.

Communication and Stakeholder Management

• Internal Communication Plans:

• Develop a communication plan for internal stakeholders, including MOM staff, to ensure that everyone is informed about the situation, their roles during the crisis, and how they can contribute to the recovery process.
• Pre-define Crisis Messaging Templates that can be quickly adapted for different scenarios, ensuring that key messages are consistent and clear.

• External Communication Plans:

• Establish communication channels with external stakeholders, including foreign workers, employers, relevant government agencies, and the public. These channels should be secured, accessible, and capable of scaling to handle high volumes of communication during a crisis.
• Ensure that foreign workers receive timely updates about disruptions to the services that may affect their work passes, legal compliance, or welfare.

• Stakeholder Awareness and Coordination:

• Maintain regular engagement with key external stakeholders such as labor unions, employers, and other government bodies to ensure they are aware of the Ministry’s crisis management protocols.
• Develop pre-arranged coordination frameworks with other critical organizations to facilitate the sharing of information during a crisis.

Testing, Exercising, and Continuous Improvement

• Crisis Simulations:

• Conduct regular crisis simulation exercises and table-top drills involving all relevant personnel, including those from external partners and agencies. These exercises should replicate real-world scenarios and stress-test all aspects of the crisis response, including coordination, recovery, and communication.
• Use the exercises to identify weaknesses in the plan and make necessary adjustments.

• Lessons Learned and Plan Refinement:

• After each exercise or real crisis, perform a post-incident review to evaluate the effectiveness of the response and identify any gaps in procedures, training, or resources.
• Update the CBF-2 Business Continuity Plan based on lessons learned, and continuously improve preparedness for future crises.

By implementing these proactive measures, the Ministry of Manpower will ensure that it is fully prepared to handle any disruption to foreign workforce management operations.

These preparations will help minimise the impact on the country’s workforce and economy, ensure compliance with regulatory requirements, and maintain the well-being of foreign workers.

Proper readiness guarantees a more efficient and effective crisis response, ensuring that MOM can maintain its crucial functions even during times of crisis.

Within T+24 Hours (RESUMPTION)

The T+24 Hours period marks the critical window in which the Ministry of Manpower (MOM) must act to resume essential operations and mitigate the impact of the disruption on foreign workforce management functions.

The objective is to restore core processes, maintain essential services, and provide immediate support to foreign workers, employers, and other stakeholders.

The following steps outline the immediate recovery actions required to resume operations within the first 24 hours after a crisis or disruption occurs:

1. Activation of Crisis Management Protocols

• Crisis Management Team (CMT) Mobilisation:

• Activate the Crisis Management Team (CMT) immediately after the disruption occurs. The CMT should gather at the designated command centre (physical or virtual) to assess the situation, allocate resources, and begin implementing the recovery process.
• Assign specific recovery tasks to individual team members, ensuring clear responsibility for each sub-function of CBF-2 Foreign Workforce Management.
• Monitor the progress of recovery efforts through regular CMT check-ins and adjust resources or strategies as needed to ensure swift resumption.

• Initial Crisis Assessment and Situation Update:

• Assess the scope of the disruption to understand the impact on each sub-function of CBF-2 (e.g., Sub CBF-2-2 Work Pass Application & Issuance, Sub CBF-2-4 Monitoring, Compliance & Enforcement, Sub CBF-2-6 Support Services & Well-being).
• Communicate the findings to key internal and external stakeholders, providing a clear picture of what has occurred, which operations are affected, and when normal operations are expected to resume.
• Define the Recovery Time Objective (RTO) for each critical sub-function based on the severity of the impact, prioritising the most time-sensitive processes (e.g., work pass issuance, employee compliance checks).

2. Prioritisation and Restoration of Critical Sub-CBFs

• Prioritise Core Functions for Resumption:

• Focus on restoring core operational functions that directly impact the continued employment of foreign workers and compliance with Singapore's immigration laws. Key priority sub-functions include:
  • Sub CBF-2-2: Work Pass Application & Issuance – Restore functionality for processing work pass applications and renewals to prevent delays in worker deployment.
  • Sub CBF-2-4: Monitoring, Compliance & Enforcement – Ensure that systems are in place to monitor foreign worker compliance with legal requirements (e.g., visas, permits), particularly for high-risk categories.
• Develop an action plan for the resumption of other sub-functions, ensuring that they follow a clear timeline for reactivation.

• Temporary Workarounds for Affected Functions:

• Implement temporary measures to maintain foreign workforce management operations where full functionality has not yet been restored. For example:
  • Manual processing of work pass applications if digital systems are down, with an alternative method for verification and approval.
  • Limited compliance checks manually recorded by staff in cases where automated systems are not yet operational.
  • Temporary extension of work permits or other legal documentation for foreign workers in transition.

• Activate Temporary Backup Solutions:

• In cases where IT systems are severely impacted, activate backup data systems to provide immediate access to key records and worker data. These could include:
  • Cloud-based databases or secure physical backups to access critical work pass and compliance records.
  • Alternative communication platforms (e.g., email, mobile applications) to interact with foreign workers and employers while primary systems are being restored.

3. Communication with Stakeholders

• Internal Communication:

• Alert all relevant MOM staff about the crisis and resumption efforts, ensuring that they are informed of their responsibilities during the recovery process.
• Communicate any changes to operational priorities to internal teams, particularly those working on work pass issuance, compliance enforcement, and worker welfare.
• Ensure that all employees understand the temporary operational adjustments (e.g., manual processes, adjusted timelines) that have been implemented to ensure continued service delivery.

• Communication with External Stakeholders:

• Notify affected foreign workers, employers, and external agencies about the status of services and provide clear instructions on any interim measures that have been put in place.
  • For example, communicate any delays in work pass processing and guide how employers should proceed with hiring or renewing worker contracts during the disruption.
  • Inform external stakeholders such as the Immigration and Checkpoints Authority (ICA), public health authorities, and labor unions about ongoing recovery efforts and expected timelines for resumption.
• Use pre-established communication channels (e.g., email, SMS, website notifications) to distribute information rapidly to all relevant parties.
• Provide regular status updates every 4-6 hours, especially for critical changes in work pass processing, regulatory compliance, or other important issues.

4. IT System Restoration and Stabilisation

• Initial IT System Recovery:

• Restore critical IT systems and infrastructure that support foreign workforce management. Begin with systems essential for work pass application, renewal, and compliance checks.
  • Reestablish access to databases containing foreign worker records and work pass applications, ensuring that they are fully synchronised with the latest available data.
  • Restore any affected network systems to ensure connectivity between MOM offices and external government agencies, employers, and workers.

• Testing and Validation:

• Once IT systems are restored, conduct quick testing to validate that all key systems are functioning correctly. This includes verifying that all data recovery processes have been successful, ensuring there are no data inconsistencies, and confirming that there is no data corruption.
• Monitor system performance to detect any potential issues early, particularly with IT systems critical to processing work passes and tracking worker compliance.

• Cybersecurity Check:

• If the disruption was caused by a cybersecurity threat, conduct a thorough security audit of IT systems to ensure that no vulnerabilities have been exploited.
• Update firewall protections and security protocols to prevent any further compromise.

5. Immediate Support for Foreign Workers and Employers

• Provision of Temporary Worker Support Services:

• For workers affected by delays in documentation processing (e.g., work pass renewals, compliance verifications), provide temporary support services to ensure their well-being. This can include:
  • Extension of housing and welfare services while their applications are pending.
  • Access to emergency helplines for workers facing urgent issues related to their employment or legal status.
• In cases where worker status is affected, ensure that foreign workers receive clear communication on how to continue working legally while their applications are being processed.

• Employer Communication and Assistance:

• Engage employers directly to provide guidance on the next steps during the resumption phase. Ensure that employers are aware of the temporary measures in place, such as manual application submissions or adjusted processing timelines.
• Provide support for employers in understanding any legal or compliance changes caused by the disruption (e.g., extensions for permits, grace periods).

6. Monitor and Adjust Recovery Progress

• Real-time Monitoring:

• Monitor recovery progress in real-time to ensure that all affected processes are resuming as planned. Establish a tracking system to evaluate which functions are back online and whether there are any bottlenecks or issues that need to be addressed.
• Continue communication with the CMT to ensure smooth coordination between teams working on different parts of the recovery.

• Adjustments and Flexibility:

• If issues are encountered during the resumption process (e.g., delays in restoring certain systems or challenges in worker support), make adjustments to the recovery plan, shifting priorities as necessary.
• Communicate any changes in the recovery timeline to external stakeholders, ensuring that they are updated on the progress and next steps.

The T+24 Hours (Resumption) phase is essential for restoring critical operations and ensuring that CBF-2 Foreign Workforce Management can continue to support foreign workers, employers, and regulatory requirements in the aftermath of a disruption.

The focus during this time is on prioritising core functions, especially work pass issuance and compliance enforcement, activating temporary workarounds, communicating effectively with stakeholders, and restoring IT systems.

These immediate recovery actions lay the groundwork for full recovery and continuity of essential services, providing the Ministry with the ability to stabilise operations and begin transitioning to a longer-term recovery phase.

After T+24 Hours (RECOVERY)

The After T+24 Hours phase focuses on completing the recovery process, ensuring that all CBF-2 Foreign Workforce Management operations are fully restored, and that the Ministry of Manpower (MOM) can return to normal functioning while minimising any lasting impact from the disruption.

This phase is critical for consolidating the resumption efforts from the previous 24 hours, addressing any gaps that remain, and ensuring that the Ministry can fully support the continued well-being of foreign workers, compliance with regulations, and operational efficiency.

The following sections outline the key recovery actions that need to be completed after the first 24 hours:

Full Restoration of IT Systems and Data

• Complete System Restoration:

• Ensure that all IT systems and infrastructure are fully restored and operational across all relevant areas of foreign workforce management. This includes systems for:
  • Work pass applications and processing (Sub CBF-2-2)
  • Compliance monitoring and enforcement (Sub CBF-2-4)
  • Support services and worker welfare (Sub CBF-2-6)
• Restore any offline or backup systems used during the T+24 hours recovery period and ensure all data has been reconciled with live systems.
  
  

• System Testing and Validation:

• Conduct comprehensive testing to ensure all restored systems are functioning at full capacity. This includes:
  • User Acceptance Testing (UAT): Ensure that the systems meet the needs of users, including staff, employers, and foreign workers, and that they perform as expected under normal operating conditions.
  • System Performance and Load Testing: Verify that the systems can handle the volume of data and user requests typical in non-crisis periods.

• Data Integrity Checks:

• Perform data reconciliation to ensure that no data was lost or corrupted during the disruption. Cross-reference backup records with live data to ensure that all transactions, work pass applications, compliance records, and other critical information are accurate and complete.
• Ensure that any data entry done manually during the T+24 hours resumption period has been digitally entered into the main system and is consistent with records.

• Cybersecurity Review and Hardening:

• If the disruption was cyber-related, conduct a full security audit to ensure that all systems are protected from potential vulnerabilities. This includes patching security gaps, updating firewalls, and strengthening access controls.
• Ensure that cybersecurity protocols are updated and fully operational to safeguard the Ministry's data and systems moving forward.

Full Resumption of All Sub-CBFs

• Prioritising the Remaining Sub-Functions:

• Following the resumption of the most critical sub-functions during the T+24 hours period, focus on fully restoring all remaining sub-functions of CBF-2 Foreign Workforce Management that were impacted by the crisis. Key sub-functions include:

• Sub CBF-2-1: Policy & Planning: Ensure that any policy updates or strategic planning activities delayed by the crisis are now completed. This includes reviewing existing regulations and processes to assess if any changes are needed due to the crisis.
• Sub CBF-2-3: Arrival, Onboarding & Deployment: Fully restore systems related to worker arrivals, onboarding, and deployment. Ensure that foreign workers who were unable to begin their work in Singapore due to the crisis are given priority for processing.
• Sub CBF-2-5: Renewal / Transfer / Exit Management: Resume normal processing of work pass renewals, transfers, and exit clearances for foreign workers, ensuring that no delays are causing issues for employers or workers seeking to return home or transfer to a new employer.

• Documenting the Recovery of Operations:

• As each sub-function is restored, document the recovery status for reference and auditing purposes. Record any deviations or challenges faced during the recovery process and outline steps taken to address them.
• Update internal procedures to reflect any changes made during the recovery period, including temporary manual processes or adjustments to timelines.

Compliance and Regulatory Checks

• Regulatory Compliance Review:

• Ensure that all systems and processes for compliance monitoring (Sub CBF-2-4) are fully operational and capable of meeting legal requirements related to foreign workforce management.
• Conduct a thorough compliance audit of foreign worker records to ensure that all work passes, permits, and immigration statuses are up-to-date and that no workers are left in limbo due to the disruption.
• If any compliance gaps are identified during the recovery phase, take immediate action to bring the affected workers into compliance. This may include temporary work pass extensions, expedited processing of late applications, or resolving any discrepancies in worker status.

• Coordination with External Agencies:

• Coordinate with relevant external regulatory bodies (e.g., Immigration and Checkpoints Authority, Ministry of Foreign Affairs) to ensure that all foreign workforce management functions comply with national laws and policies.
• Share updates with external stakeholders regarding recovery timelines and any regulatory adjustments made in response to the crisis (e.g., extended deadlines for compliance checks, special provisions for workers affected by the disruption).

Full Restoration of Support Services for Foreign Workers

Reinstatement of Worker Welfare Services:

• Restore full functionality of the Support Services & Well-being (Sub CBF-2-6) for foreign workers, including:
  • Access to healthcare, financial assistance, and legal support.
  • Re-establishment of emergency support channels for workers facing challenges due to the disruption (e.g., housing, medical care, legal matters).
• Provide psychological and emotional support to workers who may have been affected by the crisis, particularly if the disruption involved physical or emotional hardships (e.g., medical emergencies, isolation, stress).

Communication with Workers:

• Communicate with foreign workers to reassure them that operations are returning to normal and that services are fully restored. Provide clear instructions on how workers can access support services and resume normal working conditions.
• Use multiple channels (e.g., SMS, email, hotline) to ensure that information reaches workers who may be located in different parts of Singapore or facing communication barriers.

Ongoing Monitoring and Fine-Tuning

Monitoring the Stability of Recovery Efforts:

• Continue to monitor the stability of recovered systems and processes after T+24 hours to ensure that no new issues arise. This includes ongoing monitoring of IT systems, worker compliance, and support services.
• Designate a recovery oversight team that is tasked with tracking the progress of all recovery efforts and resolving any outstanding issues or delays.

Adjusting Recovery Timelines as Necessary:

• If certain functions or processes are not fully operational or require additional time for recovery, communicate any revised recovery timelines to both internal and external stakeholders.
• Review lessons learned from the recovery phase and make any necessary adjustments to improve future recovery efforts or business continuity planning.

Post-Crisis Review and Evaluation

• Post-Crisis Debrief:

• Conduct a post-crisis evaluation to assess the effectiveness of the recovery process and identify areas for improvement. This review should involve key stakeholders across the Ministry, including CMT members, IT staff, compliance officers, and external partners.
• Review recovery performance against the Recovery Time Objectives (RTOs) and Recovery Point Objectives (RPOs) to determine if any service level agreements (SLAs) were missed and why.

• Updating Business Continuity Plans:

• Based on the lessons learned during the crisis, update the CBF-2 Foreign Workforce Management Business Continuity Plan (BCP) to address any identified gaps or weaknesses.
• Strengthen risk mitigation strategies, improve recovery protocols, and ensure that lessons from this crisis are embedded into the planning for future disruptions.
• Update training programs, including tabletop exercises and simulations, to incorporate the experiences and challenges faced during the recovery.

The After T+24 Hours (Recovery) phase is focused on completing the recovery of all systems and processes related to CBF-2 Foreign Workforce Management, ensuring that normal operations are restored and that compliance with regulatory requirements is maintained.

This phase includes full restoration of IT systems, the resumption of all sub-functions, verification of compliance, and the provision of ongoing support to foreign workers and employers.

Through continuous monitoring, post-crisis evaluations, and updates to business continuity plans, MOM ensures that it is not only recovering from the current crisis but is better prepared for future disruptions, thereby strengthening the overall resilience of its foreign workforce management system.

The CBF-2 Foreign Workforce Management recovery procedure ensures that disruptions are swiftly addressed and that critical functions are restored with minimal impact on foreign workers, employers, and the economy.

Through proactive planning, immediate recovery actions, and comprehensive long-term recovery efforts, the Ministry of Manpower can maintain resilience in managing its foreign workforce and continue providing essential services to stakeholders in times of crisis.

This plan not only serves as a guideline for operational continuity but also strengthens the Ministry's overall crisis management framework, ensuring the ongoing safety, compliance, and support of foreign workers in Singapore.

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