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Booklet:
Operations
Section:
Risk
Mitigation and Control Implementation
Subsection:
Change
Management
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Technology
operations environments are dynamic, and processes, procedures, and controls
should be in place to manage change. Change management broadly encompasses
change control, patch management, and conversions. It also includes the
institution's policies, procedures, and processes for implementing change,
which are discussed more fully in the IT Handbook's “Management
Booklet” and “Development and Acquisition Booklet”.
Large and complex institutions should have a change management policy
that defines what constitutes a "change" and establishes minimum
standards governing the change process. Processes and procedures for implementing
change may be universal for the institution—applicable to all business
lines and environments—or may be stratified, such as changes affecting
the entire institution and those affecting a business line, support area,
or affiliate.
Smaller and less complex institutions may successfully operate with less
formality, but should still have written change management policies and
procedures. Because mainframe, network, client-server, and application
changes are different, institutions may choose to develop individualized
procedures. However, individualized procedures do not instill consistency
in the change management process. Consistency contributes to a change
management process that is defined, managed, repeatable, and optimized.
CHANGE CONTROL
Increasingly, technology systems are tightly integrated and interdependent.
As a result, creating a central change control oversight function is a
sound practice for management of the change process. This may be a specialized
change control or management committee in a large, complex institution,
or a technology steering committee in a small, noncomplex institution.
All changes should flow through the oversight function, which should include
appropriate representation from business lines, support areas, technology
management, information security, and internal audit. In establishing
a framework for managing change, a policy should be present describing
minimum standards and including such factors as notification, oversight,
and control. Control standards should address risk, testing, authorization
and approval, timing of implementation, post-installation validation,
and back-out or recovery.
PATCH MANAGEMENT
Vendors frequently develop and issue patches to solve problems, improve
performance, and enhance security of their software products. Management
should establish procedures to stay abreast of patches, to test them in
a segregated environment, and to install them when appropriate. Change
management procedures should require documentation of any patch installations.
Management should develop a process to ensure version control of operating
and application software to ensure implementation of the latest releases.
Management should also maintain a record of the versions in place and
should regularly monitor the Internet and other resources for bulletins
about product enhancements, security issues, patches or upgrades, or other
problems with the current versions of the software.
CONVERSIONS
Conversions involve major changes to existing systems or applications,
or the introduction of systems or data sets resulting from acquisitions
or mergers. Conversions are a unique and more complex type of systems
change, which may span multiple platforms. Consequently, they have a higher
level of risk requiring additional, specialized controls. Strong conversion
policies, procedures, and controls are critical. Improperly handled, conversions
can result in corrupt data. Moreover, because the ramifications of conversion
span technology operations, it is important for management to re-evaluate
periodically all operations processes and consider the appropriateness
of process re-engineering. Conversions require management to draw on a
number of control disciplines involving change processes and strategic
planning, including project management, change control, testing, contingency
planning, back-up, vendor management, and post-implementation review.
An improperly executed conversion can create inefficiencies including
serious degradation of IT performance, internal and external user dissatisfaction,
accounting problems, customer dissatisfaction, reputation damage, and
critical operational disruptions.
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