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Table of Contents
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II. BUSINESS CONTINUITY PLANNING METHODOLOGY
II.1 BUSINESS CONTINUITY STRATEGY
II.2 BCP ROLES AND RESPONSIBILITIES
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II.3 BUSINESS CONTINUITY PLAN SUB-PLANS
II.4 BUSINESS CONTINUITY PLAN PHASES
II.4 BUSINESS CONTINUITY PLAN STRUCTURE
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II.4.1 THE ISO 22301 STANDARD: 2012
II.4.2 CONTENTS OF A BUSINESS CONTINUITY PLAN
II.4.3 BUSINESS CONTINUITY PLAN MANAGEMENT
II.4.4 BUSINESS CONTINUITY BEST PRACTICES
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III. CASE STUDY: BUSINESS CONTINUITY PLAN FOR A SMALL ORGANIZATION
III.1 PLANNING THE ORGANIZATIONAL STRATEGY
III.2 BUSINESS IMPACT ANALYSIS
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III.4 DEVELOPMENT AND IMPLEMENTATION
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In today’s ever advancing world of technology, cyber attacks on organizations critical assets can cause serious losses and damages. Nowadays it is common to hear about businesses closing down after major attacks because they were unable to stand back on their feet after such cyber incidents or disasters. Unexpected or unplanned downtime and loss of important data can originate from a number of sources including power failures, natural disasters, human errors, malicious acts, etc. Business continuity entails the planning and preparation for such unexpected adverse situations in order to avoid the disruption of the activities of an organisation and maintain availability of its services. In the past, people thought of business continuity as simply being about getting computers, information and network back online. A good example in the financial sector is Banks who in the past outsourced their technology to service bureaus so as not to worry about disaster recovery or business continuity process. Today, business continuity not only includes protection of data but also the facilities and the people and even ensuring that the service bureaus have a rigorous business continuity plan in place. At the end of the day, organisations don’t want to lose their clients or go out of business so they must ensure that everything is well planned for the unexpected.
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In every organization, the business continuity planning team must work closely with the information security team to produce an efficient recovery plan. Together, they must ensure that all or the same physical and information security mechanisms deployed at the primary site or main facility (e.g. Firewalls, antivirus, data encryption, etc) are implemented at an alternate location. In practice, it does not make sense to protect every single asset; therefore companies should be able to prioritize their business units. Once the different business units have been prioritized, a business impact analysis (BIA) should be developed. Every employee in an organization must be part of the business continuity plan but most especially the executives and the board of directors. Business continuity does not generate revenue but rather it is an expense, hence the need for the directors and executives to be actively involved in the entire process. In addition to a steering committee to help prioritize the business activities, companies can equally have a crisis management team who will be in charge of making recommendations on decision making during an incident or a disaster. Another important consideration should be a definition of governance which is the set of programs, policies and the responsibilities of each individual within the organization during the business continuity process.
Keywords: Business continuity planning phases, Business continuity plan sub-plans, Business impact analysis, Disaster recovery, Alternate sites, NIST 800-34, ISO27031, ISO22301
Business continuity is about identifying parts of business services and activities that an organisation will not want to lose when a disaster occurs such as information assets, employees and business premises. The need for a business continuity plan which will elaborate on how to maintain these assets in the event of an incident is crucial. Most organizations without effective plans for recovery or continuity in place go out of business after a disaster. Any incident, large or small, whether it is natural, accidental or deliberate, can cause major disruption to services but if the necessary plans are made before hand, the organization will be able to stand back on their feet within the shortest possible time. The business continuity planning is a continuous process which can be summarized in figure 1 below.
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Figure 1: Business Continuity Cycle
An effective business continuity plan should be able to answer the following questions:
The next sections of this document will focus on describing business continuity planning strategies and processes and also elaborate on how to develop, write and execute an effective business continuity plan.
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This research is based on secondary data reassembled from previous research, online journals, text books, BCP consultant websites, annual reports of institutes like NIST and ISO who are developing the standards and frameworks for business continuity.
Organizations should know whether they need to be fully or partially operational to survive after a major incident/disaster. A major incident or disaster can cause:
Consequences of these scenarios [1] include loss of stock / production capability / workspace, inability to service customers, bankruptcy, redundancies etc. The quicker operations recover, the better the chance of survival of the organization. Depending on the nature of services provided, some organizations might decide to shutdown their business activities till after the resolution of the incident while others can afford to run the business through the incident. The BCP should provide all the information required to ensure proper management of the immediate incident, recovery and continuity of the critical activities identified in the risk assessment process. Separate incident response plan, business recovery and continuity plans could be implemented for a large organization. For a small organization a single plan which incorporates all three plans may be sufficient.
Key strategies involved in the business continuity planning process include:
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Assuming the incident/disaster causes a loss of primary workspace either short term or long term, how then does the business keep functioning until the new office is ready?
The old premises might require minimal planning and arrangements for activities to continue.
The organisation might procure alternate premises within a time constraint
After the BCP has been developed, it will be vital to update and test the plan with all the staff so that each employee is fully aware of their role and responsibilities. BCP testing can be carried out by:
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According to ISO 22301, business continuity plan [2] is defined as “documented procedures that guide organizations to respond, recover, resume, and restore to a pre-defined level of operation following disruption.” (clause 3.5).1It involves the identification, acquisition, documentation and testing of procedures and resources to guarantee the continuity of the activities of an organisation in the event of an incident or disaster. In other words it is involved with risk mitigation and business recovery planning. Such a plan must include authorities to invoke, instructions and communications strategy to assure continuity of operations. Inside an organization, BCP roles and the responsibility fall onto different categories of people, from the senior management to the BCP steering team.
Senior Executive Management
Senior Functional Management
BCP Team
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The BCP serve to protect, recover and sustain the organization [3].
This sub plan consists of the crisis communications and the incident management plans. On one hand, the crisis communications plan focuses on addressing notifications/communications with personnel and the public. On the other hand, the incident management plan provides procedures for minimizing loss of life and property in response to a physical threat; it does not focus on the business or IT process but rather on the personnel and property particular to an affected facility.
The recover sub plan consists of:
This also called the continuity of Operations Plan (COOP). It provides procedures to facilitate recovery at an alternate site. There are different kinds of alternate sites [4]:
A strong business continuity plan needs to address responsibility, authority, priorities and testing. NIST’s “special publication 800-34, Rev. 1: Contingency planning guide for federal information systems” and ISO 27031 among others provide guidelines for planning of incidents and disasters that require a BCP .There are several phases in the BCP:
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When conducting a BIA, the following metrics need to be defined:
The management should establish recovery priorities for business processes that identify succession plans, MOAs/MOUs (Memorandums of Agreement/Understanding), Technologies, Facilities, communication systems, etc.
ISO 22301 aims at assisting organizations [5] to be prepared and more confident to handle outages or interruptions in their services and continue their operations. It presents a scheme to help organisations protect against, respond to, and recover from incidents. ISO 22301 also aims at assisting organizations in the design of a business continuity management system that responds to its needs. Several countries including the United Kingdom have started replacing their existing national standards with the ISO 22301.
According to Dr. Stefan Tangen, Secretary of the ISO technical committee that developed the new standard, enforcing the ISO 22301 standard not only enables organizations to prove to customers, lawmakers, regulators, etc that they are observing good practices in their business continuity planning but It may also be used within an organization to measure itself against good practice, and by auditors wishing to report to management.
A Business Continuity plan is developed to ensure that business operations return to normal as fast as possible in the event of a major disruption. A major incident can bring business to a standstill hence the need of a business continuity plan. A plan should identify all the essentials for keeping the business running and include processes to assure minimum down time and effectively manage a crisis. The business continuity plan should contain information required for an organization to keep functioning after an incident or a disaster. The size and complexity of such a plan varies from one organization to the other. Below is a sample business continuity checklist [6]:
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Table 1: Sample Business Continuity Plan Checklist
As a summary, a BCP should include the following sections:
The introduction section of a BCP carries information about the users and version (date of last update), location of the plan, its objectives, a summary and definition of terms found in the plan [7].
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This includes references to the Business Continuity Policy, BIA, BCS, etc.
This section outlines the tasks assigned to each individual involved in the BC process. For instance staffs in charge of purchases, communication, evacuation, etc. It should clearly state the team members who will be called to manage the incident, monitor the maintenance of critical activities and follow up post incident recovery progress. This section should include a step-by-step checklist for the actions to be taken and priority levels should be assigned to each action.
This contains the phone numbers and addresses of those involved in the activation and realization of the BCP (internal staff, subcontractors and service providers, emergency services, etc). The various means of communication and timings during the incident and those in charge of propagating information to the right people or places should be clearly mentioned.
The BIA contains the resources [8] needed to support each critical business activity, the impact of ceasing to perform these activities, how long the business could cope without these activities. The risk management plan identifies the key activities, the risks associated with these activities and their mitigation techniques. It outlines the potential risks for the business, analyses the likelihood of occurrence of these risks, prioritizes the risks, estimates the impact of the risk and identifies mitigation strategies.
IRP and DRP are and generally included as an annex to the BCP. Each response plan should list all the business activities, with precise RTO for each, when the plans should be activated or deactivated, the method of activation, details of which staff are authorised to activate the plan, etc.
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This section indicates the primary and alternative sites, where the assembly points are, routes and the means of transportation to alternative sites.
This is a list of staff, service providers, facilities, infrastructure, information, equipment, etc. required for the recovery procedure and who is responsible to provisioning of each.
This section includes details about how you will test the BCP so as to ensure the accuracy and effectiveness of the plan. It includes schedules for performing regular tests and updates. Changes in hardware/software, laws, and environment warrant regular review and maintenance of the plan. The dates and frequency at which the plan is tested, findings from previous tests and exercises, etc could also be included. Tests could be performed through exercises, drills or auditing.
This section focuses on how to restore the business back to its original state or site after resolution of the incident.
The business continuity plan is a document that needs to be regularly tested and updated with improvements. This will help in the evaluation of its reliability and robustness in response to an incident. Updates to be BCP are made whenever there are changes in the activities or location of the business. The following strategies could be implemented for testing the BCP:
The business continuity planning process incorporates the prevention, preparedness, response and recovery framework as shown in the diagram below [9]:
Figure 2: Business Continuity Planning Process (PPRR)
Thinking ahead enables organizations to prepare for the worst and put some arrangements in place to speed up their response to an incident. They might even be able to avert the disaster in the first place by identifying the need for some additional resilience. Business Continuity is all about considering what action would achieve minimum disruption to an organization in a given scenario, and then making sure that those actions are possible. To do that, we consider people, infrastructure and plans. The following considerations should be made for a BCP:
This case study will illustrate in details the steps involved in the creation of a BCP for an imaginary company “Horizon Health”. The company Horizon Health focuses on securing in databases electronic health information of individuals and ensuring data is confidential, unaltered and available to the right individual. The company is located in central London and has 50 staffs. Ninety percent of the employees live within London while the rest live within the UK. The company has five departments. Its customers include patients, government agencies, educational establishments, medical practitioners and insurance companies. This guide can be useful to small companies who need to implement or improve their BCPs. [10]
The business continuity planning process will go through five stages:
It is at this stage that the BCP project is initialized, meetings with senior management are held, BCP team members are designated and project scheduling is done.
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Figure 3: Gantt chart for BCP creation schedule
The next task involves the BIA. This will be done in the form of a questionnaire and the following information will be gathered:
The BIA serves as a guide for the construction of the BCP and is tailored depending on the organization’s activities. The following were obtained from Horizon Health staff, customers and stakeholders:
Horizon Health Response: Good business practices and health laws are drivers for the assessment. We want to be prepared for the unexpected and gain our customers trust in our services.
Horizon Health Response: We provide an electronic platform for the collection and storage of confidential health information of individuals and care facilities.
Horizon Health Response: Secure transfer of patient information on their request and processing of payments. For this we use the Internet, VPN and data encryption technologies.
Horizon Health Response: HIPPA- it governs activities related to the access of private health information.
Horizon Health Response: Yes, in the past one our database servers were hacked. This caused some of our patient’s health data were leaked to the public. We had several court cases and settlements to deal with.
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Horizon Health Response: Similar incidents like the one mentioned above could recur.
Not only are we going to incur financial losses but also the reputation of the company will be ruined. We are concerned about the confidentiality and integrity of patient data.
Horizon Health Response: We have fifty employees divided into six departments; the executives, the London data group, the global data group, the information technology IT and Information security departments.
Horizon Health Response: They are responsible for network operations and configurations server /equipment maintenance and backup of data. The IS personnel also perform internal audits.
Horizon Health Response: We have 2 servers in our main office building, 55 desktops installed with Avast antivirus, 2 printers, one photocopier and one scanner. All software installed in equipments within our network is regularly updated and patches are sometimes installed.
Horizon Health Response: We have 5 employees who access our servers and databases from out of the office via Cisco Secure VPN.
Horizon Health Response: We have disaster recovery, Access control, Usage, Facility security and information access policies. These policies are accessible to all employees and any updates to the policies are communicated. Updates are performed by the executives and the internal audit teams. New employees also go through an induction program where they are briefed about the security policies of the organization.
Horizon Health Response: We have firewalls, Intrusion detection systems, but no cloud-based data center. Thanks to the firewall and IDS systems we monitor and review logs in the network.
Horizon Health Response: Our critical activities involve secure and confidential retrieval and distribution of patient data to patients, hospitals and insurance companies. The IT team is responsible for managing the database. In the event of a disaster, our backup processes will need to be activated and depending on the circumstances we might have to take legal actions against security breaches. Acceptable downtime is one hour.
Horizon Health Response: The employee’s company email account is deactivated and all company equipment e.g. phone, PC, etc is retrieved. His access to the company’s premises and data center is also restricted.
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Horizon Health Response: Real time mirroring of patient data into a remote server is done such that in the event of a disaster, the administrators can readily regain access to information.
Horizon Health Response: Once an incident is detected, we follow a documented set of procedures to alert the security department and manage the incident.
Horizon Health Response: We have surveillance cameras within and around the company’s premises. Employees are not allowed to copy information out from the company’s devices.
The tables below illustrate the results from the business impact and risk assessment data for Horizon Health:
Table 2: Business Impact for Horizon Health
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Assets | Loss of Integrity | Loss of Confidentiality | Loss of Availability | |
1 | Patient Information | High | High | Medium |
2 | Internal Documents | Medium | Medium | Low |
3 | HR Records | High | High | Medium |
4 | Advertising Literature | Low | Medium | Low |
Table 3: Risk Assessment for Horizon Health
Threats/Event Examples | Severity of Loss | Duration of Impact | Probability of an Incident | |
1 | Hardcopy/Electronic fraud or extortion | low | Extended | Rare |
2 | IT personnel do not have complete understanding of HIPPA regulations | High | Isolated | Rare |
3 | Backups unreliable and other mission critical systems | High | Isolated | Likely |
4 | Hacker or Dos attacks | High/medium | Isolated | Rare |
5 | Malware and spam, possession of unlicensed software | Medium | Extended | Likely |
6 | Technology obsolescence databases | Medium | Extended | Rare |
7 | Disruptive or destructive malware (Trojan horse, worm or virus) | High/medium | Isolated | Common |
8 | Civil lawsuit, retaliation or vengeance brought by employee for discrimination or harassment | High | Isolated | Rare |
The selection and implementation of the appropriate countermeasures to ensure the confidentiality, integrity and availability of information systems is very essential. In the case of Horizon Health, the following controls could be implemented:
– Employees should be schooled on lawsuits that can follow if patient information is leaked or compromised
– Hardcopies of patient information to be disposed should be done in a careful and discrete manner. Eg. Shredding.H
– Cloud based backup services should be implemented
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– The company should consider outsourcing to server service providers
– Operating systems and software should be regularly patched.
The BCP team leader (the information security manager) will be responsible for the activation upon receiving information from the emergency management team EMT about a major incident or disaster. He is responsible for contacting all other BCP team members in the event of a disaster that requires execution of the business continuity plan. Considering the size of Horizon Health, the EMT will be part of the BCP team.
Depending on the severity of the incident, the BCP team leader will decide if activities need to be moved to an alternate site. For this, there exists a hot-site located 20 miles outside London. While core departments’ employees can work directly on this site, all other employees will be required to work from home via VPN. There is a backup server at this hot site, so company operations should be able to run smoothly from there.
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Quarterly tests and exercises will be performed by the IT and IS departments to test for effectiveness of the plan. Any future changes to the Horizon Health personnel, vendors, mission statement or functions shall be reflected in the plan.
A BCP is designed to avoid or mitigate risks and the impact of an incident/disaster. There is no standard plan for business continuity; every organization needs to develop a suitable BCP based on a number of factors ranging from its size, budget, technology, and activities. Senior level organizational support for BCP is quite essential as without their approval, the BCP cannot be successfully created and implemented. Other elements to consider include funding, time constraints and staffs as all three elements contribute to the success of the BCP project.
A well-structured BCP will give the organizations clients and stakeholders more confidence in the business practices. When business is impacted by an incident/disaster, it usually costs money and time to get things back to normal, and although Insurance cover helps, claims might take a long time. When everyone is impacted, you have a little more time but eventually customers will have to go to other competitors. Disaster Recovery Plans focus primarily on IT whereas BCPs envelope the entire business process recovery. Typically, BCP/DRPs contain 5 steps, which include a variety of sub-sets from emergency response to crisis management, with a scope that extends from a technology perspective to a people perspective.
A properly written and comprehensive plan can save an organization in times of, while a poorly written plan will only cause the company extra losses and costs. Regular data restoration tests, back-up of data, antivirus/antimalware updates on workstations and servers should be performed Organizations should involve business continuity professionals and managed services providers in their cyber security business continuity plan.
[1] Peter Carr, Editor, “ Business Continuity for Facilities Managers”, pp 4-8. Fast Track Solutions Ltd
[2] Dejan Kosutic. 2018. Business continuity plan: How to structure it according to ISO 22301. [ONLINE] Available at: https://advisera.com/27001academy/knowledgebase/business-continuity-plan-how-to-structure-it-according-to-iso-22301/. [Accessed 27 February 2018].
[3] Kelly Handerhan. 2012. Business Continuity & Disaster Recovery Planning. [ONLINE] Available at: https://www.cybrary.it/skill-certification-course/business-continuity-disaster-recovery-planning-certification-training-course. [Accessed 15 March 2018].
[4] Michael E. Whitman, Herbert J. Mattord. 2013. “Management of Information Security”, 4th ed, pp 138-147.
[5] Liz Gasiorowski-Denis. 2012. ISO publishes new standard for business continuity management. [ONLINE] Available at: https://www.iso.org/news/2012/06/Ref1587.html. [Accessed 6 March 2018].
[6] Chris Owens/Annette Mercer. 2014.
The Business Continuity Plan. [ONLINE] Available at: http://psnc.org.uk/halton-st-helens-and-knowsley-lpc/wp content/uploads/sites/45/2013/12/BCP-LPC-18-6-14.pptx. [Accessed 19 March 2018].
[7] Queensland Government. 2017. What’s in a business continuity plan?. [ONLINE] Available at: https://www.business.qld.gov.au/running-business/protecting-business/risk-management/continuity-planning/plan. [Accessed 22 March 2018].
[8] M. H. Goh, Editor, “Implementing Your Business Continuity Plan”, (2nd ed., p. 104). GMH Pte Ltd,
Singapore, (2010)
[9] Queensland Government. 2009. Business Continuity Planning. [ONLINE] Available at: http://www.mackay.qld.gov.au/__data/assets/pdf_file/0018/151434/Business_Continuity_Planning_Guide.pdf. [Accessed 31 March 2018].
[10] Veo Taylor. 2009. CASE STUDY: Small Organization Business Continuity Plan Creation. [ONLINE] Available at: http://cs.lewisu.edu/mathcs/msis/projects/msis595_VeoTaylor.pdf. [Retrieved 05 April 2018].
https://en.wikipedia.org/wiki/Business_continuity#BC/BCM_plan_(BCP)
Figure 5: Sample BCP Template
BCP | Business Continuity Planning |
BIA | Business Impact Analysis |
COOP | Continuity Of Operations Plan |
DRP | Disaster Recovery Plan |
EMT | Emergency Management Team |
HIPAA | Health Insurance Portability and Accountability Act |
IS | Information Security |
ISO | International Organization for Standardization |
IT | Information Technology |
MOA | Memorandum of Agreement |
MOU | Memorandum of Understanding |
NIST | National Institute of Standards and Technology |
VPN | Virtual Private Network |
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