3 unchanged sentences
We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.
−Removed: We design and assess our program based on the National Institute of Standards and Technology Cybersecurity Framework (NIST CSF and AI Risk Management Framework).
−Removed: This does not mean that we meet any particular technical standards, specifications, or requirements, but only that we use the NIST CSF as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business.
+Added: We design and assess our program based on the National Institute of Standards and Technology Cybersecurity Framework (NIST CSF), AI Risk Management Framework (AI RMF) and other industry practices and standards.
+Added: This does not mean that we meet any particular technical standards, specifications, or requirements, but only that we use the NIST CSF, AI RMF, and other industry practices and standards as guides to help us identify, assess, and manage cybersecurity risks relevant to our business.
Information about cybersecurity risks and our risk management processes is collected, analyzed and considered as part of our overall enterprise risk management program.
Key components of our cybersecurity risk management program include:
−Removed: • risk assessments designed to help identify cybersecurity risks to our critical systems, information, services, and our broader enterprise IT environment;
−Removed: • a security team principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents;
−Removed: • the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes;
+Added: • periodic risk assessments designed to help identify cybersecurity risks to our critical systems, information, services, and our broader enterprise IT environment;
+Added: • a security team principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our detection and response to cybersecurity incidents;
+Added: • the use of external service providers, where appropriate, to assess, evaluate, test or otherwise assist with aspects of our security controls and processes;
+Added: • active testing including penetration tests, attack simulations and tabletop exercises;
• cybersecurity awareness training of our employees, incident response personnel and senior management;
12 unchanged sentences
Board members receive presentations on cybersecurity matters from our Chief Information Security Officer (CISO), information security team or external experts as part of the Board’s continuing education on topics that impact public companies.
−Removed: Our management team, led by our CISO and Sr.
−Removed: Director of Information Security, are responsible for assessing and managing our material risks from cybersecurity threats.
−Removed: The team has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and any retained external cybersecurity consultants.
−Removed: Director of Information Security has served in various roles in information technology and information security for over 20 years and holds multiple industry-recognized certifications.
−Removed: Our CISO, who is also our Chief Information Officer, has over 20 years of experience managing global IT operations, including strategy, applications, infrastructure, information security, support and execution.
−Removed: Our management team, led by our CISO and Sr.
−Removed: Director of Information Security, is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity risks and incidents through various means, which may include, among other things, briefings with internal security personnel, threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us, and alerts and reports produced by security tools deployed in our IT environment.
+Added: The CISO reports to the Chief Information Officer (CIO).
+Added: Our CISO has primary responsibility for our overall cybersecurity risk management program, and directly supervises both our internal cybersecurity personnel and any retained external cybersecurity consultants.
+Added: Our CISO has over 19 years of experience in cybersecurity including security operations, security architecture, identity and access management, cloud security, vulnerability management, and application/product security, policy, and compliance.
+Added: Our CISO is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity risks and incidents through various means, which may include, among other things, briefings with internal security personnel, threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us, and alerts and reports produced by security tools deployed in our IT environment.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.