6 unchanged sentences
Threats include traditional computer “hackers,” malicious code (such as viruses and worms), phishing attacks, employee theft or misuse and denial-of-service attacks, and use of AI.
−Removed: We have experienced cyberattacks in the past, and although immaterial, there can be no guarantee that in the future such cyberattacks will not be material.
+Added: We have experienced cyberattacks in the past, and although we believe them to have been immaterial, there can be no guarantee that in the future such cyberattacks will not be material.
We believe we are a particularly attractive target because of our prominence and scale, the types and volume of personal data and content on our systems, and the evolving nature of our products and services.
8 unchanged sentences
Successfully achieving these three certifications demonstrates our prioritization of security and privacy for both us and our customers, and we believe shows that we have proper company-wide processes for managing operations, and maintaining people and information assets, information systems, and the associated processes that enable corporate operations.
−Removed: Our three ISO certifications add to the company’s overall resiliency strategy and commitment to security for all customers, which includes other accreditations including SOC 2 Type II, compliance with HITRUST CSF v11.0.1., CSA STAR, IRAP and FedRAMP.
−Removed: 33 Table of Contents Our privacy and security program dictates a governance structure whereby we:
+Added: Our three ISO certifications add to the Company’s overall resiliency strategy and commitment to security for all customers, which includes other accreditations including SOC 2 Type II, compliance with HITRUST CSF v11.0.1., CSA STAR, IRAP, FedRAMP, and ISMAP.
+Added: Our privacy and security program dictates a governance structure whereby we:
Regularly engage senior management on data privacy and security issues;
7 unchanged sentences
Complete several cyber-specific audits per year;
−Removed: and ● Engage consultants and other third parties in connection with our cybersecurity practices.
+Added: Engage consultants and other third parties in connection with our cybersecurity practices.
Our internal audit function provides independent assessment and assurance on the overall operations of our cybersecurity and privacy programs and the supporting control frameworks.
14 unchanged sentences
Our Board oversees risks from cybersecurity threats using a multi-faceted approach that involves the Nominating and Corporate Governance Committee and various executive roles.
−Removed: Additionally, our CISO and Chief Compliance Officer regularly report on cybersecurity matters to the Board, as discussed above.
Nominating and Corporate Governance Committee
11 unchanged sentences
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.