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The Board, led by the Executive Chairman Alan McKim, who is also the Chief Technology Officer of the Company, has primary oversight responsibilities for cybersecurity risks and therefore has established oversight mechanisms to ensure effective governance in managing risks associated with cybersecurity threats.
−Removed: During 2023, the Board of Directors established a special subcommittee with the goal of reviewing the Company's overall cybersecurity risk and response landscape.
+Added: We have a special subcommittee of the Board of Directors with the goal of reviewing the Company’s overall cybersecurity risk and response landscape.
The special Cybersecurity subcommittee is comprised of board members with diverse expertise including risk management, technology and finance, with two members holding Cybersecurity Oversight Certificates issued by the National Association of Corporate Directors and Carnegie Mellon University.
−Removed: The Chief Information Security Officer ("CISO") and Chief Information Officer ("CIO") provide comprehensive briefings throughout the year to both the Cybersecurity subcommittee, which meets quarterly, and to the Board of Directors as well.
+Added: The Chief Information Security Officer (“CISO”) and Chief Information Officer (“CIO”) provide comprehensive briefings throughout the year to the Cybersecurity subcommittee, which meets quarterly.
+Added: The chair of the Cybersecurity subcommittee provides updates on the subcommittee’s activities to the Board of Directors and, from time to time as warranted, the CISO and CIO will present to the full Board of Directors as well.
The briefings include the current landscape of cybersecurity risks and emerging threats, relevant Company infrastructure and tools employed to address these risk and threats, status of ongoing initiatives, incident reports and learnings and compliance with regulatory requirements and industry standards.
Management's Oversight and Responsibilities
−Removed: Reporting to the CIO, Cybersecurity at Clean Harbors is managed by the Chief Information Security Officer who is a Certified Informational Systems Security Professional.
+Added: Reporting to the CIO, the CISO manages Cybersecurity at Clean Harbors and is a Certified Informational Systems Security Professional.
The CISO leads the Clean Harbors’ cybersecurity response program based on the National Institute of Standards and Technology (“NIST”) Cybersecurity Framework providing a collaborative, balanced risk based approach to securing and defending the Company.
−Removed: The CISO leverages both open source and private threat intelligence sources to remain current about the latest developments in cybersecurity, including potential threats and innovative risk management techniques.
−Removed: The CISO implements and oversees processes and technologies for regular monitoring of our information systems.
+Added: The CISO leverages open source and private threat intelligence sources to remain current about the latest developments in cybersecurity, including potential threats and risk management techniques.
+Added: The CISO implements and
+Added: oversees processes and technologies for regular monitoring of our information systems.
Third party cybersecurity advisory services are employed to consult on, monitor, respond and/or assess our IT landscape and cybersecurity response.
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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.