11 unchanged sentences
We decided to retain a third party for these services given the small size of our Company and internal information technology staff and the quality, comprehensiveness, and cost-effectiveness of the services offered.
−Removed: An internal team, led by our Chief Operating Officer, oversees and works collaboratively with this third party vendor to evaluate the strength of our cybersecurity protocols and the results of testing to determine what additional actions, such as trainings or remedial actions, are necessary to lessen cybersecurity risks.
+Added: An internal team, led by our Vice President of Information Technology, oversees and works collaboratively with this third party vendor to evaluate the strength of our cybersecurity protocols and the results of testing to determine what additional actions, such as trainings or remedial actions, are necessary to lessen cybersecurity risks.
We intend to continue to make investments to monitor and maintain the security of our data and cybersecurity infrastructure.
8 unchanged sentences
Risk assessment and oversight are an integral part of our governance and management processes.
−Removed: Our Board of Directors (the "Board") has ultimate oversight of the Company's risk management.
+Added: The Board has ultimate oversight of the Company's risk management.
In accordance with its charter, the Audit Committee of the Board is responsible for overseeing our enterprise risk management program on behalf of the Board, including material risks related to cybersecurity threats, and reporting on these matters to the Board.
2 unchanged sentences
Significant findings related to cybersecurity, data and technology risks or incidents are regularly reported to and discussed at the Board level.
−Removed: Three members of our Board, included two of our Audit Committee members, are currently pursuing or have received certifications in cyber-risk oversight through the National Association of Corporate Directors.
+Added: Three members of our Board, two of which are Audit Committee members, have received certifications in cyber-risk oversight through the National Association of Corporate Directors.
Management, in coordination with our information technology department, is responsible for assessing the risk of cybersecurity threats and hiring appropriate personnel and third-party consultants to oversee the cybersecurity program.
−Removed: Specifically, these processes are overseen by our multidisciplinary Technology Risk and Information Security Committee, which consists of leaders from our Information Technology, Operations, Internal Audit and Legal teams.
+Added: Specifically, these processes are overseen by our multidisciplinary Technology Risk and Information Security Committee , which consists of leaders from our Information Technology, Operations, Finance, Internal Audit and Legal teams.
Such individuals have an average of over 15 years of prior work experience in various roles across multiple industries involving information technology, risk management, operations and legal matters.
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.