6 unchanged sentences
(1) identifying vulnerabilities through automated scans, vulnerability assessments, and subscriptions to threat intelligence feeds and notices;
−Removed: (2) assessing security weaknesses identified through internal security reviews, external penetration tests, and reports on our products and services;
+Added: (2) assessing security weaknesses identified through internal security reviews, internal and external penetration tests, and reports on our products and services;
and (3) assessing the Company’s threat landscape given the industry’s risk profile, the results of our enterprise risk assessment, and information technology, privacy, and security audits.
12 unchanged sentences
asset management, tracking and disposal;
−Removed: systems monitoring, vendor risk management program;
+Added: systems monitoring;
+Added: vendor risk management program;
employee training;
22 unchanged sentences
We review our most critical providers' audit reports and certifications on a regular basis to reassess whether or not they have experienced any material changes or degradations to their security programs since our initial review that may warrant re-evaluation.
−Removed: generally attempts to engage reputable third-party service providers and when appropriate, imposes contractual obligations related to cybersecurity on its providers.
+Added: attempts to engage reputable third-party service providers and when appropriate, imposes contractual obligations related to cybersecurity on its providers.
We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.
1 unchanged sentence
For a description of the risks from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors under Part 1.
−Removed: Risk Factors in this Annual Report on Form 10-K , including “If we or our third-party providers fail to protect our IT Systems or Confidential Information, and/or experience a data security incident our business could experience materially adverse consequences, including but not limited to regulatory investigations or actions, litigation, fines and penalties, disruptions of our business operations, loss of revenue or profits, loss of customers or sales, reputational harm, and other adverse consequences.”
+Added: Risk Factors in this Annual Report on Form 10-K , including “If our IT Systems or data, or those of third parties upon which we rely, are compromised, limited, or fail, our business could experience materially adverse consequences, including but not limited to regulatory investigations or actions, litigation, fines and penalties, disruptions of our business operations, loss of revenue or profits, loss of customers or sales, reputational harm, and other adverse consequences.”
Our board of directors addresses the Company’s cybersecurity risk management as part of its general risk oversight function.
−Removed: The board of directors is responsible for overseeing Company’s cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats.
+Added: The board of directors is responsible for overseeing the Company’s cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats.
Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including our CISO , Mr.
4 unchanged sentences
Our CISO is responsible for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports.
−Removed: Our incident response plan is designed to escalate certain cybersecurity incidents, including breaches, to members of management depending on the circumstances, including our CISO, general counsel, and other members of leadership when appropriate.
+Added: Our incident response plan is designed to escalate certain cybersecurity incidents, including breaches, to members of management depending on the circumstances, including our CISO, Chief Legal Officer, and other members of leadership when appropriate.
The security incident and response team works with relevant subject matter experts across the organization when necessary to help the Company mitigate and remediate cybersecurity incidents of which they are notified.
In addition, the Company’s incident response plan includes reporting to the board of directors for cybersecurity incidents the Company's disclosure committee determines are material.
−Removed: The disclosure committee, which includes members of management such as our Chief Financial Officer and general counsel, meets quarterly.
+Added: The disclosure committee, which includes members of management such as our Chief Financial Officer and Chief Legal Officer, meets quarterly.
The CISO acts in an advisory capacity to the Company's disclosure committee on an as-needed basis.
2 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.