4 unchanged sentences
Our Adviser’s and Administrator’s resource management, information technology (“IT”), and compliance departments work in conjunction with an independent third-party information technology service provider (“ISP”) engaged by our Adviser to manage our information technology strategy.
−Removed: The ISP regularly performs cyber assessments and assist our Adviser and Administrator
−Removed: in monitoring our cyber and information security programs.
+Added: The ISP regularly performs cyber assessments and assist our Adviser and Administrator in monitoring our cyber and information security programs.
The ISP proposes recommendations for improvements to our Adviser’s Head of Resource Management, Director of IT, and Chief Compliance Officer (“CCO”), which then are considered by other relevant officers of our Adviser and Administrator before implementation.
3 unchanged sentences
When risks are detected the Director of IT, Head of Resource Management, and CCO consult with the ISP to assess if the risk is a cybersecurity threat to our information technology systems or data.
−Removed: If a risk to our information systems or data is identified, we, through our Adviser and Administrator, work in conjunction with the ISP to implement recommended processes, improvements, or safeguards to our systems or processes to address the risks as needed.
+Added: If a risk to our information systems or data is identified, we, through our
+Added: Adviser and Administrator, work in conjunction with the ISP to implement recommended processes, improvements, or safeguards to our systems or processes to address the risks as needed.
Relevant examples of such efforts include but are not limited to:
19 unchanged sentences
The reports are distributed to our Board of Directors, and our CCO engages in detailed discussions with the independent board members during the independent members’ session.
−Removed: The reports cover potentially material cybersecurity threats
−Removed: facing us, as well as key risks and mitigation efforts undertaken by us and our Adviser and Administrator.
+Added: The reports cover potentially material cybersecurity threats facing us, as well as key risks and mitigation efforts undertaken by us and our Adviser and Administrator.
As significant threats or events are identified by management or the ISP between regular reporting periods, our CCO will inform our Board of Directors immediately and keep it informed as to the developments of assessing the risks, mitigating efforts, and potential disclosure.
4 unchanged sentences
This includes identifying, assessing, mitigating, and monitoring cyber information security risks.
−Removed: Our Director of IT has over 20 years of experience in IT, with a focus in the implementation of information security projects to enhance organizations’ resilience against emerging threats, and has collaborated closely with security vendors/partners to contain and address cybersecurity incidents.
+Added: Our Director of IT has over 20 years of experience in IT, with a focus in the implementation of information
+Added: security projects to enhance organizations’ resilience against emerging threats, and has collaborated closely with security vendors/partners to contain and address cybersecurity incidents.
These managers, as well as other management personnel, attend various professional continuing education programs, which include cybersecurity matters.
8 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.