5 unchanged sentences
Our information security team, supported by our legal and compliance departments, help identify, assess and manage our cybersecurity threats and risks.
−Removed: Our information security team identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods, depending on the context, including, for example manual and automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing certain reports of threats and threat actors, conducting scans of certain environments, evaluating our and our industry’s risk profile, evaluating certain threats reported to us, conducting third-party threat assessments, coordinating with law enforcement about certain threats, conducting internal audits and threat assessments, and conducting vulnerability assessments.
+Added: Our information security team identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods, depending on the context, including, for example manual and automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing certain reports of threats and threat actors, conducting scans of certain environments, evaluating our and our industry’s risk profile, evaluating certain threats reported to us, conducting third-party threat assessments, coordinating with law
+Added: enforcement about certain threats, conducting internal audits and threat assessments, and conducting vulnerability assessments.
Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example, incident detection and response procedures and policies;
16 unchanged sentences
The program includes conducting risk assessments of certain vendors, reviewing certain vendors’ security assessments, reviewing reports of certain of our vendors’ security, and reviewing the written information security program of certain vendors.
−Removed: Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, our vendor
−Removed: management process may involve different levels of assessment designed to help identify cybersecurity risks associated with a provider and impose contractual obligations related to cybersecurity on the provider.
−Removed: For a description of the risks from cybersecurity threats that may materially affect us and how they may do so, see our risk factors under Part I.
−Removed: Risk Factors in this Annual Report on Form 10-K, including “ Our business is subject to complex, stringent and evolving U.S.
+Added: Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, our vendor management process may involve different levels of assessment designed to help identify cybersecurity risks associated with a provider and impose contractual obligations related to cybersecurity on the provider.
+Added: For a description of the risks from cybersecurity threats that may materially affect us and how they may do so, see our risk factors under Part I., Item 1A, “Risk Factors” in this Annual Report on Form 10-K, including “ Our business is subject to complex, stringent and evolving U.S.
and foreign laws, regulations, and rules, contractual obligations, industry standards, policies and other obligations relating to privacy and data protection.
3 unchanged sentences
The board of directors’ audit committee is responsible for overseeing our cybersecurity risk management processes, including oversight of mitigation of risks from cybersecurity threats.
−Removed: Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including our Senior Director of Information Technology/Information Security, Vice President, Legal, Chief Compliance Officer (“CCO”), and Chief Financial Officer (“CFO”) .
−Removed: Our Executive Director of Information Technology/Information Security has over ten years of experience in information technology and security, and previously held positions such as Associate Director of Informational Technology and Operations, Senior Manager of Informational Technology, and similar roles at other companies.
−Removed: Our Executive Director of Information Technology/Information Security is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s overall risk management strategy, helping prepare for cybersecurity incidents, approving cybersecurity processes, reviewing security assessments and other security-related reports, and communicating key priorities to relevant personnel.
−Removed: Our CFO is responsible for approving budgets as related to cybersecurity.
−Removed: Our incident response and vulnerability management processes are designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including the Executive Director of Information Technology/Information Security, Data Protection Officer, and the Vice President, Legal.
+Added: Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including our Vice President of Information Technology and Vice President, Legal .
+Added: Our Vice President of Information Technology has over fifteen years of experience in information technology and security, and previously held positions such as Vice President, Business Information Technology Strategy and Application Management, Vice President, Head of Information Technology, Executive Director, Information Technology, and similar roles at other companies.
+Added: Our Vice President of Information Technology is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s overall risk management strategy, helping prepare for cybersecurity incidents, approving cybersecurity processes, reviewing security assessments and other security-related reports, and communicating key priorities to relevant personnel.
+Added: Our CLO is responsible for legal and compliance risk, including related to cybersecurity.
+Added: Our incident response and vulnerability management processes are designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including the Vice President of Information Technology, Data Protection Officer, and the Vice President, Legal.
These individuals work with our incident response team to help us mitigate and remediate cybersecurity incidents of which they are notified.
In addition, our incident response processes include reporting to the audit committee of the board of directors for certain cybersecurity incidents.
−Removed: The audit committee of the board of directors receives annual reports from our Senior Director of Information Technology/Information Security concerning our significant cybersecurity threats and risk and the processes we have implemented to address them.
+Added: The audit committee of the board of directors receives annual reports from our Vice President of Information Technology concerning our significant cybersecurity threats and risk and the processes we have implemented to address them.
The audit committee of the board of directors also receives and has access to various presentations related to cybersecurity threats, risk and mitigation.
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.