Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
None.
Item 1C. Cybersecurity.
Cybersecurity Risk Management and Strategy
We have developed and implemented a cybersecurity risk management program designed to protect the confidentiality, integrity, and availability of our critical systems and information. Our program is designed to align with relevant legal requirements and draws upon widely accepted security frameworks and practices. We take an integrated , organization-wide approach to evaluating and addressing cybersecurity risks, incorporating these considerations alongside other enterprise risks such as regulatory, financial, and operational concerns.
Key elements of our program include, but are not limited to, the following:
• processes designed to identify, assess, and prioritize cybersecurity threats to our critical systems and information;
• technical controls and processes intended to detect and remediate weaknesses in our systems and software;
• the use of third-party service providers , where appropriate, to assist with aspects of our program;
• evaluation of key service providers based on our assessment of their criticality to our operations and respective risk profile, for example, through due diligence, contractual protections, and periodic review;
• practices designed to safeguard personal information and maintain compliance with data protection requirements;
• ongoing monitoring capabilities to detect and evaluate potential security threats; and
• a cybersecurity incident response plan that includes documented procedures for responding to, containing, and recovering from cybersecurity events.
We have experienced a number of cybersecurity incidents in the past, which we do not believe to be material, regularly experience cybersecurity attempts, and expect that we will continue to experience varying degrees of cybersecurity attempts and incidents in the future. To date, we have not identified any risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition. However, there can be no assurance that our cybersecurity risk management program and processes, including our policies, controls, or procedures, will be fully implemented, complied with or effective in protecting our systems and information. See “ Item 1A. Risk Factors ” for additional discussion regarding the risks we face from cybersecurity threats.
Cybersecurity Governance
Our Board considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit and Risk Committee (the “Committee”) oversight of cybersecurity and other information technology risks. The Committee oversees management’s implementation of our cybersecurity risk management program.
The Committee receives updates at least annually from our Vice President of Engineering or his designees and management on our cybersecurity risk management and strategy, including, as applicable, progress towards our risk-mitigation goals, results from third-party assessments, and the emerging threat landscape. In addition, management updates the Committee, where it deems appropriate, regarding cybersecurity incidents it considers significant.
The Committee reports to the full Board regarding its activities, including those related to cybersecurity and, will, from time to time, brief the full Board on our cybersecurity risk management program. From time to time, our Committee members receive presentations on cybersecurity topics from our internal or external experts as part of its continuing education on topics that impact public companies.
Our Vice President of Engineering, in coordination with our internal security staff, is responsible for assessing and managing our material risks from cybersecurity threats, and has primary responsibility for our overall cybersecurity risk management program and supervising both our internal cybersecurity personnel and our retained external cybersecurity consultants.
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OPENDOOR TECHNOLOGIES INC.
Our Vice President of Engineering, who possesses a 13-year track record in product development and engineering, six years of which consist of overseeing technology, including the oversight of information security systems, reports directly to our Chief Executive Officer. This extensive experience spans both public and private companies.
Our Vice President of Engineering takes steps to stay informed about and monitor efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel, threat intelligence and other information obtained from governmental, public or private sources, and alerts and reports produced by security tools deployed in the IT environment, such as regular network and endpoint monitoring, vulnerability assessments, penetration testing, and tabletop exercises.