4 unchanged sentences
We are committed to protecting our information technology (“IT”) infrastructure, including computers, systems, corporate networks and sensitive data, from unauthorized access or attack.
−Removed: We have established global IT policies as well as IT security management control procedures designed to assess, identify, and manage material risks from cybersecurity threats by:
+Added: We have established global IT policies as well as IT security management control procedures designed to assess, identify, and manage material risks from cybersecurity threats, including but not limited to:
● Creating information security awareness among our employees and business partners and defining responsibilities among them;
29 unchanged sentences
Our CISO has served in that position since 2018.
−Removed: Our CISO has extensive experience serving in executive and senior IT leadership positions over the past 25 years including serving at Cavium in a succession of information security roles, including Vice President of Business Systems, for eleven years, Vice President of IT Applications at ServiceNow for two years, and overseeing worldwide IT Infrastructure, IT Operations and Information Security at Pinnacle Systems for eight years.
+Added: Our CISO has extensive experience serving in executive and senior IT leadership positions over the past 25 years including eleven years at Cavium in a succession of information technology roles, including vice president of business systems, two years at ServiceNow as vice president of IT Applications, and eight years overseeing worldwide IT infrastructure, IT operations and information security at Pinnacle Systems.
We have in place an Incident Response Procedure policy to define our response to unauthorized network intrusions or other significant information security incidents, collectively cybersecurity incidents.
1 unchanged sentence
This policy serves to establish a formal process to report incidents and track response activities.
−Removed: It also defines escalation processes within the Information Security team and to our Cybersecurity Incident Response Team.
+Added: It also defines escalation processes within the Information Security team and further escalation to our Cybersecurity Incident Response Team.
It is the responsibility of the Cybersecurity Incident Response team to determine if an incident is material.
−Removed: The Cybersecurity Incident Response Team consists of members from functional groups across our organization including executive management, IT, Information Security, legal, finance and operations.
+Added: The Cybersecurity Incident Response Team consists of members from functional groups across our organization including executive management, IT, the CISO, legal, finance and operations.
We may include other individuals, including third parties, as appropriate depending on the nature of the incident and system(s) involved.
9 unchanged sentences
At each quarterly board meeting, the full board receives the quarterly cybersecurity board update that is prepared by our CISO.
−Removed: The report provides a comprehensive cybersecurity update for the past quarter, including topics such as details on threat landscape, incident response, security metrics and performance, compliance and regulatory updates, cybersecurity investments and budget, employee security awareness and trainings, vendor risk management updates, business continuity and disaster recovery updates, and an update on cybersecurity strategy, projects and roadmap.
+Added: The report provides a comprehensive cybersecurity update for the past quarter, usually including topics such as details on threat landscape, incident response, security metrics and performance, compliance and regulatory updates, cybersecurity investments and budget, employee security awareness and trainings, vendor risk management updates, business continuity and disaster recovery updates, and an update on cybersecurity strategy, projects and roadmap.
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.