5 unchanged sentences
We also maintain a comprehensive process for identifying, assessing, and managing material risks from cybersecurity threats.
−Removed: We also have a process in place to oversee and vet our third party resources, including, for critical vendors and as appropriate, through reviews of Service Organization Control Type 2 reports.
+Added: We also have a process in place to oversee and assess our third party resources, including, for critical vendors and as appropriate, through reviews of Service Organization Control Type 2 reports.
We maintain an ongoing end-user cybersecurity awareness program that is designed to raise awareness of cybersecurity threats to reduce our vulnerability as well as to encourage consideration of cybersecurity risks across functions, including quarterly training and simulated phishing campaigns.
2 unchanged sentences
Oversight and Governance
−Removed: Members of our senior management, including our Chief Executive Officer, Chief Financial Officer, and leaders from our legal and information technology functions , maintain responsibility for assessing and managing cybersecurity threats.
+Added: Members of our senior management, including our Chief Executive Officer and leaders from our legal and information technology functions , maintain responsibility for assessing and managing cybersecurity threats.
This team has deep expertise in building and leading information systems and cybersecurity teams across a variety of institutions.
Our head of information technology has approximately 20 years of information security experience.
−Removed: Cybersecurity risk governance has been delegated by our Board of Directors to the Audit Committee of the Board of Directors, or the Audit Committee.
−Removed: As provided in the Audit Committee Charter, the Audit Committee is responsible for reviewing, assessing, and considering, in consultation with management and the Board, as appropriate, the overall risk management policies and procedures of the Company, including our major risk exposures such as cybersecurity.
+Added: Cybersecurity risk governance has been delegated by our board of directors to the a udit committee of the board of directors, or the audit committee.
+Added: As provided in the audit committee charter, the audit committee is responsible for reviewing, assessing, and considering, in consultation with management and our board of directors, as appropriate, the overall risk management policies and procedures of the Company, including our major risk exposures such as cybersecurity.
The audit committee and board of directors receive routine updates from senior management, including leaders from our information technology and legal functions regarding matters of cybersecurity.
1 unchanged sentence
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.