5 unchanged sentences
We utilize third party cybersecurity consultancy firms to manage and execute our cybersecurity programs.
−Removed: These third party firms are led and supervised by our Chief Technology Officer (“CTO”).
+Added: These third party firms are led and supervised by our Chief Information Officer (“CIO”).
Our policies, standards, processes and practices for assessing, identifying, and managing material risks from cybersecurity threats are integrated into our overall risk management program and are based on frameworks established by the National Institute of Standards and Technology (“NIST”), the International Organization for Standardization and other applicable industry standards.
10 unchanged sentences
Management's Role
−Removed: Our CTO and Chief Compliance Officer have primary responsibility for assessing and managing material cybersecurity risks, including overseeing and identifying cybersecurity risks associated with our use of third party cybersecurity consultancy firms, and are members of management’s IT Steering Committee, which consists of management team members and certain employees who drive alignment on technology and security decisions across the Company.
+Added: Our CIO, who has 15 years experience in technology, has primary responsibility for assessing and managing material cybersecurity risks , including overseeing and identifying cybersecurity risks associated with our use of third party cybersecurity consultancy firms, and are members of management’s IT Steering Committee, which consists of management team members and certain employees who drive alignment on technology and security decisions across the Company.
The IT Steering Committee meets monthly to review security performance metrics, identify security risks, and assess the status of approved security enhancements.
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.