2 unchanged sentences
Risk management and strategy
−Removed: We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third party hosted services, communications systems, hardware and software, and our critical data, including intellectual property, and confidential information that is proprietary, strategic or competitive in nature (collectively, “Information Systems and Data”).
+Added: We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third party hosted services,
+Added: communications systems, hardware and software, and our critical data, including intellectual property, and confidential information that is proprietary, strategic or competitive in nature (collectively, “Information Systems and Data”).
Our information security function is led by our head of IT and supported by our executive team (specifically, our CEO, COO, and CFO), our engineering department, and third-party service providers, and helps identify, assess and manage the Company’s cybersecurity threats and risks.
−Removed: This group identifies and assesess risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods including, for example:
+Added: This group identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods including, for example:
manual and automated tools, conducting scans of the threat environment, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and actors and evaluating threats reported to us, external audits, third party testing and vulnerability assessments, and tabletop incident response exercises.
6 unchanged sentences
access and physical security controls;
−Removed: assess management;
+Added: asset management;
tracking and disposal;
systems monitoring;
−Removed: a vendor risk amangmeent program;
+Added: a vendor risk management program;
employee training;
2 unchanged sentences
Our assessment and management of material risks from cybersecurity threats are integrated into the Company’s overall risk management processes.
−Removed: For example our executive team evaluates material risks from cybersecurity threats
−Removed: against our overall business objectives and reports to the audit committee of the board of directors, which evaluates our overall enterprise risk.
+Added: For example, our executive team evaluates material risks from cybersecurity threats against our overall business objectives and reports to the audit committee of the board of directors, which evaluates our overall enterprise risk.
We use third-party service providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example professional services firms, managed cybersecurity services providers, penetration testing firms, dark web monitoring services and cybersecurity software providers.
2 unchanged sentences
The processes in place include a risk assessment for certain vendors and the imposition of certain contractual obligations related to cybersecurity on certain providers.
−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 management processes may involve different levels of assessment designed to help identify cybersecurity risks associated with these providers.
+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 processes involve different levels of assessment designed to help identify cybersecurity risks associated with these providers.
For a description of the risks from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors under Part 1.
−Removed: Risk Factors in this Annual Report on Form 10-K, including the risk factor entitled “If our information technology systems or those third parties upon which we rely or our data, are or were compromised, we could experience adverse consequences resulting from such compromise, including but not limited to regulatory investigations or actions;
+Added: Risk Factors in this Annual Report on Form 10-K, including the risk factor entitled “If our information technology systems or those third parties with whom we work, for our data, are or were compromised, we could experience adverse consequences resulting from such compromise, including but not limited to regulatory investigations or actions;
fines and penalties;
8 unchanged sentences
Management is responsible for hiring appropriate personnel and the head of IT is responsible for communicating key priorities to relevant personnel.
−Removed: The executive team works with the head of IT to help prepare for cybersecurity incidents, approve cybersecurity processes, and review security assessments and other security-related reports.
+Added: The executive team works with the head of IT to help prepare for
+Added: cybersecurity incidents, approve cybersecurity processes, and review security assessments and other security-related reports.
Our cybersecurity incident response processes are designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including the executive team, legal and others.
4 unchanged sentences
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.