5 unchanged sentences
Additionally, we rely to a great extent on third -party service providers to perform critical functions to assist in maintaining customer accounts, providing electronic banking services and financial reporting.
−Removed: Our Information Security Officer, who is a member of our Executive Management Team, is primarily responsible for managing our cybersecurity program.
+Added: Our Information Security Officer, who is a member of our Senior Management Team, is primarily responsible for managing our cybersecurity program.
Our Information Security Officer has direct access to our Board of Directors and is authorized to evaluate our cybersecurity posture throughout the Company to ensure the implementation of appropriate controls over our systems and applications to maintain an effective cybersecurity program.
4 unchanged sentences
Daily operations are monitored by a dedicated team of information technology professionals complemented by management’s monitoring of critical information security monitoring reports along with our third -party security vendor who provides for 24x7 monitoring of our external connections and email system.
−Removed: Defined incident response
−Removed: procedures are maintained, including a requirement that our security vendor notify designated members of management when unusual or suspicious activity is identified.
+Added: Defined incident response procedures are maintained, including a requirement that our security vendor notify designated members of management when unusual or suspicious activity is identified.
To test and evaluate the effectiveness of our cybersecurity program, we are subject to annual audits of our program by an outside audit firm who specializes in both information technology and cybersecurity assessments.
7 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.