8 unchanged sentences
Trinity’s IRM program is aligned to the National Institute of Science and Technology (“NIST”) Cybersecurity Framework (“CSF”) and conducts maturity assessments against the NIST CSF on a quarterly basis.
−Removed: Our IRM program encompasses the full lifecycle of information risk, from creation through disposition, and is guided by policies, processes, standards, and procedures in vulnerability management, incident response, information governance, risk management, and security awareness.
+Added: Our IRM program encompasses the full lifecycle of information risk, from creation through disposition, and is guided by policies, processes, standards, and procedures in vulnerability management, incident response, information governance, application security, risk management, and security awareness.
Additionally, Trinity exercises a variety of testing approaches to assess the state of systems and personnel, including annual penetration testing by independent third parties, ad hoc penetration testing by internal personnel, and tabletop exercises for executive and senior leadership, information technology, IRM, and legal employees.
Trinity also maintains an incident response relationship with an industry-leading provider to ensure resource availability if a significant event were to occur.
−Removed: As cybersecurity touches all employees, we include formal training on cybersecurity in the annually required Code of Business Conduct training.
+Added: As cybersecurity touches all employees, we include formal training on cybersecurity in the annually required Code of Business Conduct training, as well as dedicated information security training content.
The training focuses on awareness of cybersecurity risks and requirements.
22 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.