6 unchanged sentences
While this does not imply that we meet any particular technical standards, specifications or requirements, we use the CIS Controls framework as a guide to help us identify, assess and manage cybersecurity risks relevant to our business.
−Removed: Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, operational and financial risk areas.
−Removed: Our cybersecurity risk management program includes:
−Removed: • risk assessments designed to help identify material cybersecurity risks to our critical systems, information, products, services and our broader enterprise information technology environment;
+Added: Our cybersecurity risk management program is integrated into our overall risk management program which includes insurance coverage for cybersecurity incidents and shares common methodologies, reporting channels and governance processes that apply across the risk management program to other legal, compliance, strategic, operational and financial risk areas.
+Added: Key elements of our cybersecurity risk management program include, but are not limited to, the following:
+Added: • risk assessments designed to help identify material risks from cybersecurity threats to our critical systems and information;
• a security team principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls and (3) our response to cybersecurity incidents;
−Removed: • the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security controls;
−Removed: • cybersecurity awareness training of our employees, incident response personnel and senior management;
+Added: • the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes;
+Added: • cybersecurity awareness training of our employees, including incident response personnel and senior management;
• a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;
−Removed: • a third-party risk management process for service providers, suppliers and vendors who have access to our critical systems and information.
+Added: • a third-party risk management process for key service providers based on our assessment of their criticality to our operations and respective risk profile.
We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations or financial condition .
−Removed: In March 2020, we experienced a ransomware attack in which cybercriminals were able to access our information technology systems.
−Removed: While we isolated the source of the attack and restored normal operations with no material day-to-day impact to us or our ability to access our data, we believe confidential information was stolen.
−Removed: We believe it is possible that the ransomware attack could lead to the disclosure of our trade secrets or other intellectual property, or could lead to the exposure of personal information of our employees.
−Removed: The release of any of this information could have, but is not reasonably likely to have, a material adverse effect on our business, operations, business strategy, results of operations or financial condition.
−Removed: The March 2020 ransomware attack has not, but it is possible that it could, result in legal claims or proceedings, regulatory investigations or actions, and other types of liability under laws that protect the privacy and security of personal information, including federal, state and foreign data protection and privacy regulations, violations of which could, but is not reasonably likely to, result in significant judgements against us, penalties and fines.
−Removed: For more information, see the section titled “ Risk Factor—Risks related to our intellectual roperty, information technology and data security—If we or our critical third-party providers experience a significant disruption in our information technology systems or breaches of data security, our business could be adversely affected.
+Added: For more information, see the section titled “ Risk Factor—Risks related to our intellectual property, information technology and data security—If we or our critical third-party providers experience a significant disruption in our information technology systems or breaches of data security, our business could be adversely affected.
Cybersecurity Governance
4 unchanged sentences
The Audit Committee reports to the full Board regarding its activities, including those related to cybersecurity.
−Removed: Our management team, including our Chief Legal Officer, Chief Information Officer, President, Chief Financial Officer and Vice President of Data Analytics and Information Security is responsible for assessing and managing our material risks from cybersecurity threats.
+Added: Our management team, including our Chief Legal Officer, President, Chief Financial Officer and Vice President of Data Analytics and Information Security is responsible for assessing and managing our material risks from cybersecurity threats.
The team has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our external cybersecurity consultants.
Our management team’s cumulative experience includes decades of experience managing cybersecurity risks including serving in similar roles leading and overseeing cybersecurity programs at other companies.
−Removed: Our Chief Information Officer has served in various roles in information technology for almost 20 years and has been with us since 2013.
−Removed: He holds undergraduate and postgraduate degrees in computer science from Harvard University.
Our Vice President of Data Analytics and Information Security has served in various roles in information technology and information security for more than 10 years.
2 unchanged sentences
Team members who support our information security program have relevant educational and industry experience, including holding similar positions at large technology companies.
−Removed: Our management team supervises efforts to prevent, detect, mitigate and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel;
+Added: Our management team takes steps to stay informed about and monitor efforts to prevent, detect, mitigate and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel;
threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us;
−Removed: and alerts and reports produced by security tools deployed in the information technology environment.
+Added: and alerts and reports produced by security tools deployed in our information technology environment.
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.