4 unchanged sentences
We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.
−Removed: We design and assess our program guided by a number of well-known industry standards, such as the National Institute of Standards and Technology (NIST) Risk Management Framework (RMF), International Organization for Standardization/International Electrotechnical Commission (ISO/IEC) 27001, and Center for Internet Security (CIS) Controls V8.
−Removed: This does not imply that we meet all of these standards, specifications, and requirements, only that we use these standards as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business.
+Added: We use the National Institute of Standards and Technology (NIST) Risk Managemen t Framework (RMF) to guide our security program in support of maintaining compliance with requirements such as the Sarbanes-Oxley Act, the Payment Card Industry Data Security Standard, and the Gramm-Leach-Bliley Act.
+Added: While we do not claim full compliance with all elements of the standards, this comprehensive framework helps us consistently identify, assess, and manage cybersecurity risks appropriate to our business.
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.
1 unchanged sentence
• risk assessments designed to help identify material cybersecurity risks to our critical systems and, information;
−Removed: • an information security program, led by our Chief Technology Officer, principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents;
+Added: • an information security program, led by our Senior Director of Information Security, principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents;
• the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes;
1 unchanged sentence
• a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;
+Added: • annual tabletop exercises for incident response involving relevant members from the Company’s executive management, information security, legal and other teams to test and improve our response plans;
• a third-party risk management process for service providers, suppliers, and vendors based on their criticality and risk profile.
4 unchanged sentences
Our Board considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee (the "Committee") oversight of cybersecurity and other information technology risks.
−Removed: The Committee oversees management’s implementation of our cybersecurity risk management program.
+Added: The Committee oversees
+Added: management’s implementation of our cybersecurity risk management program.
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: The Chief Technology Officer has primary responsibility for our overall cybersecurity risk management program and supervises both our internal information security program and personnel and certain of our retained external cybersecurity consultants.
−Removed: She has over twenty-five years of experience in the technology industry.
−Removed: In addition, the Vice President of Engineering has involvement in managing cybersecurity risk and has over 30 years of experience in the technology industry.
−Removed: Vroom’s Chief Technology Officer reports to the Committee on a quarterly basis on our cybersecurity risks.
−Removed: In addition, the Chief Technology Officer updates the Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.
+Added: Vroom’s Senior Director of Information Security reports to the Committee on a quarterly basis on our cybersecurity risks.
+Added: In addition, the Senior Director of Information Security updates the Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.
The Committee periodically reports to the full Board regarding its activities, including those related to cybersecurity.
−Removed: Committee members receive presentations on cybersecurity topics from our internal security staff or external experts as part of the Committee’s continuing education on topics that impact public companies.
−Removed: Our management team, including Vroom’s Chief Executive Officer, Chief Financial Officer, Chief Legal Officer, VP of Human Resources, and Chief Technology Officer, stays informed and monitors efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal information security personnel;
−Removed: threat intelligence and other information obtained from governmental, public or private sources,
−Removed: including external consultants engaged by us;
+Added: Committee members receive presentations on cybersecurity topics from our Senior Director of Information Security, internal security staff or external experts as part of the Committee’s continuing education on topics that impact public companies.
+Added: Our Chief Technology Officer has primary responsibility for our overall cybersecurity risk management program and supervises both our internal information security program and personnel, as well as certain of our retained external cybersecurity consultants.
+Added: She has over twenty-five years of experience in the technology industry.
+Added: Our Senior Director of Information Security is the head of the Company’s cybersecurity team and reports directly to the SVP of Engineering.
+Added: The Senior Director of Information Security, who maintains CISSP and CCISO certifications, has 25 years of experience in the technology industry with 15 years of experience in cybersecurity.
+Added: Our executive management team, including Vroom’s Chief Executive Officer, Chief Financial Officer, Chief Legal Officer, VP of Human Resources, and Chief Technology Officer, stays informed and monitors efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal information security personnel;
+Added: threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us;
and alerts and reports produced by security tools deployed in the IT 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.