3 unchanged sentences
We have established policies and processes for assessing, identifying, and managing material risk from cybersecurity threats, and have integrated these processes into our overall risk management systems and processes.
−Removed: We r outinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information syst ems or any information residing therein.
+Added: We routinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein.
We adhere to industry-leading frameworks to safeguard our systems and data.
3 unchanged sentences
Our processes for assessing, identifying, and managing material cybersecurity risks align with HITRUST CSF guidelines.
−Removed: We conduct monthly risk assessme nts to identify cybersecurity threats, as well as assessments in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats.
+Added: We conduct monthly risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats.
These risk assessments include identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.
14 unchanged sentences
One of the key functions of our board of directors is informed oversight of our risk management process, including risks from cybersecurity threats.
−Removed: Our board of directors is responsible for monitoring and assessing strategic risk exposure, and our executive officers, including our Chief Financial Officer and General Counsel, are responsible for the day-to-day
−Removed: management of the material risks we face.
+Added: Our board of directors is responsible for monitoring and assessing strategic risk exposure, and our executive officers, including our Chief Financial Officer and General Counsel, are responsible for the day-to-day management of the material risks we face.
Our board of directors administers its cybersecurity risk oversight function directly as a whole, as well as through its audit committee.
−Removed: Our Chief Financial Officer and Senior Director of Information Technology are primarily responsible for assessing and managing our material risks from cybersecurity threats w ith assistance from third-party service providers.
−Removed: Our Senior Director of Information Technology leads our internal team and has over 20 years of cybersecurity experience, including the last 10 years in leadership positions, enabling him to build and transform successful cybersecurity programs and initiatives across several enterprises.
+Added: Our Chief Financial Officer and Executive Directo r of Information Technology are primarily responsible for assessing and managing our material risks from cybersecurity threats with assistance from third-party service providers.
+Added: Our Executive Director of Information Technology leads our internal team and has over 20 years of cybersecurity experience, including the last 10 years in leadership positions, enabling him to build and transform successful cybersecurity programs and initiatives across several enterprises.
His active associations include Veteran Volunteer Instructor for US Cyber Army Command (ARCYBER), Information Systems Security Association (ISSA), and Forum of Incident Response and Security Teams (FIRST), and has held many technical certifications including Strategic Planning, Policy, and Leadership (GSTRT), Certified Information Systems Security Professional (CISSP) and Certified Cloud Security Professional (CCSP).
1 unchanged sentence
Certified Information Systems Security Architecture Professional (CISSP-ISSAP), Certified in the Governance of Enterprise IT (CGEIT), Certified Data Privacy Solutions Engineer (CDPSE), and Certified Ethical Hacker (CEH).
−Removed: Our Chief Financial Officer and Senior Director, Information Technology oversee our cybersecurity policies and processes, including those described in “Risk Management and Strategy” above.
−Removed: The processes by which o ur Chief Financial Officer and Senior Director, Information Technology are informed about and monitor the prevention, detection, mitigation, and remediation of cybersecurity incidents include company incident management and data protection policies, and applicable cybersecurity incident response playbooks.
−Removed: Our Chief Financial Officer and Senior Director, Information Technology provide periodic briefings to the audit committee regarding our cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third parties, and the like.
+Added: Our Chief Financial Officer and Executive Director, Information Technology oversee our cybersecurity policies and processes, including those described in “Risk Management and Strategy” above.
+Added: The processes by which our Chief Financial Officer and Executive Director, Information Technology are informed about and monitor the prevention, detection, mitigation, and remediation of cybersecurity incidents include company incident management and data protection policies, and applicable cybersecurity incident response playbooks.
+Added: Our Chief Financial Officer and Executive Director, Information Technology provide periodic briefings to the audit committee regarding our cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third parties, and the like.
Our audit committee provides regular updates to the board of directors on such reports.
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.