2 unchanged sentences
Cybersecurity Risk Management and Strategy
−Removed: We recognize the critical importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information systems and protect the confidentiality, integrity, and availability of our and our customer’s data and information assets.
+Added: We recognize the critical importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information systems and protect the confidentiality, integrity, and availability of our and our customers’ data and information assets.
As such, we have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.
Our cybersecurity risk management program includes a cybersecurity incident response plan.
−Removed: We design and assess our program based on International Organization for Standardization (“ISO”) and National Institute of Standards and Technology (“NIST”) information security risk management frameworks.
+Added: We design and assess our program based on the International Organization for Standardization (“ISO”) and National Institute of Standards and Technology (“NIST”) information security risk management frameworks.
This does not imply that we meet any particular technical standards, specifications, or requirements, only that we use the above frameworks as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business.
7 unchanged sentences
• a third-party risk management process for service providers, suppliers, and vendors;
+Added: • a cyber insurance policy to help manage, in part, costs associated with significant cybersecurity incidents that may occur.
Although we have designed our cybersecurity program and governance procedures above to mitigate cybersecurity risks, we face cybersecurity risks, threats, and attacks that could materially affect our operations, business strategy, results of operations, or financial condition.
8 unchanged sentences
Board members receive presentations on cybersecurity topics from our Chief Information Security Officer (“CISO”), internal security staff, or external experts as part of the Board of Directors’ continuing education on topics that impact public companies.
−Removed: Our management team, including our Chief Technology Officer and CISO , is responsible for assessing and managing our material risks from cybersecurity threats.
+Added: Our management team, including our Chief Technology Officer (“CTO”) and CISO , is responsible for assessing and managing our material risks from cybersecurity threats.
The team has a primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants.
2 unchanged sentences
Our CISO has over 25 years of experience in various roles in cybersecurity and information technology.
+Added: Our CTO, CISO, and internal security personnel endeavor to stay abreast of emergent developments in relevant areas of technology and cybersecurity.
Our management team supervises efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include receiving briefings from internal security personnel;
−Removed: analyzing threat intelligence
−Removed: and other information obtained from governmental, public or private sources, including external consultants engaged by us;
+Added: analyzing threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us;
and reviewing 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.