reasoning: Paragraph provides a standard materiality assessment regarding past cybersecurity incidents without describing specific events, operational impacts, or response actions. The content consists of boilerplate language regarding the absence of material adverse effects and forward-looking disclaimers about future risks, which falls under Strategy Integration per the materiality disclaimer rule. No specific frameworks, named roles, dates of incidents, or verifiable facts are disclosed beyond the filing date.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes an internal cybersecurity procedure (access control and review processes), which falls under Risk Management Process. However, it contains no specific details—no dates, titles, named systems, or quantifiable metrics—that would distinguish this disclosure as unique to HG Holdings; it is generic language that could apply to any company.

provider: moonshotai

stage: benchmark


reasoning: The paragraph describes the company's internal procedures for tracking, reviewing, and escalating cybersecurity incidents across its ecosystem, which constitutes a risk management process. It contains no firm-specific details—no named frameworks, dates, dollar amounts, specific departmental compositions, or cybersecurity-specific titles—only generic references to 'incident management teams,' 'cross-functional working groups,' and 'senior management' that could apply to any large corporation.


content_category: Management Role

reasoning: The paragraph focuses on identifying the specific CTO (Mr. Eliran Ben-Zikri) and detailing his qualifications, military background, tenure, and career history at named companies, which centers on the management role rather than processes. It contains multiple firm-specific facts including the named individual, specific years of experience, and previous employers that identify this disclosure as unique to the company.


reasoning: The paragraph describes the company's internal risk management processes for evaluating cybersecurity risks and compliance, including third-party risk considerations as a component of those processes rather than the central topic. It contains no specific facts—no named frameworks (e.g., NIST, ISO), dates, specific titles (e.g., CISO), named committees, quantifiable metrics, or unique program identifiers—and consists of generic language applicable to any organization's cybersecurity risk management description.


content_category: Board Governance

reasoning: The paragraph describes board oversight of cybersecurity risk and specifically identifies the formation of a 'cybersecurity risk committee' (a named non-generic committee), which qualifies as a firm-specific governance fact under Board Governance.


content_category: Incident Disclosure

reasoning: The paragraph narrates an actual cybersecurity incident, providing the specific detection date (July 10, 2024), describing the unauthorized access scope ('portion of our IT systems'), and detailing response actions including investigation and system shutdowns. While it contains one specific date, it lacks a second hard verifiable fact (such as named third-party firms, specific tools, dollar amounts, or headcounts), so it does not reach the Quantified-Verifiable threshold.


reasoning: The paragraph identifies specific cybersecurity management titles (VP of information technology services), reporting structures (to the Chief Strategy Officer), and team qualifications, while also specifying the functional groups (legal advisors, communication specialists) involved in incident reporting pathways.


reasoning: The paragraph describes the company's internal cybersecurity processes, including employee training programs (monthly simulations, quarterly IT training), incident response tabletop exercises, and integration of security risk into product design. It is categorized as Risk Management Process because it focuses on the company's own internal activities and programs rather than board governance, management roles, or financial strategy. The specificity is Firm-Specific due to the inclusion of a specific date ('In 2023') and unique organizational ethos terms ('security first', 'security by design'), though it lacks the second hard verifiable fact (e.g., dollar amount, headcount, or named third-party firm) required for Quantified-Verifiable.


reasoning: The paragraph focuses on specific management roles (Director of Information Technology, Chief People Officer, Chief Legal Officer, CFO) and their reporting lines, meeting cadences, and oversight activities. The Director of Information Technology is the grammatical subject describing cybersecurity risk management monitoring and reporting to the audit committee. While the audit committee is mentioned, the primary focus is on management functions and reporting structures, not board governance processes. The specificity is Firm-Specific due to the identification of the 'Director of Information Technology' cybersecurity-specific role, while other titles (CFO, Chief Legal Officer, Chief People Officer, audit committee) are generic.


content_category: Strategy Integration

reasoning: The paragraph provides a standalone materiality conclusion stating the company has not experienced a material cybersecurity incident, which falls under Strategy Integration per the tiebreaker rules for materiality disclaimers. It contains no specific facts, dates, named roles, or frameworks, making it Generic Boilerplate.


reasoning: The paragraph describes internal processes for monitoring systems, conducting audits, and maintaining incident response capabilities. While it references a 'Director of Infrastructure,' this is not a cybersecurity-specific title (e.g., CISO, CIO) per the IS list, and the content focuses on the functions performed rather than the individual's qualifications or background. The paragraph lacks named frameworks, specific dates, quantified metrics, named third-party firms, or other distinguishing details, consisting instead of generic descriptions of security monitoring and incident response activities that could apply to any company.


reasoning: Paragraph contains a standalone materiality conclusion stating that cybersecurity risks have not materially affected the company, which falls under Strategy Integration per SEC disclosure patterns. The text is generic boilerplate with no specific dates, dollar amounts, named entities, or unique operational details—language that could appear in any company's filing.


reasoning: The paragraph describes the company's internal risk management processes, frameworks, and security activities (monitoring, vulnerability management, penetration testing) without referencing specific incidents, board oversight, or management personnel qualifications. It names the NIST Cybersecurity Framework but contains no firm-specific details such as dates, headcounts, named tools, or specific cybersecurity role titles beyond generic references to an 'IT security team'.


reasoning: The paragraph describes the company's internal cross-functional governance mechanism for managing cybersecurity risk (the Steering Committee), not the qualifications of a specific individual. It contains firm-specific details including a named non-generic committee, the CISO title, and a specific multi-departmental composition that goes beyond generic boilerplate.


reasoning: The paragraph identifies specific management positions (President of P&T, CDO, and the senior-most cybersecurity employee) as the grammatical subject responsible for leading cybersecurity processes, fitting the Management Role category. It contains firm-specific role titles but lacks quantifiable data like headcounts, dates, or named vendors.


reasoning: The board of directors is the grammatical subject with responsibility for oversight of risk management processes, fitting Board Governance. The language is entirely generic boilerplate that could apply to any company, containing no named committees (beyond the standard board), frameworks, dates, or cybersecurity-specific details.


reasoning: The paragraph focuses primarily on the CISO's personal qualifications, certifications, and experience, making it about the management role rather than the function or board oversight. It contains two hard verifiable facts (specific 20-year tenure and named CISSP certification) that satisfy the Quantified-Verifiable threshold. The Audit Committee mention is brief and generic.


reasoning: The paragraph identifies specific management positions (CISO and Senior Vice President, Internal Audit and Risk) and details their reporting lines to the Audit Committee and full Board. While board oversight is mentioned, the grammatical focus includes management roles as subjects, and the disclosure centers on the identification of these specific cybersecurity and risk management positions. The specific cybersecurity title 'CISO' provides a firm-specific fact that distinguishes this from generic boilerplate.


reasoning: The paragraph describes a specific historical cybersecurity event (a ransomware incident on December 15, 2020), including the date, systems affected (operational and IT systems), and business impact (service delays, unexpected costs), which satisfies the Incident Disclosure definition. It contains one hard verifiable fact (the specific date) and a named incident reference, meeting the Firm-Specific threshold but lacking a second hard fact (dollar amount, vendor name, or product name) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity processes (continuous monitoring, vulnerability management, employee training) where the risk management function is the grammatical subject. It contains no named frameworks, specific dates, dollar amounts, headcounts, named vendors, or specific cybersecurity titles—only generic descriptions of security controls (firewalls, EDR, encryption) and activities that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessment, security controls, and incident response) rather than focusing on the qualifications or background of the information technology manager, making it Risk Management Process under the person-vs-function test. It contains no named frameworks, specific dates, headcounts, dollar amounts, or other verifiable details that would identify this as unique to 374Water—only generic descriptions of security team responsibilities that could apply to any company.


reasoning: The paragraph contains a standalone materiality assessment stating that known cybersecurity threats have not materially affected the company and a forward-looking statement about potential material effects, which falls under Strategy Integration. It employs standard, interchangeable language ('materially affected our operations, business strategy, results of operations, or financial condition') that could appear in any company's filing without modification, containing no specific dates, roles, frameworks, or quantifiable data.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities for cybersecurity risk and the Audit Committee's role, with the Board as the primary grammatical subject. However, it contains only generic governance references ('the Board,' 'Audit Committee,' 'management') and boilerplate language about oversight and expertise without naming specific board members, their credentials, meeting dates, or unique program identifiers.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risks, with the Audit Committee serving as the grammatical subject responsible for overseeing management's implementation of cybersecurity policy. This aligns with Board Governance. The disclosure contains only generic references to standard governance bodies (Board, Audit Committee) and management, with no specific dates, named cybersecurity roles, frameworks, or other firm-specific details.


reasoning: The paragraph identifies specific cybersecurity management roles (CIO, Director of Information Security) and describes the reporting lines and team composition of the Information Security Team, fitting the Management Role category. It contains firm-specific organizational details including named cybersecurity-specific titles and the ERM Program, but lacks quantified data (dates, dollar amounts, headcounts) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, which aligns with Risk Management Process. It contains no named frameworks, specific roles, dates, dollar amounts, or other verifiable details, making it generic boilerplate language that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including risk assessments, vendor due diligence, and employee training. While it identifies a specific cybersecurity-related management title (Vice President, Information Technology & Facilities) and references specific vendor types relevant to the biotech industry (CROs), the primary focus is on the program's activities and controls rather than the individual's qualifications or background.


reasoning: The paragraph describes potential business and financial impacts of cybersecurity incidents (operational disruption, reputational harm, compliance costs, litigation exposure, and liabilities) but does not detail specific internal risk management processes, governance structures, or actual incidents. It qualifies as Strategy Integration because it addresses the business/financial impact dimension of cybersecurity risk. Specificity is Generic Boilerplate because the language contains no named entities, frameworks, dates, dollar amounts, specific roles, or verifiable facts—only generic risk factor language ('cyber-attacks,' 'business operations,' 'regulatory investigation,' 'increased costs') that could apply to any company.


reasoning: The paragraph focuses on the CIO's qualifications, tenure, and certifications (19 years experience, 11 years with company, SANS and CISA certifications), making it about the person rather than abstract processes. It contains multiple hard verifiable facts including specific durations and named professional certifications, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph provides a standalone materiality conclusion stating that known cybersecurity threats and prior incidents have not materially affected the company's operations, business strategy, or financial condition, which falls under Strategy Integration per the guidelines. The language is generic boilerplate materiality disclaimer language that could appear in any company's filing without modification.


reasoning: The paragraph describes the company's internal cybersecurity processes, including the use of frameworks, development of a cybersecurity plan, and regular policy reviews, which fits Risk Management Process. It lacks named frameworks (only referring to them generally), specific dates, dollar amounts, named third-party firms, or other verifiable specifics, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessments, threat analysis, tabletop exercises, monitoring) and identifies specific cybersecurity leadership titles (CIO and CISO) and the formal program name, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes a board committee receiving reports from management on cybersecurity posture and incidents, placing it in Board Governance. It contains no specific facts, dates, named roles, or frameworks—only generic references to 'The Committee,' 'management,' and 'annual' reports that could apply to any company.


reasoning: The paragraph provides a detailed narrative of an actual cybersecurity incident, including specific dates (February 23 and 28, 2023), the scope of systems affected (internal servers and IT telephony), confirmation of data extraction, and specific response actions (engaging experts, notifying law enforcement). The presence of two specific dates meets the Quantified-Verifiable threshold.


reasoning: The paragraph provides a standalone materiality assessment stating no material cybersecurity incidents have been identified, without describing any specific event. It consists entirely of generic boilerplate language regarding materiality and forward-looking risk disclaimers that could appear in any company's filing, containing no specific dates, dollar amounts, named roles, or other firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessments, penetration testing, incident response planning, third-party risk management, and training) but contains no named frameworks, specific dates, headcounts, dollar amounts, or unique organizational details. References to 'information security team,' 'security operations team,' and 'annual' activities are generic functional descriptions and cadences that could apply to any company.


reasoning: The ISO is the grammatical subject discussing his reporting lines to management and the BRCC, fitting the Management Role category definition which includes reporting lines. It cites a cybersecurity-specific title (ISO) and a named non-generic committee (BRCC), making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes (defense, detection, remediation, and crisis response planning) but contains no specific details about frameworks, roles, dates, metrics, or tools. Language such as 'rapid detection,' 'cybersecurity policies,' and 'crisis response and management plan' is entirely generic and could apply to any company.


reasoning: Paragraph describes the company's internal IT Steering Committee, its specific composition, and its functions regarding cybersecurity threat discussions and strategic planning, which constitutes a risk management process. Contains firm-specific organizational details including named committees and departmental composition.


reasoning: The paragraph focuses on the Audit Committee's oversight activities, including receiving briefings from the Chief Operating Officer, maintaining ongoing dialogue, participating in strategic decisions, and conducting annual reviews of the cybersecurity program. The Audit Committee serves as the grammatical subject for the majority of the disclosure, addressing board-level oversight and briefing cadence rather than management qualifications or internal operational processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including policies, standards, and processes for assessing and managing risks. While it mentions board and management oversight, the primary focus is on the risk management function itself. The disclosure contains no specific details, frameworks, dates, quantifiable metrics, or named roles, consisting entirely of generic language that could apply to any company.


reasoning: The paragraph describes the company's internal data storage architecture and security practices for handling customer information, constituting a risk management process disclosure. It contains two hard verifiable facts—specific named third-party cloud platforms (Google Cloud and Amazon Web Services)—meeting the threshold for Quantified-Verifiable specificity.


reasoning: The board of directors is the grammatical subject responsible for oversight and receiving updates on cybersecurity risks, fitting the Board Governance category. The paragraph contains only generic language ('periodic updates', 'management team', 'cybersecurity threats') with no named committees, specific dates, frameworks, or quantified details that would identify this specific company.


reasoning: The paragraph identifies the CISO as the grammatical subject and focuses on the person's qualifications, credentials, and background (20 years experience, Fortune 500/US Government client history), which fits the Management Role category. It contains firm-specific facts including the cybersecurity-specific title (CISO) and specific tenure duration.


reasoning: The paragraph identifies specific cybersecurity-related management positions (CISO, CTO) and describes the composition, responsibilities, and reporting structure of a management-level committee overseeing cybersecurity, including escalation lines to the Board. It focuses on who holds these roles and their governance functions rather than detailing specific risk assessment processes or board-level oversight.


reasoning: The paragraph identifies specific cybersecurity management roles (CISO, CIO), their reporting lines, and quantifiable professional credentials (35 years experience, specific degree), focusing on the people and their qualifications rather than processes or board oversight.


reasoning: The paragraph focuses on the specific individual managing cybersecurity (Director of IT), their reporting line, and detailed career history/qualifications (12 and 20 years of experience), satisfying the Management Role category. It meets the Quantified-Verifiable threshold with two distinct quantified metrics (years of experience) that could be independently verified.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risk management and escalation procedures, fitting the Board Governance category. However, it contains only generic references to standard governance bodies (Board of Directors, Audit Committee) without any firm-specific details, dates, named roles, or frameworks, making it Generic Boilerplate.


reasoning: The paragraph provides a detailed narrative of a specific ransomware incident in February 2023, describing the attack vector (global ransomware), impact (encrypted servers), response actions (restoration from backups, no ransom paid), and operational scope (manufacturing, sales, order processing, distribution). While it opens with a materiality conclusion, the substantive content is the incident description itself.


reasoning: The paragraph describes the company's internal cybersecurity assessment processes, including external audits of its ISMS and penetration testing activities, which are core risk management functions. It contains firm-specific details including certification to the ISO/IEC 27001:2013 standard and specific years (2023 and 2024) when independent audits occurred.


content_category: None/Other

reasoning: This paragraph contains a forward-looking hypothetical statement about potential future cybersecurity incidents and a cross-reference to the Risk Factors section, with no substantive disclosure about the company's actual cybersecurity governance, management roles, risk processes, or specific incidents.


reasoning: The paragraph describes the company's internal cybersecurity processes (technical measures, access controls, training requirements) without referencing the board, specific management roles, or incidents. It contains only generic security practices (encryption, MFA, antivirus, annual training) applicable to any company, with no named frameworks, specific dates, dollar amounts, headcounts, or unique program identifiers.


reasoning: The paragraph describes Blue Owl's internal cybersecurity governance policy (ISG Policy), framework adoption (NIST), and specific operational processes (monitoring, vulnerability management, encryption). While it identifies the CTO and Head of Technology Infrastructure as program managers, the focus is on the functions and safeguards implemented rather than the individuals' qualifications or backgrounds, making this a process description rather than a management role disclosure.


reasoning: The paragraph focuses on the qualifications, career history, and educational background of the Chief Technology Officer as a person, not on the processes or functions of the role. It contains firm-specific details including the CTO's specific tenure (30+ years), educational credentials (degrees in electrical engineering), and previous leadership positions at three public companies.


reasoning: The paragraph briefly references a past incident ('the incident') and concludes with a standalone materiality assessment that it 'did not have a material impact on our operations or financial condition,' which per the tiebreaker rules classifies it as Strategy Integration. It contains no specific dates, dollar amounts, named third-party firms, product names, or recognized frameworks, making it Generic Boilerplate.


category_confidence: medium

reasoning: Paragraph discusses regulatory inquiries related to a past cybersecurity incident, constituting a business/compliance impact rather than describing the incident itself or internal risk processes. Contains no specific dates, amounts, named entities, or quantifiable details.


reasoning: The paragraph describes the company's internal cybersecurity controls and technical safeguards (MFA, EDR, SIEM, VPN, encryption), which constitutes a description of internal risk management processes. However, it lists only generic security categories and practices without naming specific products (e.g., CrowdStrike, Splunk), frameworks (e.g., NIST, ISO 27001), dates, numbers, or unique internal program identifiers, making it applicable to any company.


reasoning: The paragraph centers on a materiality conclusion ('not reasonably likely to materially affect us') regarding identified threats and includes a cross-reference to Risk Factors, which falls under Strategy Integration per the tiebreaker rules. It contains no named frameworks, specific dates (only the relative reference 'last fiscal year'), roles, or quantifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment elements, and incident response policies, which falls under Risk Management Process. It names the NIST Cybersecurity Framework as the basis for its procedures, but contains no firm-specific details such as dates, specific roles, headcounts, or unique program identifiers, making it Sector-Adapted.


reasoning: The paragraph describes the composition and supervisory responsibilities of the management team in leading the cybersecurity program, fitting the Management Role category. It specifies the cross-functional departmental composition (IT, finance, legal, operations), which constitutes a firm-specific organizational detail.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk, with the board and committee as grammatical subjects. While CEO and CFO are mentioned, they are generic C-suite roles rather than cybersecurity-specific management positions (CISO/CTO/CIO), and the text describes governance structure rather than individual qualifications or processes. No specific dates, frameworks, headcounts, dollar amounts, or firm-specific details are present.


specificity_confidence: medium

reasoning: Paragraph constitutes a materiality assessment stating that cyber attacks in 2016 and 2017 did not materially affect the company, with a cross-reference to Risk Factors. Brief mention of past incidents with materiality conclusion as the main point maps to Strategy Integration. Specific years 2016 and 2017 are firm-specific historical facts that distinguish this from generic boilerplate.


reasoning: The paragraph describes a specific ransomware incident involving data exfiltration and subsequent notification actions, fitting the Incident Disclosure category. However, it lacks specific dates, quantified impacts, named entities, or other hard verifiable facts from the IS list, making it Generic Boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident (the data breach involving Progress software) and subsequent regulatory investigation, including specific response actions (public disclosure, customer notifications, SEC cooperation) and the exact date (February 26, 2024) the company received a document preservation request.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment program, framework adoption, and control implementations (monitoring, penetration testing, disaster recovery), which falls under Risk Management Process. It names recognized standards (ISO, NIST) but contains no firm-specific details such as dates, headcounts, named roles, or specific tools that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes the nature and sources of cybersecurity risks the company faces (geographic scope, system complexity, threat actor attractiveness, and third-party usage), which constitutes risk assessment content under Risk Management Process. It does not describe board oversight, management roles, specific incidents, or financial/materiality impacts. The language is entirely generic—no specific dates, figures, named frameworks, organizational structures, or unique business details are provided that would identify this disclosure as specific to Baldwin Insurance Group.


reasoning: The paragraph describes the company's internal technical controls and monitoring capabilities (firewalls, MFA, penetration testing, 24x7 SOC), which are core risk management processes. However, it contains only generic security practices without naming specific frameworks, vendors, products, dates, or organizational details, making it indistinguishable from standard boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal risk management processes for assessing third-party cybersecurity risks ('As part of our risk management program...'), which qualifies as Risk Management Process rather than Third-Party Risk since the focus is on internal processes rather than vendor oversight as the central topic. It lacks specific dates, named frameworks, specific roles, dollar amounts, or any quantifiable metrics, making it generic boilerplate language applicable to any company.


reasoning: The paragraph identifies specific management committees (Compliance Committee, Information Governance and Privacy Committee) and executive roles (CCO) responsible for cybersecurity oversight, including detailed committee compositions and reporting structures. It focuses on WHO manages cyber risk rather than the processes used or board-level oversight.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessment, monitoring, and incident response activities. It references alignment with the NIST 800-171 Cybersecurity Framework but contains no firm-specific details such as named roles, dates, headcounts, or unique program identifiers.


reasoning: The paragraph describes the company's internal cybersecurity processes, including continuous threat monitoring, the structure and responsibilities of the Global Information Security team, and the Enterprise Security Council's integration with Enterprise Risk Management. While management roles (CISO, CEO) are mentioned with specific qualifications, they are described in the context of organizational processes and governance structures rather than as the primary focus.


reasoning: This paragraph is a forward-looking hypothetical statement describing generic potential consequences of a cyber attack (fines, litigation, reputational damage) without disclosing any actual governance structures, management roles, internal processes, or specific incidents. It contains no substantive disclosure about the company's cybersecurity program and could appear in any company's filing.


reasoning: The paragraph identifies specific cybersecurity leadership titles (CIO, VP Information Technology, Manager of Security) and their collective qualifications (50+ years experience), focusing on the individuals holding management responsibility rather than describing risk management processes or board oversight.


reasoning: This paragraph contains forward-looking risk disclaimers and generic statements about cybersecurity threats without substantive disclosure of the company's actual cybersecurity program, board oversight, management roles, or processes. As a SPAC with no operations making general risk statements, it falls under None/Other per the specific guidance for shell companies. The text contains no specific facts, dates, roles, or frameworks—only boilerplate language about potential material adverse effects that could apply to any company.


reasoning: The paragraph describes a specific cybersecurity incident that occurred on September 14, 2023, including the attack vector (social engineering on an outsourced IT vendor), scope (loyalty program database containing driver's license and social security numbers), and specific response actions (activation of IRP, investigation, regulatory notifications). This narrative of an actual event fits Incident Disclosure. The inclusion of a specific date and the named internal program 'IRP' makes this Firm-Specific rather than generic boilerplate.


reasoning: The paragraph assigns oversight responsibility to the Board of Directors using generic governance terminology ('board of directors', 'management', 'risk management system') without specifying particular committees, reporting cadences, or firm-specific oversight mechanisms.


reasoning: The paragraph describes management's reporting lines to board committees, with 'Management' as the grammatical subject. The specific naming of the 'Enterprise Risk and Compliance Committee'—a non-standard committee beyond the generic Audit Committee—provides a firm-specific fact.


reasoning: Paragraph focuses on the Chief Information Officer's qualifications, tenure, and team composition rather than processes, including two specific verifiable metrics: over 10 years of experience for the CIO and over 13 years average experience for the supporting team.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including monthly reporting to the Board and program evaluations by experts. It contains no named frameworks, specific dates, quantified metrics, or cybersecurity-specific roles (e.g., CISO), making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the Board of Directors and Audit Committee's oversight responsibilities and briefing cadences regarding cybersecurity risks, with the board and committee as the grammatical subjects. It contains only standard governance references (Board, Audit Committee) and vague temporal descriptors (quarterly, periodically) without naming specific dates, roles, frameworks, or unique organizational details.


reasoning: This paragraph presents a standalone materiality assessment concluding that cybersecurity risks are not expected to significantly affect the company's operational capabilities, financial condition, or business objectives. It contains no incident narrative, specific process descriptions, or governance details, and uses boilerplate language applicable to any company.


reasoning: The paragraph describes a specific cybersecurity incident occurring in November 2023, including operational disruption, the scope of affected data (employee and patient information), and subsequent remediation actions, fitting the Incident Disclosure category. It contains firm-specific details including the specific date and reference to their Security Operations Center, but lacks a second hard verifiable fact (such as dollar amounts, headcounts, or named third-party firms) needed for Quantified-Verifiable.


content_category: Third-Party Risk

reasoning: The paragraph is centrally focused on vendor management and oversight of third-party service providers, describing risk assessments, security questionnaires, audits, and contractual obligations imposed on vendors. It contains no named entities, dates, frameworks, specific numbers, or unique program identifiers—only generic vendor management practices that could apply to any company.


reasoning: While the paragraph opens with board oversight, the primary focus is on the Cybersecurity Disclosure Committee (CDC)—a named, non-generic committee with a specific cross-functional composition (IT, Legal, Internal Audit, and Accounting)—and its internal processes for assessing materiality, reviewing risks, and managing mitigation strategies. This describes the company's internal risk management and disclosure processes rather than board governance alone.


reasoning: The paragraph describes the company's internal cybersecurity and risk assessment programs, including security monitoring and enterprise-wide risk assessment, with no mention of board oversight, specific incidents, or management roles. It contains no named frameworks, specific dates, numbers, tools, or organizational details that would distinguish it from any other company's disclosure.


reasoning: The paragraph exclusively addresses oversight of third-party service providers, including assessment of vendor security controls, review of SOC 2 reports, and contractual notification requirements. It names the SOC 2 framework but contains no firm-specific details such as named vendors, dates, or unique organizational structures.


reasoning: The paragraph focuses on identifying specific cybersecurity management roles (VP of IT, IT Systems & Security Administrator), their qualifications (15 years experience), reporting lines to the COO, and the departmental composition of the Cybersecurity Incident Management Team. This describes the organizational structure and personnel rather than risk management processes or board oversight.


reasoning: Paragraph focuses on the qualifications and tenure of the CEO and executive officers regarding cybersecurity oversight, including the specific claim of 'more than 15 years of experience,' rather than describing internal risk processes or board governance structures. Board oversight appears only briefly as the recipient of reports, while management roles and qualifications constitute the primary content.


reasoning: Paragraph describes internal risk assessment processes (monitoring, automated tools, escalation protocols) rather than the CFO's personal qualifications. CFO is a generic C-suite title and 'third-party cybersecurity vendors' are unnamed, with no specific frameworks, dates, or quantified details provided.


reasoning: The paragraph explicitly states the company is a start-up with limited operations and provides only general descriptions of cybersecurity threats (malware, viruses, email attachments) without disclosing any specific governance structures, management roles, internal risk management processes, or incident details. Per the classification guidelines, disclosures from shell companies or start-ups that merely acknowledge the existence of cyber risks without describing formal programs, governance, or processes are classified as None/Other.


reasoning: The paragraph describes the company's internal risk management activities—security policies, employee training programs, mock breach testing, and incident response procedures—without referencing specific frameworks, named roles, dates, or quantifiable details. It focuses on the company's own processes for managing cyber risk from employees and third parties, fitting Risk Management Process. The language consists entirely of generic practices (awareness training, policy maintenance, simulated testing) that could apply to any organization, with no firm-specific identifiers.


reasoning: The paragraph describes the company's internal cybersecurity processes (training, testing, audits, third-party engagement) and mentions a CISO-led team, but focuses on the function and activities rather than the individual's qualifications or reporting lines. The mention of a chief information security officer provides one firm-specific detail, but no named standards, dates, dollar amounts, or vendor names are present.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risk, making the board committee the grammatical subject. It specifically identifies the vCIO (virtual Chief Information Officer) as a distinct role providing reports to the committee, which qualifies as a cybersecurity-specific title under the Firm-Specific criteria.


reasoning: The paragraph centers entirely on vendor oversight, describing annual assessments of third-party vendors and contractual security requirements for vendors accessing sensitive data. This aligns with the Third-Party Risk category where vendor oversight is the central topic rather than a component of internal processes. The disclosure contains no specific frameworks, dates, dollar amounts, named vendors, or other verifiable facts, rendering it generic boilerplate applicable to any company.


reasoning: The paragraph primarily describes the company's internal risk assessment procedures, audit processes, and cybersecurity controls. While Board oversight and reporting lines are mentioned, they are framed within the context of governing these operational processes rather than being the central focus. The specific title 'Director of Information Technology' constitutes a firm-specific detail under the cybersecurity-specific roles category.


reasoning: The paragraph identifies the company's Cybersecurity Steering Committee (CSC) and lists its specific membership, including the CISO and other senior executives, which describes the management structure and reporting lines for cybersecurity. It qualifies as Firm-Specific due to the named non-generic committee, the cybersecurity-specific CISO title, and the detailed composition of specific executive roles serving on the committee.


reasoning: The paragraph describes internal risk management activities—regular meetings to review cybersecurity risks and quarterly briefings to the Audit Committee—rather than the personal qualifications of the individuals or board oversight structure. Per the person-vs-function test, because the focus is on what the roles DO (meetings, reviews) rather than who they are, this falls under Risk Management Process. Specificity is Firm-Specific due to the identification of cybersecurity-specific titles (CIO and Head of Information Security).


reasoning: The paragraph describes a specific cybersecurity incident from October 2023, detailing unauthorized access to user information from 23andMe.com accounts (scope), the nature of the breach (accessed and downloaded), and specific response actions implemented (password resets, 2FA requirements, detection tools). This is an incident narrative with verifiable date and named system.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with overall enterprise risk management. It references the NIST Cybersecurity Framework (a recognized standard) but provides no firm-specific details regarding implementation, organizational structure, dates, or named entities.


reasoning: Paragraph focuses on the Audit Committee's oversight responsibilities, including its appointment by the Board, specific director training credentials, and the CISO's reporting relationship. Contains two hard verifiable facts: specific headcount (two directors) and named third-party entity (NACD/Carnegie Mellon CERT program), meeting the Quantified-Verifiable threshold.


reasoning: Paragraph describes the company's internal cybersecurity risk management processes—including risk identification, monitoring, mitigation, and remediation activities—and the organizational structure supporting them (Management and Principal Accounting Officer overseeing programs). While Board and Audit Committee oversight are mentioned, the focus is on operational processes rather than governance cadence or a specific individual's qualifications. Contains one specific verifiable fact: the Audit Committee composition (100% independent directors).


reasoning: The paragraph centers on vendor oversight, due diligence processes for third-party service providers, and contractual requirements for vendors to adhere to security standards, making Third-Party Risk the appropriate classification. It contains no specific details such as named vendors, dates, dollar amounts, recognized frameworks, or cybersecurity-specific roles, rendering it generic boilerplate applicable to any company.


reasoning: The paragraph centers on the Information Security Officer as the grammatical subject, detailing their specific cybersecurity title, tenure ('over a decade'), and reporting line to the Board, which aligns with Management Role. It is Firm-Specific due to the named cybersecurity-specific role and experience details, though it lacks the specific dates, dollar amounts, or named third parties required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal incident response plan and procedures (detection, analysis, containment, recovery), which falls under Risk Management Process. It contains only generic descriptions of standard cybersecurity practices without naming specific frameworks, dates, tools, or qualified cybersecurity-specific roles (e.g., CISO), making it applicable to any company.


reasoning: The paragraph describes the company's internal employee training and phishing awareness programs as part of its cybersecurity risk management processes. It contains no specific dates, dollar amounts, headcounts, named roles (e.g., CISO), named third-party firms, or unique program identifiers that would distinguish it from generic security awareness disclosures applicable to any company.


reasoning: The paragraph focuses on the qualifications, tenure, and career history of a specific cybersecurity management role (VP of IT), fitting the Management Role category under the person-vs-function test. It provides firm-specific details including the specific title and experience duration, but lacks two countable hard facts (dates, dollar amounts, headcounts, percentages, or named third-party firms/products) required for Quantified-Verifiable status.


reasoning: This paragraph is a pure cross-reference directing readers to the Risk Factors section (Item 1A) for materiality assessments. It contains no standalone materiality conclusion, incident description, or substantive cybersecurity disclosure—only a pointer to where such information is located elsewhere in the filing.


reasoning: The paragraph describes Management's oversight of internal cybersecurity risk management activities, including charter adoption, policy reviews, and Board reporting, which are core risk management processes. It contains no specific titles (e.g., CISO), dates, frameworks, team compositions, or quantifiable details—only generic references to 'Management,' 'the Board,' and 'periodic' activities that could apply to any company.


reasoning: The paragraph identifies the CISO by name (Casey O'Malley) and provides detailed qualifications, career history, and education, which focuses on the management role rather than just processes. While board oversight is mentioned, the detailed description of the CISO and specific management teams (Information Security Governance, Cybersecurity Risk Management, Incident Response) makes management roles the primary subject.


reasoning: Paragraph describes internal processes (monitoring, audits, penetration testing, incident response planning) rather than the CIO's personal qualifications or reporting structure. The paragraph passes the person-vs-function test: it would still make sense if the CIO title were removed. Naming the cybersecurity-specific role of 'CIO' makes it Firm-Specific, but there are no dates, dollar amounts, named third-party firms, or tools to reach Quantified-Verifiable.


reasoning: The paragraph describes an actual 2019 cybersecurity incident (wire fraud via compromised employee email and unauthorized bank transfer), including the attack vector, scope, and post-incident response actions (MFA implementation). This meets the Incident Disclosure criteria. The specific date (2019) and detailed incident narrative make it Firm-Specific, though it lacks two hard verifiable facts (e.g., dollar amounts, named third-party firms) required for Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident including the year (2024), the attack vector (employee email account), and specific impact (fraudulent diversion of funds), which qualifies as Incident Disclosure. It contains one hard verifiable fact (the date 2024) and firm-specific details about the incident scope, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the specific qualifications, expertise, patents, and educational background of an individual executive, making it about the person rather than the function. It identifies the specific cybersecurity leadership title and the university attended, which are firm-specific details.


reasoning: The paragraph constitutes a standalone materiality assessment concluding that cybersecurity threats did not materially affect the company in 2024, which falls under Strategy Integration per the guidelines (materiality disclaimers without incident narratives). The reference to '2024' provides a specific temporal fact that distinguishes this disclosure from generic boilerplate, making it Firm-Specific.


reasoning: The paragraph describes the board of directors' responsibility for cybersecurity risk oversight and mentions the audit committee's role in this function, with board/committee as the grammatical subjects. It contains only generic governance references (board of directors, audit committee, executive officers) without specific frameworks, dates, named roles, or quantifiable details that would identify it as unique to this company.


reasoning: The paragraph primarily addresses the company's cybersecurity risk management posture, explicitly stating the lack of a formal program while describing informal internal processes (CEO and Interim CFO addressing incidents, reporting to the full board). While it mentions management roles and board oversight, the focus is on the company's risk management framework and processes. The reference to 'fiscal year 2023' provides a specific temporal anchor for the materiality assessment, making the disclosure firm-specific rather than generic boilerplate.


reasoning: The paragraph identifies a specific management individual (R. LaDuane Clifton, CFO) as responsible for cybersecurity risk management and details the IT staff's combined experience (40 years), making Management Role the primary category under the person-vs-function test. While Board activities are mentioned, the specific management qualifications and named role serve as the substantive disclosure. Specificity is Firm-Specific due to the named individual and quantified experience metric, though only one hard verifiable fact (40 years) is present, falling short of the Quantified-Verifiable threshold.


reasoning: The paragraph focuses on the qualifications, tenure, and professional credentials of specific cybersecurity leadership roles (CDIO and CISO), falling under Management Role. It meets Quantified-Verifiable specificity by providing exact durations of experience ('over 25 years') for both roles and naming five distinct professional certifications (CISSP, CISM, CRISC, CEH, PCI DSS ISA), which are verifiable hard facts.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight of cybersecurity risk, with the Audit Committee as the grammatical subject. It contains only generic references to the standard Audit Committee and unspecified management roles without naming specific frameworks, dates, or cybersecurity-specific titles.


reasoning: The paragraph focuses on describing the implementation of additional safeguards since the identification of prior incidents, which constitutes an internal risk management process rather than a detailed incident narrative. It contains two specific, independently verifiable dates (June 30, 2023 and September 30, 2023) referencing the quarters of prior disclosures, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal incident management processes and specific reporting lines to senior management. While it includes a materiality disclaimer, the primary focus is on the procedural aspects of incident response (who receives reports). The mention of 'GxP Systems Director' and 'Vice President of Regulatory and Quality Assurance' provides firm-specific organizational detail not found in generic filings.


reasoning: The paragraph focuses on the identification and qualifications of specific management personnel (CTO and Head of Technology Infrastructure), including their specific years of experience and career backgrounds, which constitutes discussion of the persons rather than just their functions. While the C-ROC committee is mentioned, the detailed description of management expertise and leadership structure is the primary content.


reasoning: The paragraph describes the company's internal escalation procedures for cybersecurity incidents (monitoring, evaluation, and escalation to the CISO and senior leadership), which constitutes a risk management process. It mentions the CISO, a cybersecurity-specific title, making it Firm-Specific, but contains no dates, dollar amounts, or other hard verifiable facts required for Quantified-Verifiable.


reasoning: Paragraph describes the company's internal cybersecurity processes (risk assessments, security team responsibilities, incident response planning, and third-party risk management). While it mentions a 'security team' and 'incident response personnel,' these are generic functional descriptions rather than specific titles (e.g., CISO) or named entities. No frameworks (NIST, ISO), dates, headcounts, dollar amounts, or named vendors/products are disclosed.


reasoning: Paragraph describes the company's incident response plan and internal notification/escalation procedures. While it mentions the CISO and board reporting, the grammatical focus is on the plan's operation (process), not the board's oversight activities or the CISO's personal qualifications. The mention of the CISO role provides one firm-specific detail, but there are no dates, dollar amounts, or other hard verifiable facts to reach Quantified-Verifiable.


reasoning: The paragraph focuses on the qualifications, tenure, and educational background of the Chief Digital Information Officer (a cybersecurity-specific management role), making the individual the grammatical subject. It contains specific quantitative details (27 years) and identifying information (university name, degree) that are unique to this disclosure, but only one hard verifiable fact (the duration), placing it at Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph provides only a generic, forward-looking statement about the importance of cybersecurity to commercial success without substantive disclosure of specific governance structures, management roles, risk management processes, or strategic details. It contains no named entities, frameworks, dates, or quantifiable information that would distinguish this disclosure from any other company.


reasoning: The paragraph identifies the SVP, Head of Legal and Compliance as the management position responsible for cybersecurity risk mitigation and incident response, and details their reporting line to the Audit Committee. However, it contains only generic governance elements—standard committee names (Audit Committee), vague cadences ('quarterly'), and generic C-suite titles (SVP)—without specific dates, named frameworks, cybersecurity-specific roles (e.g., CISO), or other firm-specific details.


reasoning: The paragraph focuses on the Board's oversight function, with the Board as the grammatical subject receiving reports from a specific 'cybersecurity committee.' The identification of a non-generic committee dedicated to cybersecurity (distinct from a standard Audit Committee) provides a firm-specific fact, though the absence of specific dates, headcounts, or named third parties prevents a Quantified-Verifiable classification.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessments, policy development, incident response planning, and compliance oversight) rather than identifying specific management personnel or their qualifications. Despite referencing 'management,' the content focuses on functional activities, not individual roles. It contains no specific dates, frameworks, titles (e.g., CISO), or verifiable facts, consisting entirely of generic responsibilities applicable to any organization.


reasoning: The paragraph describes the company's internal cybersecurity processes (detection, assessment, classification, response, and reporting) managed by the CIRT. While specific management roles are identified, the grammatical focus is on the team's functional responsibilities rather than personal qualifications or reporting lines, satisfying the Person-vs-Function test for Risk Management Process. Specificity is Firm-Specific due to the named internal program (CIRT), the specific multi-role leadership structure, and the quantified experience level (over 20 years), though it lacks the two hard verifiable facts (dates, dollars, headcounts, third-party firms, or tools) required for Quantified-Verifiable.


reasoning: This paragraph is a pure cross-reference directing readers to the Risk Factors section, containing no substantive disclosure about the company's cybersecurity governance, processes, incidents, or strategy. As a cross-reference with no materiality conclusion or operational details, it falls under None/Other and automatically receives Generic Boilerplate specificity.


reasoning: The paragraph describes the qualifications, career history, educational backgrounds, and professional certifications of specific cybersecurity and technology management personnel (CIO, Director of Cyber Security, Director of Technology Compliance), making it about the persons rather than organizational processes. It contains multiple hard verifiable facts including specific durations of experience (e.g., 'over 30 years', '12 years') and named professional certifications (CISSP, CISA) that exceed the threshold for Quantified-Verifiable.


reasoning: The paragraph provides a materiality assessment stating that cybersecurity threats and previous incidents have not materially affected the company, which falls under Strategy Integration per the guidelines (materiality disclaimers without incident narrative). It contains only generic boilerplate language with no specific dates, roles, frameworks, or quantified details that would identify it as unique to Fortive.


reasoning: The paragraph describes the Board's oversight of cybersecurity risk and receipt of incident updates, with the Board as the grammatical subject. It lacks specific details such as named committees, cybersecurity-specific roles (e.g., CISO), dates, or frameworks, consisting entirely of generic governance language applicable to any company.


reasoning: The paragraph describes the reporting line and responsibilities of a management role (Vice President of Corporate Development & Administration) to the board on cybersecurity matters. It contains no specific dates, quantified metrics, named frameworks, or cybersecurity-specific titles (e.g., CISO), rendering it generic boilerplate applicable to any company.


reasoning: The paragraph provides a narrative of a specific phishing scam incident that occurred in 2024, including the impact (financial loss) and response actions (additional cybersecurity procedures and new checking accounts). This constitutes an incident disclosure rather than just a materiality assessment, as it describes what happened rather than merely stating the financial or strategic impact. The specific year 2024 serves as a firm-specific fact, though the lack of specific dollar amounts, exact dates, or named entities prevents it from reaching Quantified-Verifiable status.


reasoning: Paragraph describes the company's internal incident response procedures, monitoring capabilities, and escalation protocols. While the third-party firms are unnamed and the procedures are standard, the specific enumeration of departments comprising the cross-functional response teams constitutes a firm-specific organizational detail.


reasoning: The paragraph describes the involvement of specific management positions (CFO, COO, Controller, Director of Finance) in cybersecurity communications and their reporting lines to the CEO and Audit Committee. All mentioned titles are generic roles standard across companies, with no cybersecurity-specific titles, named frameworks, dates, or unique organizational details provided.


reasoning: The paragraph's grammatical subject is the 'information security program,' and the text focuses on the program's design, objectives (confidentiality, integrity, availability), and control implementation to identify threats and detect attacks—characteristics of Risk Management Process. While the CISO and reporting structure are mentioned, they provide context for who leads the process rather than focusing on the individual's personal qualifications or background. Specificity is Firm-Specific because it identifies the cybersecurity-specific CISO role, the specific reporting line to the GCSO, and cites specific experience qualifications, but it lacks two hard verifiable facts (e.g., specific dates, dollar amounts, headcounts, or named third-party firms/products) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity risks and its incident response plan, including escalation procedures and post-incident remediation. While it mentions the Information Security Officer, the focus is on what the function does (monitoring, reporting, assessing) rather than the person's qualifications or background, making this a process description rather than a management role disclosure.


reasoning: The paragraph describes the Company's internal cybersecurity processes, including risk management, access controls, and annual assessment procedures, which aligns with Risk Management Process. It contains two hard verifiable facts—named third-party firms AON, plc and Netdiligence—meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph identifies the Chief Information Officer (CIO) as the specific management role responsible for cybersecurity, including their qualifications (20 years experience) and detailed responsibilities. The mention of professional tenure qualifies this as management-focused under the person-vs-function test.


reasoning: The paragraph describes the company's internal process for briefing the audit committee on cybersecurity matters, including threat assessments, incident reporting, and compliance updates. While management is mentioned as the actor, the focus is on the function and process rather than specific management roles, qualifications, or reporting lines. The content contains no firm-specific details—no named frameworks, specific dates, dollar amounts, cybersecurity-specific titles (e.g., CISO), or named third parties—and could apply to any company.


reasoning: The paragraph's grammatical subject is the EROC (Enterprise Risk Oversight Committee), describing its oversight of the ERM process and receipt of cybersecurity reports, which falls under Board Governance. The disclosure identifies the specific committee name 'EROC' rather than using generic terms like 'the Board' or 'Audit Committee', making it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity processes, including the Incident Response Team's composition, monitoring activities, and coordination with various committees. It focuses on operational risk management functions rather than individual management qualifications or board oversight as the primary subject.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risk management policies, fitting the Board Governance category where a board committee is the grammatical subject. It contains only generic references to standard governance bodies and activities without naming specific frameworks, roles, dates, or other verifiable facts, rendering it generic boilerplate.


reasoning: The paragraph describes a specific real-world cybersecurity incident involving a third-party vendor (Change Healthcare), including details of what happened (threat actor gained access), operational impact (disruption to EXOGEN device claims and billing/collections), and response actions (engaging an alternative intermediary). It contains two or more independently verifiable hard facts: named third-party firms (Change Healthcare, UnitedHealth Group) and a named product (EXOGEN device).


reasoning: The paragraph describes internal risk management processes including management-level cybersecurity committees, escalation procedures to the Non-Financial Risk Committee, and reporting structures by the CIO and Head of Operational Risk to various risk committees. While board committees are mentioned as recipients of reports, the grammatical subjects are the management committees and risk escalation processes, not the board itself, fitting Risk Management Process rather than Board Governance.


reasoning: The paragraph describes the company's internal processes for risk assessment, safeguard implementation, and monitoring effectiveness. While it mentions an IT consultant and reporting lines to the IT Manager and COO, it focuses on the functional process (what the program does) rather than personal qualifications or background, and contains no named entities, dates, frameworks, or specific details unique to Precipio.


reasoning: Paragraph describes the company's internal risk assessment program and policies for overseeing third-party providers, including annual datacenter audits and vendor reviews through the Sarbanes Oxley process. While vendor oversight is discussed, it is framed as a component of the company's overall risk management process rather than the central topic. The disclosure names recognized standards (SOX, SSAE-16) but contains no firm-specific details such as named vendors, dates, or quantified metrics.


reasoning: The paragraph describes governance structures responsible for cybersecurity oversight, naming the specific 'Enterprise Risk Management Committee' (a non-generic committee per the IS list), which indicates firm-specific governance details rather than generic boilerplate.


reasoning: The paragraph references past cyber incidents but focuses primarily on describing the implementation of 'additional safeguards' designed to prevent future cybersecurity events, which falls under the company's internal risk management processes rather than incident disclosure. The inclusion of two specific, verifiable dates (June 30, 2023 and September 30, 2023) referencing prior reporting periods satisfies the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the reporting lines and cadence of the CISO and senior management to the Audit Committee and Board. The CISO serves as the grammatical subject, and the disclosure focuses on management's reporting responsibilities rather than board oversight processes or operational risk management activities. The presence of the cybersecurity-specific title 'CISO' makes this Firm-Specific.


reasoning: The paragraph describes the company's internal processes for overseeing cybersecurity risks and updating stakeholders on the cyber program, fitting Risk Management Process. It contains only generic references to CEO, management, and Board oversight with standard cadences ('at least annually'), lacking any firm-specific details, named frameworks, or verifiable facts.


reasoning: The paragraph describes the company's internal governance structure for risk management—the cross-functional Information Security Steering Committee (ISSC)—and identifies the specific functional departments involved in assessing and managing cybersecurity risks. This focuses on internal risk management processes rather than board oversight, specific incidents, or third-party vendor management. While it contains firm-specific details including the named committee, specific departmental composition, and reference to LMC, it only provides one hard verifiable fact (named third-party firm LMC), falling short of the two required for Quantified-Verifiable status.


reasoning: The paragraph describes the company's internal process of re-examining systems following risk assessments and continuously evaluating cybersecurity risks. While it mentions the head of the IT department, the focus is on the function (evaluating risks, ensuring safeguards) rather than the individual's qualifications or credentials, and the role lacks a specific cybersecurity title (e.g., CISO, CIO) or unique identifying details.


reasoning: The paragraph describes the company's internal cybersecurity controls and defense-in-depth strategy, listing standard security domains such as vulnerability management, access control, and incident response. While it references an 'ISP' (Information Security Program), this is a generic designation rather than a uniquely named program, and the control categories listed are standard industry practices without naming a specific framework (e.g., CIS, NIST) or providing firm-specific implementation details, dates, metrics, or roles.


reasoning: Paragraph describes an actual ransomware attack in late May 2023 affecting certain systems, including specific response actions (investigation, engaging experts, law enforcement coordination), which fits Incident Disclosure. It contains a specific date (month+year), making it Firm-Specific, but lacks a second hard verifiable fact (named firm, dollar amount, etc.) required for Quantified-Verifiable.


reasoning: The paragraph describes the integration of cybersecurity risk assessment into the company's broader enterprise risk management framework and references an incident response plan as part of this process. It contains no named frameworks, specific dates, dollar amounts, cybersecurity-specific roles, or other distinguishing details that would identify this as specific to Cidara Therapeutics.


reasoning: The paragraph describes the company's internal cyber risk management program and processes, including oversight administration, use of third-party service providers, and threat intelligence sources. While management is mentioned as responsible for these activities, the focus is on the functional processes rather than specific cybersecurity leadership roles (CISO/CTO/CIO) or board governance structures.


reasoning: The paragraph focuses on the management team's responsibilities for cybersecurity risk management and describes their prior work experience and expertise, fitting the Management Role category. It contains no specific titles (e.g., CISO, CTO), named third-party firms, dates, or quantifiable metrics—only generic references to 'management team,' 'cybersecurity personnel,' and 'external consultants'—rendering it generic boilerplate.


reasoning: The paragraph focuses on the CIO as the grammatical subject, detailing their reporting lines, meetings with the Audit Committee, and prior work experience/qualifications, which fits the Management Role category. It contains at least one firm-specific fact (the cybersecurity-specific title 'CIO') but lacks two hard verifiable facts (dates, dollar amounts, headcounts, percentages, named third-party firms, or named tools) required for Quantified-Verifiable.


reasoning: Paragraph describes board and Audit Committee oversight of cybersecurity risks, including briefing cadences from management. Contains no specific frameworks, dates, numbers, or named entities beyond generic governance terms (Board, Audit Committee, CEO) that apply to any company.


reasoning: The paragraph describes the company's internal risk assessment processes, framework adoption (NIST), and program maturity evaluations, which falls under Risk Management Process. While it names the NIST Framework (a recognized standard), it lacks firm-specific details such as named third-party assessors, specific evaluation dates, or unique program identifiers, making it Sector-Adapted rather than Firm-Specific.


reasoning: The paragraph focuses primarily on board and audit committee oversight mechanisms, including the adoption of a specific cybersecurity policy, briefing cadences, and director expertise, with secondary mention of the CTO's reporting lines and qualifications.


reasoning: The paragraph describes the board of directors' oversight responsibilities and reporting cadence regarding cybersecurity, with the board as the grammatical subject throughout. It contains only generic references to the board, management, and quarterly/semi-annual reporting without naming specific committees, dates, frameworks, or quantified details, rendering it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal security governance structure and processes for evaluating cybersecurity risks. While the CEO and CFO are mentioned as actors, the focus is on their functional activities (consulting, developing strategies) rather than their personal qualifications, reporting lines, or tenure. The Board and Audit Committee are mentioned only as providing oversight, not as the grammatical subjects. The text contains no specific dates, dollar amounts, named third-party firms, cybersecurity-specific roles (e.g., CISO), or recognized frameworks, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes including vulnerability management, employee training, incident response planning, and third-party risk management. However, it lists only generic security practices (penetration testing, phishing simulations, tabletop exercises) without naming specific frameworks, tools, dates, headcounts, or third-party firms, making it applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessments, disaster recovery testing, vulnerability scanning, and integration with ERM, with no mention of the board, specific management roles, or actual incidents. It contains no named frameworks, tools, dates, numbers, or specific roles, using only generic language like 'external advisors,' 'every year,' and 'established frameworks' that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk mitigation processes, including access controls and system architecture. It contains multiple specific headcounts (9 employees, 6 full-time, 3 part-time, 3 with access, 1 consultant) that meet the threshold of two or more hard verifiable facts for Quantified-Verifiable classification.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity affecting online ordering in Q4 fiscal 2024) with multiple independently verifiable hard facts including specific dollar amounts ($3M remediation, $11M lost revenue, $10M EBITDA impact) and dates (December 11, 2024 8-K filing).


reasoning: The paragraph describes the oversight responsibilities of the DPIRC and Enterprise Risk Committee regarding cybersecurity policies, risk posture, and incident response capabilities, and notes that the Enterprise Risk Committee receives quarterly updates from the CISO. As board/committee entities are the grammatical subjects performing oversight functions, this is Board Governance. The disclosure includes specific non-generic committee names (DPIRC, Enterprise Risk Committee) and the CISO title, making it firm-specific.


reasoning: The paragraph focuses on management structures, specifically identifying the CISO and a dedicated Risk Committee chaired by the CISO, along with their responsibilities and reporting lines to the Audit Committee. While board oversight is mentioned, the detailed description centers on management roles rather than board processes. The disclosure contains firm-specific elements by naming the cybersecurity-specific role (CISO) and a non-generic committee (Risk Committee), but lacks hard verifiable facts like dates, dollar amounts, or headcounts needed for Quantified-Verifiable.


reasoning: The paragraph contains a materiality disclaimer stating that cybersecurity threats, if realized, are 'reasonably likely to materially affect' the company, which per the tiebreaker rules maps to Strategy Integration. It offers no specific details about the company's actual risk management processes, governance structure, or incidents, and contains only generic forward-looking cautionary language and a cross-reference to Risk Factors.


reasoning: The paragraph describes the company's internal cybersecurity assessment processes (Internal Audit reviews, independent third-party reviews, and regulatory examinations) with the Cybersecurity Program as the grammatical subject. It identifies specific organizational entities—the Morgan Stanley Internal Audit Department (IAD) and the committee acronym BOTC—which qualify as firm-specific details, though it lacks quantifiable data like dates, dollar amounts, or named third-party firms that would be required for Quantified-Verifiable.


reasoning: The paragraph identifies the Chief Information Security Officer (CISO) as the grammatical subject of the primary sentence and details their reporting line to the Audit Committee, including reporting frequency and scope. While the Audit Committee's briefing cadence is mentioned, the detailed focus on the CISO's specific reporting responsibilities and duties makes Management Role the appropriate classification.


reasoning: The paragraph primarily describes the company's internal information security program, including specific technical controls (firewalls, intrusion prevention, endpoint detection, etc.) and organizational structures for implementing these processes. While it mentions management titles (Chief Security & Cash Operations Officer, Chief Compliance Officer), the focus is on what the security function does rather than the personal qualifications or backgrounds of the individuals, placing it under Risk Management Process per the person-vs-function test. It contains firm-specific elements including the cybersecurity-specific title 'Chief Security & Cash Operations Officer' and the named department 'Global Information Security organization', but lacks quantified data (dates, dollar amounts, headcounts) or named third-party firms/tools required for Quantified-Verifiable.


reasoning: The paragraph provides general business context about technology dependence and data assets but discloses no substantive information about governance structures, management roles, risk management processes, or strategic integration. It serves as introductory background material that could apply to any technology-dependent company without revealing specific cybersecurity practices or organizational details.


reasoning: Paragraph describes specific management roles (CIO, Senior Directors, Architect), their reporting structure, and their qualifications/experience (years of experience, CISSP certification), fitting the Management Role category focused on the persons rather than processes. Contains specific cybersecurity titles and experience metrics that identify this company's disclosure.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk identification, incident response coordination, policy assessment) performed by management, making it Risk Management Process. It is Firm-Specific because it names the 'Cybersecurity Committee' (a non-generic committee) and identifies the specific executive role ('Executive Vice President, Administration') directing these activities.


reasoning: The paragraph focuses on Board oversight of cyber risk and the specific Risk Committee's responsibilities for enterprise risk management and materiality determinations, placing it in Board Governance. It identifies a specific 'Risk Committee' (a named non-generic committee) but contains no quantifiable data, dates, or hard verifiable facts.


reasoning: Paragraph describes the company's internal processes for cybersecurity risk assessment, monitoring, and mitigation, with management responsible for establishing these processes. While the Board and Audit Committee are mentioned as recipients of updates, the substantive focus is on the risk management functions performed by management. The disclosure contains no specific dates, named cybersecurity-specific roles (only the generic CEO), named frameworks, or other identifying details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity incident response escalation procedures and reporting mechanisms, which falls under Risk Management Process. However, it contains only generic references to standard roles (CFO, Audit Committee, legal department) and boilerplate policy descriptions without naming specific frameworks, dates, quantifiable metrics, or firm-unique details.


reasoning: The paragraph describes a specific historical cybersecurity incident (May 2020 ransomware attack), including the date, attack vector, and scope (data removed from self-hosted environment), which meets the criteria for Incident Disclosure. It contains one hard verifiable fact (May 2020) and specific details about the incident's nature, making it Firm-Specific rather than Generic Boilerplate, but lacks a second hard fact (such as dollar amounts, specific percentages, or named third-party firms) required for Quantified-Verifiable.


reasoning: The paragraph enumerates the company's internal cybersecurity processes and organizational safeguards (monitoring, vulnerability scans, incident response plans, training programs) without referencing specific incidents, board oversight, or individual management roles. It contains no named frameworks (e.g., NIST, ISO), specific dates, dollar amounts, headcounts, named tools (e.g., Splunk, CrowdStrike), or named third-party firms, and relies entirely on generic security practices and standard program names (e.g., 'incident response plans,' 'vendor risk management program') that could apply to any company.


reasoning: The paragraph focuses on board committee oversight of cybersecurity risks, with the Board and specific committees (Audit Committee, Technology and Innovation Committee, and Governance Committee) as the grammatical subjects. The identification of non-standard committees like the 'Technology and Innovation Committee' elevates this beyond generic boilerplate to firm-specific disclosure.


reasoning: The company explicitly states it is a SPAC with no business operations and has not adopted any cybersecurity risk management program or formal processes. Per classification rules, SPACs explicitly stating they have no operations or cybersecurity program are categorized as None/Other regardless of incidental mentions of board oversight. As a None/Other paragraph, it automatically receives Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal incident response and vulnerability management procedures, including escalation protocols to management and reporting mechanisms to the board. While it references specific roles (CISO) and a board committee, the grammatical focus is on the processes themselves ('processes are designed to,' 'processes include reporting') rather than the qualifications of management or the oversight activities of the board.


reasoning: The paragraph describes the company's internal processes for risk identification and assessment using automated tools and audits. It identifies a specific cybersecurity role (chief information consultant), which distinguishes it from generic boilerplate, but lacks hard verifiable facts like dates, dollar amounts, or named vendors required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including integration with ERM, adoption of industry frameworks, and engagement of consultants to test the security program. The mention of a 'Cybersecurity Committee' (a non-generic board committee) provides a firm-specific detail that distinguishes this from generic boilerplate.


reasoning: Paragraph identifies the CIO and details their specific tenure and qualifications, along with the Strategy Committee Chair's unique government cybersecurity background. The focus is on the persons and their credentials rather than processes or board oversight functions, satisfying the Person-vs-Function test for Management Role.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CTO and Senior Director, Information Security) and details their personal qualifications, tenure, and career history, satisfying the Person-vs-Function test for Management Role. It meets the Quantified-Verifiable threshold through multiple hard facts: specific durations of experience (15 and 20 years) and named third-party firms (Ticketmaster, Sony Pictures, Warner Bros).


reasoning: Paragraph describes the company's internal cybersecurity processes, including the Incident Response Team structure, incident monitoring activities, and coordination mechanisms with various committees. While the CISO and CIO are mentioned, the focus is on organizational functions and processes rather than individual qualifications or reporting lines as the primary subject.


reasoning: Paragraph focuses on specific cybersecurity management roles (Director of IT and third-party CISO), their qualifications, reporting lines, and precise experience levels (30 and 21 years). The two specific durations satisfy the quantified-verifiable threshold.


reasoning: The paragraph focuses primarily on the Sustainability & Safety Committee's oversight of cybersecurity risk beginning in 2025, including the transition from full Board oversight and specific briefing cadences. While it identifies the CIO and their qualifications, the board and committee serve as the grammatical subjects for the majority of the sentences, emphasizing governance structure over management functions.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including framework adoption (NIST), cross-departmental risk assessment, ERM integration, and specific internal policies and programs. While the Board and committees are mentioned, the focus is on operational processes and systems rather than governance structure or individual management qualifications.


reasoning: The paragraph identifies specific management positions responsible for cybersecurity oversight (Head of Security, Head of Global Privacy, Head of Enterprise Technology & IT) and describes their roles in risk assessment and incident response, fitting the Management Role category. The disclosure of these specific cybersecurity-related titles and the cross-functional team composition constitutes firm-specific detail.


reasoning: The paragraph assigns Board Governance as the primary category because the Board of Directors serves as the grammatical subject in key sentences describing oversight authority and specific briefing cadences (semiannual updates from the CISO and CIO). While the paragraph also references management roles and internal risk processes, the central focus is on the Board's governance function and the reporting structure to the Board. The specificity is Firm-Specific due to the identification of cybersecurity-specific executive titles (CISO and CIO) and the specific briefing cadence (semiannual), though no quantifiable metrics or dates are present to reach Quantified-Verifiable.


reasoning: The paragraph focuses on identifying specific cybersecurity leadership roles (CISO, CRO), their reporting lines to the Board, the CISO's detailed qualifications (15 years experience, CISSP certification, prior roles), and the specific composition of the Enterprise Risk Committee. While risk management processes are mentioned, the specific, unique details center on the people, their credentials, and organizational structure, fitting the Management Role category per the person-vs-function test.


reasoning: The paragraph describes the company's internal cybersecurity governance process, specifically the role of the Bank Technology Governance Committee in approving policies and receiving threat monitoring reports. While it identifies specific cybersecurity roles (CIO, Director of Information Security), the focus is on the committee's function and reporting structure rather than individual qualifications, satisfying the Person-vs-Function test for Risk Management Process. It contains firm-specific details including the named committee and cybersecurity-specific titles.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and team structure, focusing on what the Cybersecurity Team does (maintains programs, monitors trends, oversees training) rather than individual qualifications or board oversight. It identifies a cybersecurity-specific title (CTO) and provides a detailed team composition, satisfying the firm-specific threshold.


reasoning: The paragraph describes the company's internal cybersecurity program, including controls, monitoring, employee training, and vendor risk policies, which falls under Risk Management Process. However, it lacks specific details such as named frameworks (NIST, ISO), specific management titles (CISO, CIO), named third-party firms, dates, or quantifiable metrics, making it generic boilerplate that could apply to any company.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight responsibilities for cybersecurity risk, including delegation of duties and briefing cadences. While CIO and CISO are mentioned, they appear as objects briefing the committee rather than as the primary subject, and the disclosure emphasizes governance structure over management qualifications.


reasoning: The paragraph focuses on the CISO's personal qualifications, career history, and certifications, making it about the management role rather than processes. It contains a specific duration (20 years) and multiple named industry certifications (CISSP, CISM, PCI), which per the calibration example qualifies as Quantified-Verifiable.


reasoning: The paragraph is a standalone materiality conclusion stating that no cybersecurity incidents have materially affected the company, which falls under Strategy Integration per the tiebreaker rules. It meets the Quantified-Verifiable threshold by providing two specific dates (December 31, 2024 and January 2018) that serve as hard, externally verifiable facts defining the temporal scope of the assessment.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessments, monitoring, threat detection, penetration testing) without referencing a specific incident, board oversight, or management roles. It names specific regulatory bodies (FFIEC, FDIC, UDFI) that provide the guidance for these processes, which distinguishes it from generic boilerplate, but lacks the hard verifiable facts (dates, numbers, named consulting firms) required for Quantified-Verifiable.


reasoning: The paragraph identifies specific management positions (Chief Risk Officer and CISO) and describes their cybersecurity oversight responsibilities and working relationship, making Management Role the appropriate category. It contains firm-specific facts including the specific year (2024) and the cybersecurity-specific title (CISO), but lacks the two hard verifiable facts (e.g., specific dates with month/year, dollar amounts, headcounts) required for Quantified-Verifiable.


reasoning: The paragraph contains generic statements about cybersecurity importance and threat types (ransomware, phishing) without substantive disclosure regarding board oversight, management roles, specific internal processes, vendor oversight, actual incidents, or strategic integration. It serves as introductory risk context that could apply to any company.


reasoning: The paragraph describes internal risk assessment and cost estimation processes for security risk mitigation, which falls under Risk Management Process. It contains no named frameworks, specific dates, dollar amounts, roles, or other identifying details that would distinguish it from any other company's disclosure, making it Generic Boilerplate.


reasoning: The paragraph identifies specific cybersecurity management roles (CIO, Senior Director of Information Security) and provides detailed qualifications for the CIO (15 years experience, specific degree), making management roles the grammatical subject and primary focus per the person-vs-function test. It also establishes a specific management committee (Cybersecurity Infrastructure Committee) and its meeting cadence.


reasoning: The paragraph provides detailed biographical and qualification information about specific cybersecurity and IT leadership roles (CISO, CTO, Head of IT Infrastructure), including specific years of experience, named professional certifications (CISA, CRISC, Series 99), and specific academic degrees, meeting the threshold for Quantified-Verifiable with multiple hard facts.


reasoning: Paragraph discusses potential business and financial impacts of future cyber-attacks, materiality considerations, and compliance costs without describing internal processes or specific incidents. Contains no named entities, frameworks, dates, or quantifiable details applicable only to this company.


reasoning: The paragraph provides biographical details about an executive's career history and current role overseeing communications, franchising, and ESG initiatives, but contains no mention of cybersecurity responsibilities, risk management, or information security governance.


reasoning: The paragraph focuses exclusively on vendor oversight as the central topic, describing the Vendor Risk Management Program, Policy, and onboarding/review processes. It names the Interagency Guidance on Vendor Relationships, a recognized regulatory framework, but contains no firm-specific details such as specific dates, named vendors, or unique team compositions.


reasoning: The paragraph focuses on the Audit Committee's oversight activities, describing its receipt of reports and briefings on cyber risks, management programs, and incidents. While a management role is mentioned, the Audit Committee serves as the grammatical subject of the substantive second sentence detailing oversight functions. No specific facts are present: 'Manager of Information Technology' is not a cybersecurity-specific title (e.g., CISO, CIO), 'Audit Committee' is standard governance, and 'periodically' is a vague cadence without specific dates or quantified details.


reasoning: The paragraph focuses on the qualifications, reporting lines, and credentials of specific management roles (CIO and CISO), satisfying the Management Role category. It meets the Quantified-Verifiable threshold through multiple hard facts: specific durations of experience (30 years, nine years, thirty years) and named professional certifications (CISM, CDPSE, CRISC).


reasoning: The paragraph focuses on the Vista CIO's qualifications, appointment date, and career history, fitting the Management Role category under the person-vs-function test. It meets the Quantified-Verifiable threshold with two hard facts (appointment year 2017 and over 20 years experience) and includes additional firm-specific details like the named DPIRC committee and specific departmental composition.


reasoning: The paragraph provides a detailed narrative of a specific ransomware incident that occurred in March 2020, including the attack vector (access to IT systems), response actions (isolated source, restored operations), and scope of affected data (confidential information, trade secrets, employee personal information), which satisfies the criteria for Incident Disclosure. The inclusion of the specific date March 2020 qualifies as a firm-specific fact, though it does not meet the threshold for Quantified-Verifiable as only one hard verifiable fact is present.


reasoning: The paragraph describes the internal communication process for cybersecurity risks flowing from IT providers to the COO/CFO and subsequently to the Board, which constitutes a risk management process rather than focusing on the specific qualifications of the individuals (Person-vs-Function test). It contains no firm-specific details—COO and CFO are generic C-suite titles, 'information technology providers' is unnamed, 'regularly' is vague, and no dates, numbers, or specific committees are mentioned.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment processes, internal audit procedures, and ISO 27001 certification maintenance. It meets the Quantified-Verifiable threshold with two specific dates ('since 2014', 'December 31, 2024') and a specific numeric quantity ('two additional locations').


reasoning: The paragraph discusses potential business and financial impacts of cybersecurity risks, including material adverse effects on operations, financial condition, and cash flows, as well as reputational harm and regulatory actions. This aligns with Strategy Integration, which covers business/financial impact and materiality assessments without incident narrative. The language is entirely generic, containing no named entities, specific dates, dollar amounts, or firm-specific details that would distinguish it from standard risk disclosure applicable to any company.


reasoning: Paragraph describes the company's Enterprise Risk Council and its risk management activities (identification, assessment, management, monitoring of cybersecurity risk), which constitutes ERM integration. While the CISO is mentioned as a member, the focus is on the council's processes and composition rather than individual qualifications or reporting lines.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including risk identification, third-party assessments, internal IT audits, penetration testing, and employee training. However, it contains no named frameworks (e.g., NIST, ISO), specific dates, named tools or vendors, cybersecurity-specific roles, or quantifiable details that would distinguish it from standard industry practice.


reasoning: The paragraph focuses on the company's internal processes, controls, and technologies for assessing and managing cybersecurity risks, as well as describing the threat landscape and potential operational impacts. While it mentions the Vice President of IT and Board oversight, these are contextual to the risk management framework rather than the primary focus, and no qualifications or personal details are provided for the management role.