reasoning: The paragraph describes the company's incident response plan and notification procedures, which are internal processes for managing cybersecurity risks, rather than focusing on board oversight or management roles.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal cybersecurity processes and measures, such as monitoring, vulnerability scans, and incident response plans, without referencing specific incidents, roles, or unique details, aligning with Risk Management Process and Generic Boilerplate specificity.

provider: xiaomi

stage: benchmark


content_category: Board Governance

reasoning: The paragraph primarily describes the Board of Directors' oversight role and delegation to the Audit Committee, with a brief mention of an employee's day-to-day oversight, fitting Board Governance. It contains no specific facts such as dates, names, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph centers on the EROC committee's oversight of cybersecurity risks, with the committee as the grammatical subject, fitting Board Governance. The named committee EROC is a firm-specific fact.


content_category: Management Role

reasoning: The paragraph identifies specific management roles (Global IT Director, System Infrastructure Manager, Network Infrastructure Manager) leading the Cyber Incident Response Team and their qualifications, which is central to the Management Role category.


content_category: Strategy Integration

reasoning: The paragraph is a materiality assessment concluding no material cybersecurity incidents have affected the business, which aligns with Strategy Integration. It includes two specific dates (assessment date and inception date), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes ADT's internal cybersecurity risk management processes, including the CISO's responsibilities and specific tools like SecurityScorecard and the NIST framework, which fits the Risk Management Process category.


reasoning: The paragraph focuses on the Audit Committee's oversight and reporting structure with the CISO, which is central to Board Governance. The mention of the Chief Information Security Officer role is a cybersecurity-specific title, making it Firm-Specific.


reasoning: The paragraph describes the company's internal organizational structure for managing cybersecurity risks, with committees and management positions responsible for risk assessment and management, aligning with risk management processes.


content_category: None/Other

reasoning: The paragraph is a generic statement about cybersecurity's importance for commercial success with no specific details on governance, processes, roles, or incidents, fitting forward-looking disclaimers or non-substantive content.


content_category: Incident Disclosure

reasoning: The paragraph explicitly describes a cybersecurity incident with specific timing, operational disruptions, and financial impacts, including verifiable dates and dollar amounts.


reasoning: The paragraph focuses on the reporting of cybersecurity threats and incidents to the Audit Committee and Board, which is a key aspect of board oversight and governance.


reasoning: The paragraph describes a specific cybersecurity incident that occurred in October 2023, including details about unauthorized access to user information from 23andMe.com accounts and subsequent response actions, which aligns with the Incident Disclosure category.


reasoning: The paragraph describes the company's internal processes for managing IT systems and third-party reliance, with BD as a specific third party, indicating it is about risk management processes rather than third-party risk oversight or other categories.


reasoning: The paragraph focuses on the Chief Technology Officer's qualifications, experience, and background, which aligns with management role identification rather than board oversight or risk processes.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, such as risk assessment and monitoring, which aligns with Risk Management Process. It names the NIST 800-171 framework, indicating Sector-Adapted specificity, but lacks unique company-specific details.


reasoning: The paragraph centers on the Board of Directors and a named Risk Committee responsible for cyber risk oversight, fitting the Board Governance category. The Risk Committee is a specific, non-generic committee, qualifying as a firm-specific fact.


specificity_confidence: medium

reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk, making Board Governance the appropriate category. The reference to vCIO, a cybersecurity-specific role, provides a firm-specific detail.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, including management roles and specific policies, with no incident description or board oversight emphasis.


reasoning: The paragraph describes the implementation of additional safeguards to detect and prevent cybersecurity events, which is a core component of the company's internal risk management processes. It includes two specific, verifiable dates referencing previous disclosures, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph focuses on the company's internal processes for managing IT and cybersecurity risk through named committees and roles, aligning with Risk Management Process. It includes specific titles and committee names, making it Firm-Specific.


reasoning: The paragraph describes management's process of providing quarterly briefings to the audit committee on cybersecurity topics, which focuses on internal risk management processes rather than specific role identification or incident disclosure. No specific dates, names, or verifiable facts are present, making the content generic and applicable to any company.


reasoning: The paragraph describes the company's cybersecurity risk management processes, including integration into enterprise risk management and oversight by the Cybersecurity Committee, which is a firm-specific detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management process, including specific committees and reporting lines, which aligns with Risk Management Process rather than focusing on board oversight or individual roles.


reasoning: The paragraph centers on the Information Security Officer's role, responsibilities, and qualifications, which aligns with Management Role classification, and it includes firm-specific details such as the cybersecurity-specific title and a specific duration of experience.


reasoning: The paragraph describes the Enterprise Risk Council's role in managing cybersecurity risk, with the CISO as a member, focusing on the company's internal risk management processes rather than individual roles or incidents.


reasoning: The paragraph references previously disclosed incidents with specific report dates and focuses on implementing safeguards to prevent material adverse effects, aligning with business impact and strategy integration rather than incident description or internal process details.


reasoning: The paragraph describes the Board and Audit Committee's oversight activities, including briefings from management and the CTO, which centers on board governance of cybersecurity.


reasoning: The paragraph primarily describes management-level roles and committees, with the CISO and Risk Committee as grammatical subjects, detailing their oversight responsibilities and reporting structure.


reasoning: The paragraph describes a specific past cybersecurity incident (ransomware attack in October 2021) and its material adverse impact, which qualifies as Incident Disclosure under the tiebreaker for describing what happened in an incident.


reasoning: The paragraph describes the company's internal incident response process and materiality assessment, which are core components of risk management, but it uses generic terms like IRT, IRP, and CSC without verifiable details or named standards.


reasoning: The paragraph describes assessment and review processes of the cybersecurity program, which aligns with Risk Management Process. It contains no named frameworks, specific dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph identifies key personnel (CIO and Strategy Committee Chair) and their qualifications, experience, and roles, which aligns with the Management Role category. It contains firm-specific facts such as the CIO's tenure and the Chair's detailed government background, making it Firm-Specific.


reasoning: The paragraph focuses on identifying specific management roles (CTO and Senior Director, Information Security) and their qualifications, which aligns with the Management Role category, and contains firm-specific details like titles and named previous employers.


reasoning: The paragraph describes the company's internal process of risk assessment and management, focusing on how the IT head and management evaluate cybersecurity risks, with no specific dates, names, numbers, or frameworks mentioned.


reasoning: The paragraph focuses on the qualifications and tenure of the CFO, CCO, and CIO, who are management roles responsible for cybersecurity oversight, with specific verifiable facts about their experience and a named firm.


reasoning: The paragraph focuses on the Nominating and Governance Committee receiving reports from the CISO, which is a board-level oversight activity. It includes a cybersecurity-specific title (CISO) and a named committee, making it firm-specific.


reasoning: The paragraph primarily details management roles and qualifications, with specific titles like Chief Digital and Technology Officer and Chief Information Officer, making it Management Role, and it contains firm-specific facts such as experience durations and degrees, thus Firm-Specific.


reasoning: The paragraph describes the qualifications, experience, and credentials of management personnel in cybersecurity-related roles, which is characteristic of Management Role. It includes specific titles like CIO and Director, Cyber Security, along with named certifications, making it Firm-Specific as it contains unique facts about the company's management team.


reasoning: The paragraph describes management's cybersecurity responsibilities under the Executive Vice President, Administration and reporting to the Cybersecurity Committee, focusing on the management role and structure.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including annual assessments and engagements with named third-party firms, which are central to the disclosure.


reasoning: The paragraph describes the company's own internal cybersecurity processes, including risk assessments and monitoring, which aligns with Risk Management Process. It references the FFIEC framework, a recognized standard in financial services, but contains no unique company-specific details, making it Sector-Adapted.


category_confidence: medium

reasoning: The paragraph emphasizes the Board's oversight role with specific update cadences (semiannual from CIO and CISO), making Board Governance the primary category despite mentions of management and processes. It includes cybersecurity-specific titles like CISO and CIO, which qualify as Firm-Specific facts.


reasoning: The paragraph focuses on a management role (Vice President of Corporate Development & Administration) reporting to the board on cybersecurity, which aligns with Management Role. It contains no hard verifiable facts, no cybersecurity-specific title from the defined list, and no named standards, making it Generic Boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, team responsibilities, and incident response coordination, with specific organizational details like the CISO role and named committees.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, team activities, and incident response coordination, which aligns with Risk Management Process, and it includes specific organizational details like the CISO role and team compositions, making it Firm-Specific.


reasoning: The paragraph describes management roles (CIO and senior directors) responsible for cybersecurity, including their qualifications and experience, which aligns with the Management Role category. It contains multiple hard verifiable facts: specific years of experience and a named certification (CISSP), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the Board's oversight of cybersecurity through the Audit Committee and its interaction with a specific management role, fitting Board Governance. It includes a firm-specific role (Director of Information Technology), making it Firm-Specific.


reasoning: The paragraph focuses on the company's internal information security program and methods, including specific management roles in oversight, which aligns with Risk Management Process rather than board governance or incident disclosure.


reasoning: The paragraph centers on the Board delegating cybersecurity oversight to the Audit Committee and the reporting cadence involving CIO and CISO, which is characteristic of Board Governance. The named cybersecurity-specific roles (CIO and CISO) qualify as firm-specific facts.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, focusing on the responsibilities of the DPIRC committee and oversight by the Enterprise Risk Committee, which are firm-specific organizational details.


reasoning: The paragraph primarily describes the CEO's qualifications and executive officers' responsibilities in cybersecurity oversight, with board oversight mentioned briefly, aligning with Management Role. It contains no firm-specific facts such as named roles, dates, or frameworks, making it Generic Boilerplate.


reasoning: The paragraph describes the qualifications, expertise, and background of a specific management role (Chief Security and Cash Operations Officer), which aligns with the Management Role category, and includes firm-specific details like the officer's title and educational institution.


reasoning: The paragraph primarily describes the Chief Technology Officer's qualifications, reporting lines, and oversight role, making Management Role the most applicable category. It includes firm-specific details like the named policy, CTO title, and years of experience, but lacks multiple hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk mitigation processes, such as access control and system separation, which aligns with Risk Management Process. It contains specific headcounts (nine employees, three with access) that are hard verifiable facts, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph primarily details the Vista CIO's experience and appointment, which are core to management role classification, and includes specific verifiable facts such as the appointment year and years of experience.


reasoning: The paragraph describes the company's cybersecurity assessment processes, including external audits and ISO 27001 certification, which are core elements of risk management.


reasoning: The paragraph's grammatical subject is the audit committee, and it describes oversight through reports from the CIO and board reporting under the incident response plan, which aligns with Board Governance.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk oversight and materiality assessment through the Cybersecurity Disclosure Committee and specific team compositions, which aligns with risk management processes rather than board governance or management roles.


reasoning: The paragraph identifies specific management roles (interim Chief Legal Officer and CSO) co-chairing a Cybersecurity Steering Committee, with the focus on their oversight responsibilities, making it Management Role.


content_category: Third-Party Risk

reasoning: The paragraph centers on policies and procedures to oversee cybersecurity risks from third-party service providers, including auditing a core provider, making Third-Party Risk the most applicable category. It names recognized standards (Sarbanes Oxley and SSAE-16) but contains no unique company-specific details, fitting Sector-Adapted specificity.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as intelligence sharing and resource allocation, which aligns with risk management. It contains no named frameworks, hard verifiable facts, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily describes the incident response plan, which is a core element of the company's cybersecurity risk management processes, with a specific date provided for context on a physical incident.


reasoning: The paragraph centers on management roles (CTO and Head of Technology Infrastructure) with their qualifications and responsibilities, fitting the Management Role category, and includes firm-specific details like named roles and years of experience.


reasoning: The paragraph focuses on the qualifications and experience of management roles (Director of Information Technology and third-party CISO), which aligns with the Management Role category. The specific years of experience (30+ and 21) are hard verifiable facts, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph primarily focuses on board oversight, with specific details about the Sustainability & Safety Committee's role, the change in oversight starting in 2025, and reporting cadences, making Board Governance the most applicable category.


reasoning: The paragraph focuses on the qualifications, experience, and certifications of the CDIO and CISO, which are management roles, with specific numerical durations and named certifications that are verifiable hard facts.


reasoning: The paragraph focuses on the CIO's role, qualifications, and reporting structure, with the CIO as the grammatical subject, making Management Role the primary category. It contains firm-specific facts such as the cybersecurity-specific CIO title and a direct reporting line to named executive roles.


reasoning: The paragraph centers on the CISO's qualifications, background, and role, fitting the Management Role category, and includes firm-specific details like the CISO's name and appointment date.


reasoning: The paragraph primarily identifies and describes the Vice President, IT Security, including his qualifications, experience, and certifications, which fits the Management Role category. It contains multiple verifiable hard facts such as years of experience and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the cybersecurity governance structure with the Board and Audit Committee as subjects overseeing risks, fitting Board Governance, and includes multiple verifiable facts about the CISO's background, making it Quantified-Verifiable.


reasoning: The paragraph centers on the CTO's role, including his responsibilities, reporting lines, and personal qualifications, making Management Role the appropriate category. It contains firm-specific details like the CTO's name, background, and previous employers, qualifying as Firm-Specific.


reasoning: The paragraph centers on the Audit Committee directing and overseeing the CIO and SIRT in cybersecurity monitoring and reporting to the Board, with board/committee as key grammatical subjects, fitting Board Governance. The mention of the CIO role provides a firm-specific fact, elevating specificity from Generic Boilerplate.