reasoning: The paragraph focuses on the cybersecurity program's internal processes and interfaces with specific departments, which is core to risk management, and includes a firm-specific list of functional areas.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph centers on the company's internal cybersecurity and risk management processes, including integration into ERM and specific roles like CISO, with no incident disclosure or third-party focus.

provider: xiaomi

stage: benchmark


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, which fits the Risk Management Process category. It contains no specific dates, names, frameworks, or verifiable details, making it generic boilerplate applicable to any company.


content_category: Board Governance

reasoning: The paragraph centers on the Audit Committee's direct oversight and detailed activities regarding cybersecurity, with management roles reporting to it, fitting Board Governance. It includes firm-specific details like named cybersecurity roles and a specific attendee composition, justifying Firm-Specific specificity.


specificity_confidence: medium

reasoning: The paragraph focuses on the company's internal security processes and tools, such as using.pem files, SSL encryption, and AWS Shield, which aligns with Risk Management Process. It names AWS Shield, a specific product, making it Firm-Specific.


reasoning: The paragraph describes the company's internal processes for incident response and recovery planning, which is a core component of risk management. It does not reference any actual incidents, board oversight, or specific management roles, and contains no verifiable facts unique to the company.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident involving a fraudulent email that led to an erroneous $0.7 million payment during 2023, along with response actions, fitting the Incident Disclosure category. It contains two verifiable hard facts: a specific date (year ended December 31, 2023) and a dollar amount ($0.7 million), meeting the threshold for Quantified-Verifiable specificity.


category_confidence: medium

reasoning: The paragraph primarily describes the company's internal process for evaluating and implementing safeguards after risk assessments, which is central to risk management. The mention of IT leadership reporting to the CEO is brief and does not shift the focus to detailed management role description.


reasoning: The paragraph focuses on the company's internal process for assessing and reporting cybersecurity threats via the MAT, involving specific roles and committees, which aligns with Risk Management Process.


reasoning: The paragraph focuses on the Audit Committee's oversight activities, such as receiving incident reports and quarterly discussions, which aligns with Board Governance. The mention of the CSO is a cybersecurity-specific title, making it Firm-Specific.


reasoning: The paragraph focuses on the company's internal processes for conducting risk assessments and implementing cybersecurity safeguards, which is characteristic of Risk Management Process. It contains no specific dates, names, or verifiable facts, making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes a specific cybersecurity incident from June 2018, including unauthorized access and a $10 million financial impact, which fits the Incident Disclosure category. It contains two verifiable hard facts (specific date and dollar amount), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal risk management framework and a committee chaired by a specific IT leadership role, focusing on processes rather than individual qualifications or board oversight.


content_category: Strategy Integration

reasoning: The paragraph primarily concludes that cybersecurity risks have not materially affected the company, with a brief mention of a past incident as an example, aligning with Strategy Integration. It contains two hard verifiable facts (specific date and dollar amount), making it Quantified-Verifiable.


content_category: None/Other

reasoning: The paragraph provides a generic definition of Denial of Service attacks without disclosing any company-specific information, processes, or incidents, fitting the 'None/Other' category for non-substantive content.


reasoning: The paragraph describes the company's internal cybersecurity safeguards and processes, including general tools and external service providers, which falls under risk management. It lacks specific details about incidents, management roles, board oversight, or named standards, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes internal cybersecurity processes such as patch deployment, software maintenance, employee training, and third-party security reviews, which are central to risk management. It contains no specific dates, named entities, or verifiable details, making it generic boilerplate.


content_category: Management Role

reasoning: The paragraph focuses on the individual responsible for cybersecurity risks and his lack of expertise, which is characteristic of Management Role disclosures, but it contains no specific, verifiable facts and uses generic language.


reasoning: The paragraph details the company's internal cybersecurity processes and measures, with the CISO mentioned as part of the organizational structure, aligning with Risk Management Process. The mention of a CISO is a specific cybersecurity role, making it Firm-Specific, but no other hard verifiable facts are present.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation, including scope and potential data compromise, which aligns with Incident Disclosure. It contains no verifiable specific facts such as dates, names, or amounts, making it generic boilerplate.


reasoning: The paragraph describes an incident response action (immediate assessment) conducted in relation to a cybersecurity incident, which aligns with the Incident Disclosure category. It contains no hard verifiable facts like dates, amounts, or named entities, using only generic terms such as 'incident response team' and 'sensitive patient data,' making it applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including integration into ERM and adherence to recognized frameworks, with Board oversight mentioned but not the primary focus. It names specific standards (NIST and ISO) but contains no unique company-specific details, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal cybersecurity policy and its objectives, which is focused on the company's own risk management processes rather than board oversight, management roles, or incidents.


reasoning: This paragraph is a generic forward-looking disclaimer about potential cybersecurity risks and impacts, with no description of actual incidents, specific processes, board oversight, or management roles, fitting 'None/Other' as it lacks substantive disclosure.


reasoning: The paragraph focuses on the informational technology consultant's role and qualifications in leading cybersecurity oversight, making it about the person rather than processes.


reasoning: The paragraph focuses on the Cybersecurity Incident Management Team (CIMT), detailing its composition, leadership by specific roles (General Counsel and CDO), and responsibilities, which centers on management roles in incident response rather than board oversight or general processes.


reasoning: The paragraph describes Deutsche Bank Group's cybersecurity measures, not RREEF Property Trust's own governance, processes, or incidents, and it contains only general practices with no specific, verifiable facts.


reasoning: The paragraph focuses on the responsibilities of a management role (Director of IT) in cybersecurity risk management, fitting Management Role. It contains no verifiable facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal process of using service providers to identify, assess, and manage cybersecurity risks, which aligns with Risk Management Process. It contains no specific facts such as named firms, dates, or quantifiable details, making it generic boilerplate.


reasoning: The paragraph describes the Trust's cybersecurity risk management process through reliance on BlackRock's ERM framework and board oversight, with specific references to BlackRock and the Sponsor's structure, fitting Risk Management Process.


reasoning: The paragraph describes the company's internal security controls and mitigation measures for managing cybersecurity risks, which aligns with risk management processes. It contains no specific details, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for incident response and recovery planning, which falls under risk management. It contains no specific dates, names, frameworks, or verifiable facts, making it generic boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is the company's vendor management program for cybersecurity risks, including security questionnaires and contractual obligations, which aligns with Third-Party Risk. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph narrates a specific cybersecurity incident with exact dates, scope, and response actions, fitting Incident Disclosure. It contains two verifiable dates (February 23, 2023, and February 28, 2023), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, such as engaging external resources for evaluation, monitoring threat intelligence, and using information to inform investments and strategies, with specific management roles mentioned as part of the consultation.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including threat monitoring, third-party partnerships, and control evaluations, with no specific verifiable details.


reasoning: The paragraph describes a cybersecurity incident, including the scope of data accessed and response actions, but lacks specific dates, named entities, or quantifiable details, making it generic boilerplate.


reasoning: The paragraph describes a cybersecurity incident with details on disruptions and restoration, but contains no hard verifiable facts such as specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents for a specific fiscal year, which falls under Strategy Integration, and the specific date makes it Firm-Specific.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes and oversight by a specific cybersecurity committee with defined membership, aligning with Risk Management Process, and contains firm-specific details like named roles and committee composition.


reasoning: The paragraph describes a specific cybersecurity incident with a date and details (unauthorized access leading to misdirected vendor payments), fitting the Incident Disclosure category. The specific date of the incident makes it Firm-Specific.


reasoning: The paragraph explicitly states the company has no formal cybersecurity program or processes, which falls under 'None/Other' as it describes an absence of substantive disclosure, and the materiality conclusion is boilerplate.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity risk, which aligns with Board Governance. It contains no specific facts, named entities, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph centers on the cybersecurity committee's composition and reporting structure, highlighting specific management roles and oversight processes, which fits the Management Role category. The references to past incidents and materiality are secondary to this governance detail.


reasoning: The paragraph primarily details the management team's responsibilities and composition for cybersecurity risk management, including a named executive role and quantified staff experience, making Management Role the most applicable category with firm-specific facts.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, including strategy development, control implementation, and reporting to the Audit Committee, which aligns with 'Risk Management Process' rather than focusing solely on a management role or board oversight.


reasoning: The paragraph describes the company's internal cybersecurity processes, including team support for the CISO and employee training activities, which are core elements of risk management. The focus is on functional processes rather than board oversight, management roles, or incident details.


reasoning: The paragraph describes a specific cybersecurity incident that occurred in June 2023, including details about unauthorized access, notification timing, and financial expenses, which aligns with the Incident Disclosure category.


reasoning: The paragraph centers on the CISO's role, qualifications, and reporting lines, fitting the Management Role category. It includes hard verifiable facts such as specific years of experience and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the CISO's role in supervising and assisting the ERMC with monitoring cybersecurity risks and incidents, which centers on the company's internal risk management processes rather than personal attributes or governance oversight.


reasoning: The paragraph describes general internal cybersecurity processes for prevention, detection, and response, which fits the Risk Management Process category. It contains no specific facts, named standards, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the Board of Directors' oversight of cybersecurity risk, including receiving updates from a specific management role (Vice President of Information Services), which is a firm-specific detail.


reasoning: The paragraph describes a specific cybersecurity incident in February 2023, including details on the ransomware attack, encryption of servers, response actions, and operational impact, which aligns with Incident Disclosure. It contains a specific date, making it Firm-Specific.


reasoning: The paragraph describes an actual cybersecurity incident with a specific date, details of unauthorized access, and response actions, which aligns with the Incident Disclosure category.


reasoning: The paragraph focuses on the functions of an information technology department in managing cybersecurity risk assessment, controls, and incident response, which aligns with internal risk management processes rather than board oversight or specific personnel.


reasoning: The paragraph provides a materiality assessment of past cybersecurity incidents and discusses potential future business impacts, which aligns with Strategy Integration. It includes a specific date (February 28, 2024), making it Firm-Specific, but no other verifiable facts are present.


reasoning: The paragraph describes a generic internal reporting process for cybersecurity risks from IT providers to management and the board, fitting risk management without specific details.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, such as monitoring, safeguards, and incident response planning, with the CISO as the subject but emphasizing functional activities rather than personal attributes. It includes firm-specific details like the CISO title and specific team composition.


reasoning: The paragraph's central topic is the company's processes for overseeing third-party service providers, fitting 'Third-Party Risk', though it includes a generic materiality disclaimer. No specific dates, names, or verifiable facts are present, making it generic boilerplate.


reasoning: The paragraph describes internal access management processes, which are part of cybersecurity risk management, but it contains no specific, verifiable facts such as dates, named tools, or quantifiable details unique to the company.


reasoning: The paragraph describes a specific cybersecurity incident with dates, scope (network outage, data extraction), and response actions, directly fitting the Incident Disclosure category. It contains two verifiable dates, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph discusses the Company's commitment to developing and amending cybersecurity processes, aligning with internal risk management activities, and includes the specific fact of no incidents in 2024.


reasoning: The paragraph centers on the company's reliance on IHM, a third-party manager, for cybersecurity processes and controls, making Third-Party Risk the appropriate category. It includes named entities (IHM and NIST CSF), which are specific facts, but lacks two or more hard verifiable facts like dates or amounts, so it is Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes management's supervision of internal cybersecurity processes such as briefings, threat intelligence, and security tools, which aligns with Risk Management Process as it focuses on activities rather than specific roles or incidents.


reasoning: The paragraph focuses on management roles and responsibilities for cybersecurity, with CEO and CFO identified as key personnel, fitting the Management Role category. It lacks any specific verifiable facts such as dates, amounts, or named entities, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity controls and processes, such as the defense-in-depth posture and Information Security Program domains, which are central to risk management without referencing specific incidents, roles, or verifiable details.


reasoning: The paragraph describes the integration of cybersecurity risk management into the enterprise risk management program, focusing on internal processes like methodologies and governance. It contains no verifiable facts, named standards, or company-specific details, making it generic boilerplate applicable to any company.


reasoning: The paragraph identifies a specific management role (Vice President of Operations) responsible for cybersecurity oversight and describes reporting lines, which aligns with the Management Role category. It contains at least one firm-specific fact (the role assignment) but no hard verifiable facts like dates or amounts, making it Firm-Specific.


reasoning: The paragraph centers on identifying a specific management role (Director of Information Security) with reporting lines and committee memberships, detailing cybersecurity responsibilities within the organization.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibility for cybersecurity within the Enterprise Risk Management framework, with no specific details or verifiable facts provided.


reasoning: The paragraph describes a corporate cybersecurity steering committee chaired by the CISO, which is part of the company's internal risk management processes for strategizing on cybersecurity challenges.


reasoning: The paragraph describes the company's internal cybersecurity incident response and vulnerability management policies, including escalation to management and reporting to the Audit Committee, which centers on risk management processes rather than board oversight or individual roles.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as risk assessments and incident response planning, without referencing specific roles, dates, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the Cybersecurity Committee's oversight and composition, which is a board-level committee providing governance over cybersecurity, fitting the Board Governance category. It contains firm-specific facts like the named committee and specific roles, making it Firm-Specific.


reasoning: The paragraph describes the operational experience and briefing activities of the CEO, CFO, and corporate controller in cybersecurity risk, focusing on management roles. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal processes for developing, maintaining, and monitoring cybersecurity protocols and controls, which aligns with Risk Management Process, and it contains no specific verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, such as risk assessments, audits, and reporting lines, rather than describing an incident or focusing solely on board or management roles.


reasoning: The paragraph focuses on the company's internal processes for managing cybersecurity risks, including team responsibilities, certifications, and oversight mechanisms, which aligns with Risk Management Process. It contains firm-specific details like named teams and specific certifications held by team members.


reasoning: The paragraph describes the company's own internal processes for cybersecurity risk management, including framework adoption and incident response planning, which aligns with Risk Management Process.


reasoning: The paragraph describes the Bank's internal cybersecurity processes, such as continuous monitoring, training, and incident response planning, with no mention of board governance, management roles, or actual incidents. All elements are generic practices without any named frameworks, tools, dates, or other verifiable specifics.


reasoning: The paragraph focuses on the CFO's day-to-day oversight and use of a specific tool for cybersecurity risk management, which describes internal processes rather than personal qualifications or board governance.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including framework adoption, cross-departmental approach, and policy reviews, with specific references to the Risk Committee and departmental areas.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as monitoring and strategy implementation, led by a specific executive role, making it Risk Management Process and Firm-Specific due to the named title and experience duration.


reasoning: The paragraph focuses on identifying the CIO and CISO, their qualifications, reporting lines, and credentials, which aligns with Management Role. It contains firm-specific details such as cybersecurity-specific titles and named certifications.


reasoning: The paragraph centers on the COO's qualifications and reporting role in cybersecurity, with a specific number of years of experience, fitting Management Role and Firm-Specific due to the verifiable duration.


reasoning: The paragraph describes the company's internal risk management process that incorporates third-party assistance for identifying, assessing, and managing cybersecurity risks, aligning with Risk Management Process. It contains no specific facts such as named firms, dates, or tools, making it generic boilerplate.


reasoning: The paragraph is a materiality disclaimer stating that cybersecurity threats have not materially affected the company, which aligns with Strategy Integration as it focuses on business impact without describing any incidents. The language is boilerplate with no specific facts, frameworks, or verifiable details.


reasoning: The paragraph describes a cybersecurity incident with a specific date and response actions, fitting the Incident Disclosure category. It contains a specific date (June 30, 2024), which is a firm-specific fact, but lacks two or more hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity metrics and reporting framework, which is a risk management process, and it includes specific roles and committees that identify unique aspects of the company's governance structure.


reasoning: The paragraph describes the semi-annual and annual reporting cadence from a specific management role to the Audit and Reserves Committee on cybersecurity oversight, which is central to board governance.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as integration into enterprise risk management and listing key risks, without focusing on board governance, management roles, or specific incidents.


reasoning: The paragraph includes a standalone materiality conclusion about the absence of cybersecurity incidents and forward-looking risk monitoring, which aligns with Strategy Integration per the tiebreakers for materiality assessments.


reasoning: The paragraph focuses on the company's internal cybersecurity program, ERM integration, and framework adoption, with management roles described as part of the risk management process rather than as the primary subject.


reasoning: The paragraph describes the company's general approach to managing cybersecurity risks, including threats from third parties, which aligns with Risk Management Process. It lacks any verifiable facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal risk assessment and mitigation processes, such as redesigning safeguards and monitoring effectiveness, which aligns with Risk Management Process. It lacks any specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph centrally describes vendor oversight processes and contractual requirements for third-party service providers, making Third-Party Risk the appropriate category. It contains no verifiable facts, named standards, or unique details, so it is generic boilerplate.


reasoning: The paragraph identifies specific cybersecurity-related management roles (CIO, CISO) and a named committee, focusing on organizational structure rather than processes or oversight activities.


reasoning: This paragraph provides a materiality conclusion regarding cybersecurity threats and cross-references risk factors, focusing on potential business impact without describing any actual incident or internal processes, which aligns with Strategy Integration.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, with a focus on a specific cross-functional team composition, which is a firm-specific detail.


reasoning: The paragraph focuses on the company's internal risk management process, specifically the ERMC's role in receiving and incorporating cybersecurity reports from the CISO and CDO, which aligns with Risk Management Process rather than individual roles.


reasoning: The paragraph's central topic is vendor oversight, detailing processes for assessing third-party compliance with cybersecurity requirements, including SOC 2 report reviews and business associate agreements, which fits Third-Party Risk. It names a recognized standard (SOC 2) but lacks unique company-specific details, making it Sector-Adapted.


reasoning: This paragraph is a forward-looking disclaimer about hypothetical future incidents and a cross-reference to risk factors, providing no substantive disclosure about the company's cybersecurity practices, governance, or actual events.


reasoning: The paragraph describes the internal cross-functional team and its responsibilities for day-to-day cybersecurity program implementation, focusing on processes rather than individual qualifications, and includes specific management titles and quantified experience.


reasoning: The paragraph details the company's cybersecurity risk management approach through CIM Group's policies and procedures, fitting Risk Management Process. It is Firm-Specific because it names CIM Group as a unique entity relied upon by the company.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, such as program reviews, audits, and risk assessments, with the FFIEC Cybersecurity Assessment Tool being a specific, named tool used in these activities.


reasoning: The paragraph's central topic is vendor oversight through a third-party risk management program, fitting Third-Party Risk, but it lacks specific dates, names, or verifiable details, making it Generic Boilerplate.


reasoning: This paragraph describes the company's internal processes for incident detection and response, which are core risk management activities. It contains no specific facts such as dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management program components, such as policies, risk assessments, and team responsibilities, with no reference to specific incidents, board oversight, or management roles.


reasoning: The paragraph describes a specific cybersecurity incident in 2021 with details on detection, response, operational impact (flight cancellations), financial loss, and insurance recovery, making it an Incident Disclosure. It contains multiple hard verifiable facts including specific dates, numbers, and dollar amounts, meeting the threshold for Quantified-Verifiable.


reasoning: This paragraph is a forward-looking statement about the potential material impact of cybersecurity risks, which aligns with Strategy Integration as it involves materiality assessments without describing specific incidents, processes, or roles.


reasoning: The paragraph centers on materiality conclusions, financial costs, and risk impacts without describing any specific incident details, aligning with Strategy Integration. It includes a specific date and a quantified count of past breaches, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph provides a materiality conclusion about cybersecurity threats and incidents not affecting the company, which falls under Strategy Integration. It contains no specific facts about the company's cybersecurity program, only general statements and a vague timeframe, making it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with date, method, scope, and response actions, fitting Incident Disclosure. It contains a specific date (September 14, 2023), which is a firm-specific fact, but lacks additional hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity processes like scans, penetration tests, and tabletop exercises, which are standard risk management activities with no unique or verifiable details.


reasoning: The paragraph centers on the Board of Directors' oversight role in discussing cybersecurity risks and inquiring about controls, with the mention of lacking a CIO providing a firm-specific detail.


reasoning: The paragraph details the company's internal cybersecurity processes for data storage and network security using specific AWS services, fitting Risk Management Process, and includes two verifiable hard facts (named product and named third-party firm).


reasoning: The paragraph centers on the qualifications, experience, and credentials of specific management roles (CTO and VPCS), fitting the Management Role category. It contains multiple hard verifiable facts, including specific years of experience, degrees from named universities, and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph is a generic risk statement acknowledging past cyber-attacks and future risks without describing any specific incident, governance, or processes, making it non-substantive and fitting for None/Other.


reasoning: The paragraph focuses on the company's internal processes for assessing and managing cybersecurity risks, including the establishment of a specific committee with defined composition and reporting lines, rather than describing a person's role or an incident.


reasoning: The paragraph is a standalone materiality conclusion stating that cybersecurity risks have not materially affected the company, which falls under Strategy Integration per the tiebreakers, and it contains no specific details, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph discusses insurance reimbursements and a materiality conclusion related to a past incident without describing the incident itself, aligning with Strategy Integration. It contains no specific dates, amounts, or named entities, making it generic boilerplate materiality language.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, including risk assessment, CEO oversight, and use of standard software, which fits Risk Management Process. It lacks any named entities, dates, or specific details, making it Generic Boilerplate.


reasoning: The paragraph describes the integration of cybersecurity risk assessment into the company's overall risk management processes, which is a core aspect of Risk Management Process. It contains no specific, verifiable facts such as dates, amounts, or named entities, making it generic boilerplate language applicable to any company.


reasoning: The paragraph describes the establishment and oversight role of a cross-functional management committee (ISSC) for assessing and managing cybersecurity risks, which is a core internal risk management process.


reasoning: The paragraph describes management roles (CFO, COO, etc.) and their reporting responsibilities for cybersecurity threats, focusing on who is involved and notifies whom, which aligns with Management Role. It contains no unique or verifiable details, making it generic boilerplate applicable to many companies.


reasoning: The paragraph describes response actions (regulatory inquiries and cooperation) related to a data incident, fitting Incident Disclosure. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response process, including assessment, classification, escalation, and board notification procedures, which aligns with risk management processes and contains no specific verifiable details.


reasoning: The paragraph describes the company's general approach to cybersecurity risk assessment and management, including threat evaluation and maintaining practices, which aligns with Risk Management Process. It contains no specific facts, named standards, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity processes such as training, monitoring, and vulnerability management, which aligns with risk management, and contains no specific details unique to the company, making it generic boilerplate.


reasoning: The paragraph describes the Company's internal Data Security Event Plan (DSEP), which formalizes processes for incident identification, investigation, and reporting, focusing on functions rather than specific incidents or governance.


reasoning: The paragraph provides a materiality conclusion about cybersecurity incidents, stating none have materially affected the company, which aligns with Strategy Integration. It contains no specific facts and is boilerplate language.


reasoning: The paragraph focuses on the management team and CISO's responsibilities and qualifications, which aligns with the Management Role category, and it includes specific details like the CISO title and years of experience, making it Firm-Specific.


reasoning: The paragraph describes a specific cybersecurity incident (phishing attacks on the online banking platform) with details on the method and response, aligning with Incident Disclosure. It contains no verifiable facts such as exact dates, named entities, or quantifiable data, making it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with details on timing, cause, financial impact, and response actions, fitting Incident Disclosure. It contains firm-specific facts like the fiscal year and dollar loss, but only one hard verifiable fact (dollar amount) prevents a Quantified-Verifiable rating.


reasoning: The paragraph describes a specific cybersecurity incident involving fraudulent wire transfers, including discovery, response actions, and financial impact, which aligns with Incident Disclosure. It contains two verifiable facts: the fiscal year reference and a specific dollar amount, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal process of monitoring threat intelligence to manage cyber risks, which aligns with Risk Management Process, and contains no specific details such as named frameworks, roles, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on identifying and overseeing cybersecurity threats from third-party vendors, which is the central topic of Third-Party Risk. It contains no specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes management's role in overseeing cybersecurity risk mitigation and reporting incidents to the board, which aligns with risk management processes. It contains no specific facts such as dates, names, or frameworks, making it generic boilerplate applicable to any company.


reasoning: This paragraph describes a specific cybersecurity incident that occurred on September 14, 2023, including the attack method, data compromised, and response actions, fitting the Incident Disclosure category.


reasoning: The paragraph describes the creation of a Chief Risk Officer position and their responsibilities in overseeing risk management with the CISO, focusing on management roles and oversight functions.


reasoning: The paragraph describes the company's internal cybersecurity processes and measures in general terms, with no specific details, verifiable facts, or named standards, making it applicable to any company.


reasoning: The paragraph focuses on the functions and responsibilities of management roles in cybersecurity risk management processes, such as integrating risk and preparing for incidents, rather than personal qualifications or board oversight.


reasoning: The paragraph identifies specific management roles (CFO, General Counsel, Head of IT) leading cybersecurity processes and their qualifications, with a named committee and experience durations, making it firm-specific but not quantified-verifiable.


reasoning: The paragraph focuses on the IT Director's qualifications and responsibilities, and the IT Steering Committee's composition, which centers on management roles in cybersecurity oversight.


reasoning: The paragraph centers on the Audit Committee's oversight role and reporting structures from management to the board, fitting Board Governance. It includes cybersecurity-specific titles (CDIO and CISO), which are firm-specific facts.


reasoning: The paragraph focuses on a materiality conclusion regarding cybersecurity threats within the enterprise risk management framework, with no incident narrative or specific verifiable details, aligning with Strategy Integration and generic boilerplate language.


reasoning: The paragraph focuses on the Board's oversight role and reporting structure to the Board, with specific cybersecurity management roles mentioned, making it Board Governance with firm-specific details.


reasoning: The paragraph is a materiality disclaimer stating no material cybersecurity disruptions occurred and cross-references risk factors for detailed assessment, focusing on business impact rather than specific governance, processes, or incidents.


reasoning: The paragraph describes a specific cybersecurity incident detected in 2022, including its impact on the network and response actions, which directly aligns with the Incident Disclosure category. The materiality conclusion is integrated into the incident assessment.


reasoning: The paragraph describes the company's internal incident response policy, including escalation to management and reporting procedures, which is focused on risk management processes rather than board oversight or incident details.


reasoning: The paragraph describes potential financial and operational impacts of cybersecurity incidents without referencing any actual events or specific company processes, aligning with Strategy Integration, and contains no verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes management-level committees and roles (e.g., CCO, CFO, CLO) with specific compositions and responsibilities for cybersecurity oversight, making it focused on organizational structure rather than processes or incidents.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as risk assessments, security team roles, training, and incident response planning, which fits the 'Risk Management Process' category. It contains no specific verifiable facts like dates, amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the company's planned internal cybersecurity risk management activities, such as enhancing threat detection and conducting tabletop exercises, which are general processes without specific details or verifiable facts.


reasoning: The paragraph describes the company's internal cyber risk management process, focusing on activities like threat identification and mitigation, but contains no specific details such as named frameworks, roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity programs and processes managed by the CISO and team, including framework adoption and risk management activities, which aligns with Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity program anchored by a named framework (EISF) and adherence to various standards, which aligns with risk management processes.


reasoning: The paragraph describes the oversight process where management updates the Audit Committee on IT and data privacy risks, and reports are provided to the full Board, fitting the Board Governance category with no firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including audits, risk assessments, and vendor oversight, with the IT team led by a specific role, making it Risk Management Process and Firm-Specific due to the named title.


reasoning: The paragraph describes the CISO's responsibilities and the Information Security Department's duties, such as managing policies, supervising training, conducting access reviews, and monitoring security measures, which are internal risk management processes. It includes the cybersecurity-specific title 'CISO', making it Firm-Specific.


reasoning: The paragraph describes the board of directors' oversight of cybersecurity risk management, including receiving reports from management and a reporting cadence, which fits the Board Governance category. It contains no named entities, specific dates, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and protection processes, which is the focus of 'Risk Management Process'. It contains only generic descriptions of security practices with no verifiable specific facts.


reasoning: The paragraph focuses on the potential business and financial impacts of cybersecurity risks, such as reputation damage and material adverse effects, which is characteristic of Strategy Integration. It contains no specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including integration into overall risk management and reliance on the NIST framework, which aligns with Risk Management Process. It names a recognized standard (NIST) but contains no firm-specific details, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal cybersecurity processes, including risk assessments, incident response planning, and third-party risk management, which aligns with the Risk Management Process category.


reasoning: The paragraph's central topic is vendor oversight, including due diligence, risk assessments, and contractual requirements, which aligns with Third-Party Risk. It names the SOC standard, a recognized framework, but lacks any unique details about Primis Financial Corp., making it Sector-Adapted.


reasoning: The paragraph explicitly states the Board's responsibility for overseeing risk management and cybersecurity integration, with no specific details, verifiable facts, or named standards.


reasoning: This paragraph provides a materiality conclusion about cybersecurity incidents and includes a forward-looking disclaimer referencing risk factors, which aligns with Strategy Integration. It contains no specific details, making it generic boilerplate.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk, with the committee as the grammatical subject, fitting Board Governance. It includes the specific cybersecurity title 'Chief Information Officer', making it Firm-Specific.


reasoning: The paragraph identifies specific management roles involved in cybersecurity processes, with the grammatical subject being management, making it focused on role identification rather than process description.


reasoning: The paragraph describes the company's internal incident response process, including a cross-functional committee and escalation procedures, which aligns with Risk Management Process. The specific departmental composition (IT, Finance, Legal) makes it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as integration into enterprise risk management, testing, and annual reviews, with no focus on board oversight, specific roles, or actual incidents.


reasoning: The paragraph focuses on the company's internal processes for identifying, remediating, and overseeing cybersecurity risks, with specific details about management roles, committees, and qualifications, aligning with Risk Management Process.


reasoning: The paragraph focuses exclusively on the company's processes for overseeing third-party service providers, which is the central topic of Third-Party Risk. It contains no verifiable facts, named entities, or specific details, making it Generic Boilerplate.


reasoning: The paragraph describes the integration of cybersecurity risk management into the company's overall enterprise risk management program, focusing on internal processes like methodologies and governance. No specific facts, dates, or named entities are present, making it generic and applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness processes, which aligns with Risk Management Process. It lacks any specific dates, amounts, named entities, or frameworks, making it generic boilerplate applicable to many companies.


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks, which fits the Risk Management Process category. It contains no specific details such as dates, frameworks, roles, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph centers on the VP of IT's identification, qualifications, and responsibilities, making management role the primary focus. It contains firm-specific facts like the cybersecurity-specific title and detailed experience/credentials.


reasoning: The paragraph describes board oversight activities, with the Board receiving briefings and presentations on cybersecurity, making it Board Governance. The mention of the Chief Information Officer is a cybersecurity-specific title, providing a firm-specific detail.


reasoning: The paragraph describes the company's process of engaging external service providers to evaluate and enhance cybersecurity policies, which is part of its internal risk management processes, with no specific details or named entities.


reasoning: The paragraph provides a standalone materiality conclusion about the absence of material cybersecurity incidents, which aligns with Strategy Integration per the tiebreakers. It includes a specific date (December 31, 2024), making it Firm-Specific.


reasoning: The paragraph describes the escalation process to specific management roles like CISO and references the Risk Committee, focusing on their qualifications and involvement, which aligns with Management Role category.


reasoning: The paragraph focuses on the processes and activities overseen by the Director of Infrastructure, such as monitoring, risk management, and incident response, which are core to internal cybersecurity risk management. The specific title 'Director of Infrastructure' identifies a unique role within the company, making it Firm-Specific.


reasoning: The paragraph focuses on identifying specific management roles (ISO, Director of IT, Director of Information Services) and their reporting lines, which aligns with the Management Role category. It contains cybersecurity-specific titles and organizational details, making it Firm-Specific.


reasoning: The paragraph emphasizes a specific management position with detailed qualifications, making Management Role the primary category despite brief mention of board oversight.


reasoning: The paragraph describes a specific cybersecurity incident at Targus, including the discovery date, scope, response actions, and operational impact, which aligns with Incident Disclosure. It contains firm-specific facts such as the exact date and named subsidiary, but only one hard verifiable fact (the date), so it is Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph is entirely focused on managing cybersecurity risks through third-party providers, including risk assessments and contractual obligations, which aligns with 'Third-Party Risk.' It contains no specific dates, names, or verifiable facts, using generic language that could apply to any company.


reasoning: The paragraph primarily offers a materiality conclusion by stating no material cyber breaches have occurred, which is a core element of Strategy Integration, and the mention of reviewing policies is generic without specific details.


reasoning: The paragraph describes the company's cybersecurity risk management processes, including the use of a consultant and vendor for threat identification and assessment, which is central to internal processes. No specific dates, names, or verifiable facts are provided; the methods listed are common practices, making it generic.


reasoning: The paragraph describes a specific cybersecurity incident involving unauthorized bitcoin transfer, including the year, quantity of BTC, and dollar value, which are verifiable facts, making it an Incident Disclosure with Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal committee overseeing cybersecurity processes, including strategy, policies, and incident response, which aligns with risk management. It includes specific roles and a named program, making it firm-specific.


reasoning: The paragraph primarily identifies the Chief Technology Officer, their qualifications (including years of experience and external affiliations), and reporting lines, making Management Role the most applicable category. It contains multiple verifiable hard facts such as specific years and named organizations, warranting Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal cybersecurity program and team responsibilities, focusing on processes for identifying and mitigating threats, which aligns with Risk Management Process. It lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph is a materiality disclaimer about cybersecurity threats, which aligns with Strategy Integration per the tiebreakers. It contains no unique facts about the company, making it generic boilerplate.


reasoning: The paragraph focuses on the Audit Committee's oversight role in receiving cybersecurity reports, which aligns with Board Governance. It includes a specific cybersecurity-related title, making it Firm-Specific.


reasoning: The paragraph describes a specific past cybersecurity incident with a date and operational impact, fitting the Incident Disclosure category. The specific date (December 15, 2020) is a firm-specific fact, but no additional hard verifiable facts are present.


reasoning: The paragraph describes a cybersecurity incident involving employee interactions with suspicious websites, including containment and forensic investigation, which fits the Incident Disclosure category. It contains no specific dates, named entities, or quantifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the board of directors' responsibility for monitoring and assessing cybersecurity risks, with the board as the grammatical subject, fitting Board Governance. It contains no specific dates, names, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph centers on the reporting and escalation processes to the Board of Directors, highlighting board oversight of cybersecurity risks. It includes firm-specific details such as the ISO role and the BRCC committee.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, integrated into overall risk management, with a specific role mentioned as part of the function.


reasoning: The paragraph describes internal cybersecurity risk management processes and activities, such as monitoring and assessments, without referencing specific incidents, board oversight, or third-party risks. It contains no verifiable facts like dates, names, or numbers, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on identifying specific management roles (CIO and director of IT) responsible for cybersecurity programs and their reporting lines, which aligns with the Management Role category. It contains firm-specific details like named roles and organizational relationships, making it Firm-Specific.


reasoning: The paragraph describes the company's internal risk assessment processes and use of a cybersecurity framework, which aligns with 'Risk Management Process'. It names the CIS Critical Security Controls, a recognized industry standard, but lacks any unique details about the company, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as monitoring tools, incident response planning, and employee training, which aligns with Risk Management Process. It contains no specific details like named tools, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes internal processes for reviewing and assessing cybersecurity risks through a named Cybersecurity Council and executive management, with specific team compositions and roles, fitting Risk Management Process.


reasoning: The paragraph focuses on the company's internal Enterprise Risk Management program and the specific roles and functions involved in managing cybersecurity risk, such as the CISO and GRC team, which aligns with Risk Management Process and includes firm-specific details.


reasoning: The paragraph describes a cybersecurity incident with specific dates and unauthorized access details, which aligns with Incident Disclosure, and the date range provides a firm-specific fact.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and processes, including framework adoption, which aligns with Risk Management Process. It names the NIST Cybersecurity Framework, a recognized standard, but contains no other verifiable facts unique to the company, making it Sector-Adapted.


reasoning: The paragraph focuses on the Board's oversight role in cybersecurity, including receiving incident updates and reviewing policy changes, which aligns with Board Governance. It lacks any specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes a specific cybersecurity incident in November 2023, including operational disruption, data exfiltration, and remediation actions, which aligns with Incident Disclosure. It contains a specific date, making it Firm-Specific, but lacks multiple hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal processes for threat notification, employee education, and risk assessment, with no focus on board oversight, management roles, or actual incidents, fitting Risk Management Process. It lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph is a generic acknowledgment of cybersecurity risks by a start-up with limited operations, with no description of any cybersecurity program, governance, processes, or incidents, fitting 'None/Other' as non-substantive disclosure.


reasoning: The paragraph describes the company's internal processes for penetration testing and vulnerability assessments, which are core risk management activities, with no specific dates, names, or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including evaluation of third-party risks, with no specific details or verifiable facts.


reasoning: The paragraph centers on materiality assessments and insurance coverage without describing specific incidents, aligning with Strategy Integration. It contains no verifiable facts, named entities, or specific details, making it Generic Boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, such as program creation and framework adoption, with no mention of board oversight, management roles, incidents, or third-party risk.


reasoning: The paragraph primarily identifies specific management roles (CTO, Compliance Manager, etc.) and their qualifications, with the CTO's experience as a key detail, making Management Role the most applicable category.


reasoning: The paragraph describes oversight by a committee receiving reports from management on cybersecurity posture and incidents, which aligns with board governance. It contains no specific facts, dates, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment processes and committee activities, which is central to Risk Management Process. It includes specific named entities like the Information Security Steering Committee and CISO title, qualifying as Firm-Specific.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight role, detailing reporting cadences and management support, which aligns with Board Governance. It contains firm-specific facts such as the CIO's tenure, background, and the CISO's certifications.


reasoning: The paragraph describes the managerial responsibility, experience, and educational background of the Chief Digital Information Officer, which is a cybersecurity-specific management role, making it clearly about the person rather than processes.


reasoning: The paragraph focuses on the company's internal processes for implementing and maintaining cybersecurity practices, including team activities, training, and audits, which aligns with Risk Management Process.


reasoning: The paragraph describes Alphabet's internal processes for tracking, reviewing, and escalating cybersecurity incidents, which is a core aspect of risk management, with no specific verifiable facts or unique details.


reasoning: The paragraph describes the company's internal risk management processes, including specific cadences and policies for engaging third-parties in cybersecurity assessments, which falls under Risk Management Process rather than Third-Party Risk as the central focus is on the company's own procedures.


reasoning: This paragraph is a materiality disclaimer stating that cybersecurity threats have not materially affected the company's business, which falls under Strategy Integration per tiebreakers. It contains no specific facts, dates, or details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as risk assessment, third-party selection, incident response procedures, training, and monitoring, without focusing on specific roles, incidents, or board oversight. It contains no named frameworks, dates, amounts, or other verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the company's internal risk assessment, safeguard implementation, and monitoring processes, which are core to risk management, and it mentions a specific cybersecurity role (CIO) as part of managing these processes.


reasoning: The paragraph describes the company's exposure to regulatory cybersecurity risks, which is part of its internal risk management processes. It contains no specific details, frameworks, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: This paragraph is solely a cross-reference to risk factor disclosures in Item 1A and provides no substantive cybersecurity disclosure, fitting the 'None/Other' category for non-content.


reasoning: The paragraph's central focus is on the company's reliance on third-party software and its control system for assessing vendor controls via SOC reports, with a brief materiality conclusion, making Third-Party Risk the most applicable category.


reasoning: The paragraph describes a specific cybersecurity incident involving Change Healthcare, including details about the incident, its impact on billing processes, and response actions, which aligns with Incident Disclosure. It contains multiple hard verifiable facts such as a specific date and named entities, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph centers on the board's oversight of cybersecurity risk management, with the board as the grammatical subject, and contains no specific facts, names, dates, or standards, making it generic boilerplate.


reasoning: The paragraph focuses on the Audit Committee and Board of Directors overseeing cybersecurity risks, which is a standard board governance disclosure with no specific facts, dates, or unique details.


reasoning: The paragraph centers on assessing and imposing security requirements on third-party vendors, which is the core of Third-Party Risk. It lacks any named frameworks, dates, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, including continuous monitoring, third-party assessments, and employee training, which aligns with Risk Management Process. It contains no specific dates, named entities, or verifiable facts, using generic language applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the named Cyber Incident Response Team and Cybersecurity Plan, with specific roles and functions, rather than focusing on board oversight or individual management qualifications.


reasoning: The paragraph focuses on the Chief Operating Officer's role in informing the Audit Committee on cybersecurity risks, which aligns with management roles and reporting lines, but it contains no specific verifiable facts such as dates, names, or quantifiable details.


reasoning: The paragraph focuses on Duncan Fulton's management role, responsibilities, and career background, which aligns with the Management Role category. It contains multiple specific dates and named firms, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and frameworks, which aligns with Risk Management Process. It names recognized industry standards like NIST and CIS without any unique company-specific details, making it Sector-Adapted.


reasoning: This paragraph is a forward-looking materiality assessment stating that no cybersecurity risks are expected to significantly affect the company's operations, financial condition, or objectives, which aligns with Strategy Integration. It contains no specific details such as dates, names, or numbers, making it Generic Boilerplate.


reasoning: The paragraph centers on the audit committee's oversight responsibility and management reporting lines for cybersecurity risk, aligning with Board Governance. It contains no verifiable facts like dates, amounts, or named standards, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, including governance measures and control requirements like change management and monitoring, which aligns with Risk Management Process. It contains no specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph details the company's internal processes for monitoring cybersecurity incidents and executing the incident response plan, with specific roles and committees involved, fitting Risk Management Process.


reasoning: The paragraph primarily describes the Board and Audit Committee's oversight of cybersecurity risk, with the VP IT's reporting as part of the governance structure, making Board Governance the most applicable category.


reasoning: The paragraph describes the company's internal processes for cybersecurity incident reporting, risk tiering, recovery, and materiality assessment, which aligns with Risk Management Process. It includes the cybersecurity-specific title 'CISO,' making it Firm-Specific, but lacks hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including team structure and reporting lines, which are specific to the organization's operations.


reasoning: The paragraph focuses on the qualifications, experience, and certifications of specific management roles (Head of Cybersecurity and VP Information Security), which aligns with the Management Role category.


reasoning: The paragraph describes a specific cybersecurity incident from June 2022, including the date and response actions, which aligns with Incident Disclosure. It contains two verifiable specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph is a general, non-substantive statement about the importance of cybersecurity to business operations, with no specific details on processes, roles, incidents, or strategies, fitting 'None/Other' and lacking any verifiable facts for higher specificity.


reasoning: The paragraph centers on board and Audit Committee oversight of cybersecurity with generic descriptions of updates and discussions, lacking any firm-specific details such as dates, frameworks, or named entities.


reasoning: The paragraph describes a past cybersecurity incident with specific details including date, impact, and response actions, fitting the Incident Disclosure category. It contains a specific date and named entity, making it Firm-Specific.


reasoning: The paragraph describes management's oversight of the cybersecurity risk management process, including charter adoption and Board reporting, which aligns with internal risk management activities. No verifiable facts, named standards, or company-specific details are present, making it generic boilerplate.


reasoning: The paragraph centers on the Board's oversight of cybersecurity risk through the Audit Committee and management's supporting role in reviewing risks, making board governance the primary focus.


reasoning: The paragraph describes the management role responsible for cybersecurity, focusing on the Director of IT's qualifications and reporting line, with specific verifiable facts about years of experience.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight roles and briefing cadences, which is characteristic of Board Governance. It contains no verifiable facts, named entities, or specific details beyond generic governance structures and cadences, making it Generic Boilerplate.


reasoning: The paragraph's central topic is vendor oversight, detailing the vendor management program and assessment processes, which aligns with Third-Party Risk. It includes a specific team composition (corporate security, product security, and legal), making it Firm-Specific.


reasoning: The paragraph centers on the company's Vendor Risk Management Program for overseeing vendor risks, making Third-Party Risk the primary category. It names a specific regulatory guidance but contains no other unique company details, aligning with Sector-Adapted specificity.


reasoning: The paragraph centers on management roles (CTO, DPI Head, SSA) with specific qualifications, responsibilities, and contributions, making Management Role the primary category, and it contains firm-specific details like named internal systems and exact durations.


reasoning: The paragraph describes the board of directors' oversight role for risks and processes, which aligns with Board Governance. It contains no specific facts, frameworks, or unique details, making it Generic Boilerplate.


reasoning: The paragraph focuses on the board's oversight of cybersecurity through the formation of a dedicated committee, which is a core aspect of Board Governance. It does not describe management roles, internal processes, or incidents.


reasoning: The paragraph focuses on the Cybersecurity Team's functions in maintaining the cybersecurity program and overseeing activities, which aligns with internal risk management processes rather than individual roles or board oversight.


reasoning: The paragraph describes the company's internal cybersecurity program, including policies and crisis response plans, which aligns with Risk Management Process. It contains no verifiable facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment process, including third-party evaluation against the NIST Framework, which aligns with Risk Management Process. It is Sector-Adapted because it names a recognized standard (NIST) but contains no unique firm-specific details.


reasoning: The paragraph focuses on the CISO's qualifications, experience, and certifications, which directly identifies a management role in cybersecurity.


reasoning: The paragraph describes the company's internal process of providing regular cybersecurity briefings to management and the board, which falls under risk management processes, and it includes the CIO role as a specific fact.


reasoning: The paragraph is a standalone materiality disclaimer stating no material impact from cybersecurity threats, which falls under Strategy Integration per tiebreakers. It contains no specific facts, frameworks, or unique details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's own cybersecurity risk management processes, including assessment, controls, and integration into enterprise risk management, which aligns with Risk Management Process. It names recognized frameworks ISO and NIST, but contains no firm-specific details like dates, names, or quantifiable facts, making it Sector-Adapted.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity risks and incidents, which aligns with Strategy Integration, and uses standard boilerplate language with no unique company-specific details.


reasoning: The paragraph centrally discusses vendor oversight for cybersecurity risks through a vendor management program, making Third-Party Risk the appropriate category. It contains no verifiable facts, named entities, or specific details, relying on generic descriptions of risk management processes.


reasoning: The paragraph is a forward-looking statement assessing the potential material adverse business impact of cybersecurity incidents, which aligns with materiality assessments in Strategy Integration. It contains no specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risks and the CTO's reporting line to the committee, which aligns with board governance. The mention of the CTO title is a firm-specific fact, though no other verifiable details are present.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including ERM integration and reporting structures, with specific committee names and roles indicating firm-specific details.


reasoning: The paragraph focuses on specific management roles (CIO, VP Information Technology, Manager of Security) and their qualifications, making it a clear fit for the Management Role category. It contains firm-specific details like named roles and a specific experience duration, but lacks two hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph centers on third-party agreements with named entities (NEE Management and NEER) for cybersecurity services, with board oversight, making vendor risk the central topic.


reasoning: The paragraph describes board and committee oversight of cybersecurity risk, which is a standard governance disclosure without any specific details about the company's practices, frameworks, or personnel.


reasoning: The paragraph describes a cybersecurity incident with details on unauthorized access, fraudulent fund diversion, detection, and impact assessment, fitting the Incident Disclosure category. It contains a specific date (2024), making it Firm-Specific, though no other verifiable facts are present.


reasoning: The paragraph focuses on the CIO's primary responsibility, qualifications, and experience, which directly pertains to management roles in cybersecurity oversight.


reasoning: The paragraph describes a specific cybersecurity incident that occurred in November 2023, detailing the response actions, scope, and notifications, which fits the Incident Disclosure category. The inclusion of a specific month and year makes it Firm-Specific, though it lacks additional hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes the internal process of management reporting cybersecurity risks to committees, which is part of the company's risk management program. The named 'Enterprise Risk and Compliance Committee' is a firm-specific detail, making the disclosure non-generic.


reasoning: The paragraph centers on the Board of Directors and Audit Committee's oversight of cybersecurity, with the CISO reporting to them, which is characteristic of board governance.


reasoning: The paragraph discusses cybersecurity insurance as a financial strategy element without describing any incident or specific details, aligning with Strategy Integration. It lacks any verifiable facts such as dates, amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph centers on the cybersecurity sub-committee's oversight responsibilities and expertise, fitting the Board Governance category. It includes firm-specific details such as the named committee and quantified experience, warranting a Firm-Specific rating.


reasoning: The paragraph focuses on the board of directors' oversight role in receiving updates on cybersecurity risks, which is a standard governance disclosure with no unique details about the company.


reasoning: The paragraph describes a specific cybersecurity incident with a date, affected systems, and response actions, fitting the Incident Disclosure category. It contains firm-specific facts like the incident date and reference to the Aurora acquisition.


reasoning: The paragraph focuses on the CISO's qualifications, background, and the information security team's composition, which aligns with management role identification rather than processes or oversight.


reasoning: The paragraph describes the company's internal cybersecurity processes and protective measures, such as multifactor authentication and firewalls, which are standard practices without any company-specific details or named frameworks.


reasoning: The paragraph focuses on materiality assessments and potential business impact of cybersecurity incidents, which aligns with Strategy Integration. It contains no specific details about the company's cybersecurity program, making it generic boilerplate.


reasoning: The paragraph centers on the Board and Audit Committee's oversight of cybersecurity risk, with management mentioned only in a reporting context, making it primarily about board governance. No specific details or verifiable facts are present.


reasoning: This paragraph is a boilerplate materiality disclaimer about cybersecurity risks and program effectiveness, which aligns with Strategy Integration as per tiebreakers for materiality statements, and it contains no verifiable facts or company-specific details.


reasoning: The paragraph describes a ransomware incident with a specific date and response actions, fitting the Incident Disclosure category. It contains a specific date (late May 2023), which is a firm-specific fact.


reasoning: The paragraph's central topic is the oversight of cybersecurity risks from third-party service providers, aligning with Third-Party Risk, and it contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight of the cybersecurity program, which is central to Board Governance. It includes a specific date reference (fiscal year 2024), qualifying it as Firm-Specific.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity risks and incidents, which aligns with Strategy Integration as it discusses potential business impact without describing specific events, and it contains no verifiable facts or specific details, making it generic boilerplate.


reasoning: The paragraph focuses on management's oversight of cybersecurity risks and reporting to the board, but it lacks specific cybersecurity roles (e.g., CISO), dates, or frameworks, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes a specific ransomware incident with date, scope, and response actions, fitting Incident Disclosure; the date 'late May 2023' is a firm-specific fact, but no other verifiable details are present.


reasoning: The paragraph describes the Cybersecurity Steering Committee's composition and its responsibilities for monitoring and managing cybersecurity risks, which focuses on the company's internal risk management processes rather than individual roles or board oversight.


reasoning: The paragraph describes expected Board oversight and management reporting on cybersecurity, which aligns with Board Governance. It contains no verifiable facts, named entities, or specific details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, including framework usage, plan development, and regular reviews, which aligns with Risk Management Process. No specific dates, named entities, or verifiable facts are provided, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including team responsibilities, council structures, and risk escalation, with firm-specific roles and committees.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as controls, monitoring, training, and vendor risk policy, without referencing board oversight or specific management roles, aligning with the Risk Management Process category.


reasoning: The paragraph centers on identifying management roles (VP of IT, COO) and their qualifications, with specific details on team composition and reporting lines, aligning with the Management Role category. It contains firm-specific facts like the VP's experience and cross-functional team makeup, justifying Firm-Specific specificity.


reasoning: The paragraph focuses on the CFO's role in cybersecurity risk management processes, such as monitoring and evaluation methods, which aligns with Risk Management Process as it describes functions rather than personal qualifications. It contains no specific dates, names, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, policies, and oversight, with no specific incidents, verifiable facts, or named entities, making it generic boilerplate.


reasoning: The paragraph primarily describes the CISO's responsibilities and qualifications, with the Audit Committee's oversight mentioned briefly, aligning with Management Role as the main focus.


reasoning: The paragraph describes the operational status and restoration timeline of a cybersecurity incident, which is central to incident disclosure. It contains two hard verifiable facts: a specific date (March 31, 2023) and named services (DISH TV and SLING TV), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal governance structure and processes for evaluating and addressing cybersecurity risks, with no specific verifiable facts or unique details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and management processes, including specific dates and numerical details, which aligns with Risk Management Process and meets the threshold for Quantified-Verifiable specificity due to multiple hard verifiable facts.


reasoning: The paragraph focuses on the chief information officer's oversight role, qualifications, and team composition, with specific experience details, aligning with Management Role. It contains firm-specific facts like the CIO title and experience durations, but no exact hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including incident response and governance reporting, with specific organizational details like the named Directors Risk Committee and Corporate Security Group.


reasoning: The paragraph lists standard cybersecurity processes like vulnerability scans, employee training, incident response planning, and third-party risk management, which are internal risk management activities without any unique company-specific details.


reasoning: The paragraph centers on the board and audit committee's oversight of cybersecurity risks, with management providing updates, which aligns with Board Governance. It contains no specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness processes, which aligns with Risk Management Process, and it lacks any specific dates, names, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph identifies the management team (CEO, COO, Chief Accounting Officer) as responsible for cybersecurity risk management and describes their general experience, but it lacks any specific verifiable facts such as dates, names, or quantified details.


reasoning: The paragraph focuses on the company's internal processes for assessing and managing cybersecurity risks, including specific management roles (CIO and CISO) that oversee the program, aligning with Risk Management Process rather than personal attributes.


reasoning: The paragraph describes management's responsibilities for identifying, assessing, and mitigating cybersecurity risks through internal processes, with no focus on individual qualifications or specific verifiable details.


reasoning: The paragraph focuses on the Board of Directors and its committees (including named non-generic committees like Technology and Innovation Committee and Governance Committee) overseeing cybersecurity risks through the ERM program, which is a board governance activity.


reasoning: The paragraph describes the company's internal risk management framework and guidelines for cost estimation, which is a core element of risk management processes. It contains no specific facts, names, dates, or standards, making it generic boilerplate applicable to any company.


reasoning: The paragraph discusses potential business and financial impacts from cybersecurity risks, including costs and materiality, without describing any actual incident or specific details, aligning with Strategy Integration and Generic Boilerplate due to lack of verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity technologies, tools, and processes, including third-party assessments and PCI DSS certification, which fall under risk management activities.


reasoning: The paragraph details the company's internal cybersecurity processes, such as the SOC and threat detection programs, with the CISO role as a specific fact, aligning with Risk Management Process rather than person-focused Management Role.


reasoning: The paragraph describes a specific cybersecurity incident (March 2020 ransomware attack) with details on access, response actions, and potential impacts, which fits the Incident Disclosure category.


reasoning: The paragraph focuses on the Risk Management Steering Committee's function in monitoring and reporting cybersecurity threats, indicating an internal risk management process rather than board oversight or individual roles.


reasoning: The paragraph describes the company's internal data security processes, such as storage and handling of customer information, with named cloud platforms providing verifiable details.


reasoning: The paragraph focuses on the design and objectives of the information security program, with the CISO and reporting line as specific organizational details, indicating internal risk management processes.


reasoning: The paragraph describes the board of directors' oversight of cybersecurity risk, with the board as the grammatical subject, fitting the Board Governance category.


reasoning: The paragraph describes a specific cybersecurity incident in 2019, including the wire fraud scheme and response actions like implementing MFA, which aligns with the Incident Disclosure category.


reasoning: The paragraph's grammatical subject is the Audit Committee, a board committee, overseeing cybersecurity risk assessment and management, which aligns with Board Governance. It contains no verifiable facts, named standards, or company-specific details, making it generic boilerplate.


reasoning: The paragraph focuses on the management team's responsibilities and qualifications for cybersecurity risk management, but it uses generic terms like 'management team' and 'external cybersecurity consultants' without any specific names, dates, or verifiable details, making it boilerplate.


reasoning: The paragraph states the absence of cybersecurity incidents, which does not describe board governance, management roles, risk processes, third-party risk, actual incidents, or strategy integration, fitting 'None/Other'. It includes a specific date (December 31, 2024), making it Firm-Specific.


reasoning: The paragraph describes the qualifications, experience, and certifications of the CIO and CISO, which are management roles, fitting the 'Management Role' category. It contains multiple verifiable facts such as specific years of experience and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes actual cybersecurity incidents that occurred in September 2022, including details about unauthorized access, scope of data compromised, and response actions, which directly aligns with the Incident Disclosure category.


reasoning: The paragraph focuses on internal cybersecurity processes such as education, monitoring, vulnerability management, and incident response planning led by the CIO, which aligns with risk management activities rather than describing a person's credentials or board oversight.


reasoning: The paragraph describes the management team's organizational structure and leadership in the cybersecurity risk management program, which is an internal process rather than focusing on individual role identification or board oversight.


reasoning: The paragraph lists general cybersecurity risks without describing any specific processes, governance structures, or incidents, making it non-substantive for the purpose of these categories.


reasoning: The paragraph centers on the ISO's role, qualifications, and reporting line, with the ISO as the grammatical subject, fitting Management Role. It contains multiple hard verifiable facts: a specific number of years of experience and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats in 2024, which aligns with Strategy Integration. The specific year reference makes it firm-specific rather than generic boilerplate.


reasoning: The paragraph centers on vendor oversight, including due diligence and security standards for third-party providers, which aligns with Third-Party Risk. It lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph details internal cybersecurity measures and processes, such as VPN, MFA, EDR, and SIEM, which are core components of risk management. It does not reference board oversight, specific personnel, incidents, or strategic elements, confirming it as Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes (risk assessment, controls, incident response) led by a security team, which aligns with Risk Management Process. It contains no verifiable facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph centers on a materiality assessment of cybersecurity threats to the company, using a specific third-party incident as an example to support its conclusion, which aligns with Strategy Integration. It contains two named third-party firms (Change Healthcare and UnitedHealth Group), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal processes for monitoring and escalating cybersecurity incidents, which is central to risk management, and it includes the specific role of CISO, making it firm-specific.


reasoning: The paragraph primarily identifies the CIO, their reporting line to the CEO, and professional qualifications including CISSP certification, which aligns with the Management Role category for detailing responsible personnel.


reasoning: The paragraph describes management's responsibilities in cybersecurity processes like risk assessment and incident response, which aligns with internal risk management processes, and it contains no specific facts, making it generic boilerplate.


reasoning: The paragraph focuses on the board's oversight of cybersecurity risk and explicitly mentions a 'cybersecurity committee,' which is a named non-generic committee indicating firm-specific governance.


reasoning: The paragraph centers on the vCISO's role, qualifications (CISSP certification and experience), and reporting lines, making Management Role the most applicable category. It contains firm-specific facts such as the cybersecurity-specific title and named certification.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as oversight and risk assessment programs, without referencing board governance, management roles, incidents, or specific details.


reasoning: The paragraph describes generic internal cybersecurity risk management processes such as policies, training, and incident response procedures, with no specific details or verifiable facts.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk oversight and management, including delegation to the Audit Committee and CFO, and operational management by the Director of IT, but it lacks any hard verifiable facts or firm-specific details beyond generic roles and common practices.


reasoning: The paragraph details the company's internal cybersecurity procedures for monitoring, detection, and incident response, including specific team compositions, which aligns with Risk Management Process.


reasoning: The paragraph describes a specific cybersecurity incident involving Progress software, including public disclosure, customer notifications, and an SEC investigation request on a specific date, which aligns with incident disclosure.


reasoning: The paragraph is a generic acknowledgment of cybersecurity risks and potential material impacts with no specific details about governance, processes, or incidents, and as a SPAC, it lacks substantive disclosure, fitting None/Other.


reasoning: The paragraph describes a specific cybersecurity incident, including the impact on IT systems, containment and restoration actions, and detailed financial costs and insurance proceeds, which aligns with the 'Incident Disclosure' category.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, such as policies and third-party partnerships, with no mention of board governance, specific management roles, or actual incidents.


reasoning: The paragraph describes the company's internal cybersecurity program design and employee training processes, which are core elements of risk management. The named internal policy ('Technology Acceptable Use Policy') is a specific fact that identifies something unique to this company, making it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity incident response and vulnerability management processes, including escalation to specific roles and reporting to a named committee, which centers on risk management procedures rather than board oversight or management roles alone.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including framework adoption and security practices, fitting Risk Management Process. It names the NIST framework but contains no other unique details, making it Sector-Adapted.


reasoning: This paragraph is a standalone materiality conclusion stating no material impact from cybersecurity threats, which falls under Strategy Integration per the tiebreakers, and it contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program and processes for managing risks, which is central to Risk Management Process. It names the NIST Cybersecurity Framework, a recognized standard, but contains no unique details about the company, making it Sector-Adapted.


reasoning: The paragraph describes a specific cybersecurity incident (a phishing scam in 2024) and the company's response actions, which aligns with Incident Disclosure. The date '2024' is a firm-specific fact, but no other verifiable details are present, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and specific measures, including enrollment in named threat intelligence services, which are unique to this disclosure.


reasoning: The paragraph focuses on the qualifications and experience of a specific management role (Vice President of IT), including a verifiable duration of experience, which fits the Management Role category.


reasoning: The paragraph describes the interim leadership of the information security program by an IT Manager with specific experience, focusing on management roles and qualifications. It contains two hard verifiable facts: a specific date (February 25, 2025) and a specific duration (two years).


reasoning: The paragraph describes management's internal process of providing regular cybersecurity reports to the Board and evaluating the program, which aligns with risk management processes rather than focusing on board oversight or specific roles.


reasoning: The paragraph describes management roles leading cybersecurity processes such as hiring, budgeting, and risk integration, which aligns with Risk Management Process. It lacks specific verifiable facts like dates, amounts, or named standards, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's internal processes for assessing, identifying, and managing cybersecurity risks, including governance and oversight structures, with a specific management role mentioned.


reasoning: The paragraph focuses on the escalation of cybersecurity incidents to the board and audit committee for oversight, and highlights a board member's specific IT experience in the mortgage industry, making Board Governance the primary category with firm-specific details.


reasoning: The paragraph focuses on the internal risk management process through a cross-functional governance committee, with specific cybersecurity roles and named committees indicating firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity incident response plan and procedures, which falls under risk management processes. It contains no specific dates, named entities, or verifiable details, making it generic boilerplate applicable to any company.