reasoning: The paragraph primarily describes the company’s internal incident escalation and response process, including management and committee notification pathways. Although it mentions the Chief Financial Officer and Audit Committee, those are generic governance references and do not make board oversight or management-role identification the main subject.


content_category: Management Role

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph is centered on senior management—especially the chief executive officer and other executives—and their role in assessing cyber risk and briefing the audit committee. Although it references committee oversight, the grammatical subject and main focus are management responsibilities rather than the board or a named cybersecurity leader.

provider: openai

stage: benchmark


content_category: Risk Management Process

category_confidence: high

reasoning: The paragraph describes the company's internal cybersecurity activities—scans, penetration tests, vulnerability assessments, tabletop exercises, and use of external assistance—as part of its risk management process. It does not focus on board oversight, management qualifications, third-party vendor risk, or any actual incident.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk assessment and review process, led by a cross-functional council and management, rather than focusing on board oversight or the qualifications of specific individuals. It includes firm-specific governance structure details and cybersecurity-specific roles, which makes it Firm-Specific.


specificity_confidence: medium

reasoning: The paragraph primarily describes the company's cybersecurity risk management activities and controls, including monitoring, assessments, vulnerability management, and resilience measures. Although it mentions oversight of key third-party providers, that is only one component of the broader internal risk management approach, so Risk Management Process is the best fit.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk management activities, including policies, assessments, controls, training, incident response, and continuous improvement. Although it mentions third-party service providers, vendor oversight is only one component of the broader internal process rather than the central topic.


reasoning: The paragraph describes the company's internal cybersecurity risk management process, specifically its integration into the broader enterprise risk management structure. It does not focus on board oversight, management personnel, third parties, or any actual incident.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident, including when it occurred, the nature of the attack, affected servers, restoration actions, and operational impact. Although it begins with a materiality statement, the core of the paragraph is the incident narrative and response.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk governance and escalation process—who assesses risks, how a management committee reviews them, and how reporting flows upward. Although a CISO is mentioned, the focus is on the functioning of the risk management process rather than the individual's qualifications or background.


content_category: Strategy Integration

reasoning: The paragraph is a standalone materiality assessment stating that known cybersecurity threats and prior incidents have not materially affected the company and are not reasonably likely to do so. The cross-reference to risk factors does not change the main point, which is the materiality conclusion.


reasoning: The paragraph focuses on the potential business, operational, financial, and reputational impacts of cybersecurity risks rather than governance, management roles, or a specific incident. It is framed as general risk/materiality disclosure with no company-unique facts, dates, named roles, frameworks, or quantified details.


reasoning: The paragraph primarily describes the company’s internal incident escalation and response process, including how incidents are elevated to management and the board committee, rather than focusing on the board’s oversight role or an individual executive’s qualifications. It includes one firm-specific role title, but otherwise uses mostly generic process language.


reasoning: The paragraph describes how the company integrates cybersecurity risk assessment and incident response into its internal enterprise risk management processes. It does not focus on board oversight, management personnel, third-party risk, or any specific incident.


reasoning: The paragraph’s main point is a materiality assessment and strategic framing: it says identified threats were not reasonably likely to materially affect the company and references broader risk-factor disclosure. Although it briefly mentions ERM, the central disclosure is the materiality conclusion rather than a detailed internal cybersecurity process.


reasoning: The paragraph is primarily about the company's internal cybersecurity oversight and operational processes through management committees that help prevent, detect, mitigate, and remediate cyber risks. Although specific roles are named, the focus is on how the function operates rather than on the qualifications or background of any individual manager.


reasoning: The paragraph’s main substantive point is a materiality/status statement that the company is not aware of material cybersecurity incidents, plus a related risk-factor cross-reference, rather than describing governance, management roles, or internal risk processes. The specific date makes the disclosure firm-specific, but there are not two hard verifiable facts to elevate it to quantified-verifiable.


reasoning: The paragraph primarily describes the company's own cybersecurity program assessment process and benchmarking, which fits Risk Management Process. Although it mentions a third-party firm and reporting to the Audit Committee, those are supporting details rather than the main subject.


reasoning: The paragraph is mainly about the company's internal risk management process: how the ERMC receives risk assessments, remediation plans, and information security inputs to incorporate cybersecurity into enterprise risk decisions. Although management roles are mentioned, the focus is on the process rather than on any individual's qualifications or reporting line.


reasoning: The paragraph is centered on the VP of IT's leadership role and qualifications, making management the primary subject rather than the broader process alone. It also includes a firm-specific cybersecurity-related role, which elevates it above generic or framework-only disclosure.


reasoning: The paragraph is primarily about the company's internal cybersecurity risk management function—specifically which internal teams establish policies, oversee risk, and validate controls. Although the Board's Audit Committee is mentioned, the board is not the main subject and the focus remains on internal process ownership and oversight.


reasoning: The paragraph’s main point is a materiality assessment that cybersecurity threats have not materially affected, and are not reasonably likely to materially affect, the company’s business, results, or financial condition. Although it briefly references a prior outage and response actions, that incident mention is secondary to the materiality conclusion, which places it in Strategy Integration.


reasoning: The paragraph primarily identifies the management roles responsible for cybersecurity programs and describes their reporting structure and leadership responsibility. Although it mentions annual assessments and risk reviews, the main focus is on the CIO and director of IT as the leaders of cybersecurity at the relevant entities.


reasoning: The paragraph primarily describes the company's internal management structure for assessing and managing cybersecurity and related operational risks, which makes it a risk management process disclosure rather than board oversight or a person-focused management role disclosure. Its named ISSC and specific cross-functional departmental composition make it firm-specific.


reasoning: The paragraph describes the company's internal cybersecurity practices for assessing risks, monitoring systems, and using security capabilities to detect and respond to threats. It does not focus on board oversight, management personnel, third-party oversight, or any specific incident.


reasoning: The paragraph describes the company’s internal cybersecurity practices and how they are integrated into risk management, such as testing, recovery planning, encryption, and program review. It does not focus on board oversight, management qualifications, third-party/vendor oversight as the main topic, or any actual cybersecurity incident.


content_category: Board Governance

reasoning: The paragraph is primarily about how the Board and its committees oversee cybersecurity risk, with the Audit Committee and Board as the main actors. It includes a firm-specific fact through the identified CISO role, but otherwise consists mostly of standard governance language.


reasoning: The paragraph’s most substantive governance disclosure is that the full board retains oversight of cybersecurity risk and has not delegated that oversight to a committee. Although it also mentions management responsibilities and a materiality statement, the board’s oversight role is the clearest primary topic.


reasoning: The paragraph’s main point is a materiality/status statement that the company has not experienced any material cyber breaches, coupled with generic language about reviewing policies and procedures. It does not describe a specific incident, governance body, management role, or concrete risk management process details.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including how controls are structured, tested, and benchmarked. Its only qualifying specific detail is the reference to the NIST framework, which makes it sector-adapted rather than firm-specific.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including unauthorized access, the attack vector, affected data, and response actions taken. It contains one qualifying firm-specific fact—a precise date—but not two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: Although the paragraph opens with board risk oversight, the most substantive and distinguishing content is the identification and qualifications of a specific management role responsible for IT/cyber-related functions. The named IT leadership role and stated 20+ years of experience make the disclosure firm-specific.


reasoning: The paragraph is primarily about the board of directors' oversight of cybersecurity risk and the reports it receives from management, making Board Governance the best fit. It contains only generic governance language and non-qualifying reporting cadences, with no firm-specific named roles, committees, frameworks, dates, or other qualifying facts.


reasoning: The paragraph focuses on the company's internal cybersecurity risk assessment and management processes, including integration with enterprise risk management. It does not center on board oversight, management qualifications, third-party risk, or any actual incident.


reasoning: The paragraph is primarily about the Audit Committee's oversight of cybersecurity risk, including briefings, dialogue, strategic involvement, and annual review, which fits board-level governance. It does not include any qualifying specific facts because the references are to generic roles and committees and use boilerplate oversight language.


reasoning: The paragraph describes the company's process for identifying, assessing, and managing cybersecurity risk, even though outside parties assist with those activities. It does not center on vendor oversight requirements or any actual incident, so Risk Management Process is the best fit.


reasoning: The paragraph describes a real cybersecurity incident's aftermath by noting regulator inquiries and the company's response and cooperation. It contains no qualifying specific facts such as dates, named firms, named systems, or quantified details.


reasoning: The paragraph primarily describes the company's cybersecurity monitoring, auditing, and incident response activities, even though they are carried out by the Director of Infrastructure. It is focused on what the function does rather than the individual's qualifications or reporting role.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk briefing and remediation process—how management and the board are kept informed to support prevention and response—rather than focusing on the qualifications or oversight role of a specific person or committee. It includes one firm-specific fact, the presence of a CIO in the management briefing structure.


reasoning: The paragraph describes the company's internal cybersecurity risk identification, assessment, and mitigation activities, making it a risk management process disclosure. It contains only generic descriptions of a cybersecurity team and ongoing processes, with no qualifying specific facts, named standards, or verifiable details.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management program and how it is structured within overall risk management, which fits Risk Management Process. Its only qualifying specific detail is reference to the NIST Cybersecurity Framework, with no firm-unique facts.


reasoning: The paragraph describes the company's internal method for assessing and selecting cybersecurity controls, which is a risk management process. Its only qualifying specific detail is the named CIS Critical Security Controls framework, with no firm-unique roles, dates, or verifiable company-specific facts.


reasoning: This paragraph is primarily about board-level oversight because the Audit Committee is the subject overseeing cybersecurity risk and receiving reports. It includes a firm-specific cybersecurity role fact—the CTO—but no two hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity controls, policies, and training practices, making it primarily about its risk management process. It contains only generic security measures and boilerplate training language, with no qualifying firm-specific facts or named frameworks.


content_category: Third-Party Risk

reasoning: The paragraph is centered on dependence on third-party software providers and the company’s review of their controls through Service Organization Controls reports, making vendor oversight the main topic. The reference to Microsoft is a company-specific fact, while the rest is otherwise fairly general.


reasoning: The paragraph is centrally about how the bank evaluates, contracts with, and monitors third-party service providers, so Third-Party Risk is the best fit. It does not include qualifying firm-specific facts such as named roles, committees, dates, firms, products, or other verifiable details.


reasoning: The paragraph is centrally about oversight of third-party service providers, including onboarding risk assessments, required security measures, and contractual breach-notification obligations. It contains no named vendors, dates, frameworks, tools, committees, roles, or other qualifying specific facts.


reasoning: The paragraph is primarily about board-level oversight, with the Audit Committee and full Board described as overseeing cybersecurity risk and receiving reports. It includes one firm-specific fact—a cybersecurity-specific management role (Chief Information Officer)—but no two hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph discusses the company's planned cybersecurity activities and improvements to its internal risk management practices, such as monitoring, tabletop exercises, and posture adjustments. It does not center on board oversight, management qualifications, third-party vendor oversight, or an actual incident.


reasoning: The paragraph is not about governance, management, or risk-management processes; it briefly references past cyber-attacks but provides no incident details, and its main point is the potential harm to the business from future disruptions. Because it contains no dates, named systems, firms, roles, or other qualifying facts, it is generic boilerplate.


reasoning: The paragraph is primarily framed around oversight by the Board of Directors and its Audit Committee, with the management discussion serving to explain how that oversight is informed. It includes firm-specific details about the CTO’s role and experience, but not two or more qualifying hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity program elements, including risk assessments, security controls, training, incident response planning, and vendor risk as one component of the overall process. Because it contains no named frameworks, specific roles, dates, tools, firms, or other qualifying firm-unique facts, it is generic boilerplate.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk assessment, safeguard evaluation, and monitoring activities, so it is about the risk management process rather than the individual executive. It becomes firm-specific because it identifies a cybersecurity-relevant management role, the Chief Information Officer, as part of that process.


reasoning: The paragraph describes the company’s internal cybersecurity program structure and governing standards, which makes it a risk management process disclosure. It is firm-specific because it names the company’s own Enterprise Information Security Framework (EISF), beyond merely citing industry standards.


reasoning: The paragraph primarily describes an actual cybersecurity event, including when it was detected, what type of incident occurred, and its operational impact on the company. Although it also mentions costs and materiality, the core disclosure is the incident narrative itself.


reasoning: The paragraph is primarily about the Board’s oversight of cybersecurity risk and how that oversight is informed, making Board Governance the best fit. Although management roles are named, they are described mainly in support of the Board and Audit Committee oversight structure.


reasoning: This paragraph primarily describes a real cybersecurity incident, including how access occurred, what data was affected, and the response actions taken, so Incident Disclosure is the best fit. It includes a specific date, which makes it firm-specific, but it does not contain two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph’s main point is a materiality assessment stating that cybersecurity threats have not materially affected, and are not reasonably likely to materially affect, the company’s business, results, or financial condition. The additional healthcare reference and risk-factor cross-reference do not add substantive incident, governance, or process detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities, including risk assessments, security controls, training, incident response planning, and vendor risk processes. Although third-party risk is mentioned, it is only one component of the broader internal program, so the central topic is risk management process.


reasoning: The paragraph is primarily about management responsibility, identifying the Chief Risk Officer role and its relationship with the CISO in overseeing cybersecurity risk. It does not focus on board oversight or describe the company’s cyber processes in detail.


reasoning: This paragraph describes an actual cybersecurity incident, stating that it impacted the company's network and that incident response protocols were activated and an investigation completed. Although it includes a materiality conclusion, the primary focus is the incident and response actions, not broader strategy or financial assessment.


reasoning: The paragraph is primarily about the management person responsible for cybersecurity and his reporting line and qualifications, so Management Role is the best fit. It includes multiple specific numeric experience facts, which makes the disclosure Quantified-Verifiable.


reasoning: The paragraph is centrally about assessing and overseeing third-party service providers, including onboarding diligence, questionnaires, audit reports, and contract terms, so Third-Party Risk is the best fit. It contains no named frameworks, roles, firms, dates, or other qualifying specific facts.


reasoning: The paragraph describes the company's internal cybersecurity risk identification, assessment, and management processes for its systems and data. Although it mentions third-party hosted services, vendor oversight is not the central topic, so this is best classified as Risk Management Process.


reasoning: The paragraph primarily describes the company’s internal cybersecurity activities and processes—implementation, training, testing, audits, and use of outside assistance—rather than focusing on the CISO’s qualifications or board oversight. It includes a firm-specific fact because it identifies a cybersecurity-specific role, the chief information security officer.


reasoning: The paragraph is centrally about oversight of vendors and third-party relationships, including onboarding and reviews of vendors with access to sensitive data, so Third-Party Risk is the best fit. It does not include qualifying firm-specific facts under the stated rules, and the cited interagency guidance is not one of the recognized frameworks that would make it Sector-Adapted.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities—using external service providers to help evaluate and improve its policies and procedures. It is not focused on oversight of vendor risk itself, and it contains no qualifying specific facts such as named firms, frameworks, dates, or roles.


reasoning: The paragraph primarily describes the company's internal cybersecurity controls and improvement activities, such as change management, patching, multifactor authentication, backups, and monitoring. The brief mention of reporting significant issues to the Audit Committee is secondary and does not make board oversight the main topic.


reasoning: The paragraph is primarily about management personnel responsible for cybersecurity and the qualifications of the Vice President, Information Security, rather than the company’s cybersecurity processes themselves. It includes firm-specific role titles and a quantified experience statement, but not two qualifying hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph is primarily about the board of directors' oversight of cybersecurity risk, with the board as the grammatical subject. It contains only generic governance language and references to the audit committee, which do not qualify as specific facts.


reasoning: The paragraph is primarily about board-level oversight of cybersecurity, with the Board of Directors and Audit Committee as the main subjects. Although it mentions a management role, that reference supports the governance reporting structure rather than making management the central topic.


reasoning: The paragraph’s main point is a materiality statement that no identified cybersecurity incident has had a material impact, followed by general risk/disclaimer language. It does not describe an actual incident or discuss governance, management roles, or specific risk processes.


reasoning: The paragraph is centered on materiality, potential costs, and business/regulatory consequences of cybersecurity incidents rather than describing governance roles or a concrete incident narrative. Although it mentions past breaches and a reporting period, it does not describe what happened in any specific incident, so Strategy Integration is the best fit.


reasoning: The paragraph is primarily about how the Board and its committees oversee cybersecurity, with the Board and committee structure serving as the main subject. Although it includes management qualifications, those details support the governance discussion rather than making management roles the central focus.


reasoning: The paragraph describes the company's internal cybersecurity practices—monitoring, incident response planning, and employee training—so it is best categorized as Risk Management Process. It contains no named frameworks, roles, systems, dates, firms, or other qualifying specific facts, making it generic boilerplate.


reasoning: The paragraph is a standalone materiality assessment stating that identified cybersecurity risks are not expected to significantly affect operations, financial condition, or business objectives. It does not describe governance, management roles, or specific risk management processes.


reasoning: The paragraph is mainly about the company's internal cybersecurity function and the team implementing the cybersecurity program, rather than board oversight or a single executive's biography. It includes firm-specific details through a cybersecurity-specific role and a quantified experience figure, but not two qualifying hard verifiable facts for a higher specificity level.


reasoning: The paragraph is primarily about an internal cybersecurity governance mechanism and how it supports prioritization, oversight, and incident response, which fits the company’s risk management process more than board oversight or a single management role. It includes firm-specific facts such as a named Cybersecurity Committee, its four-member composition, and specific cybersecurity-relevant roles, but lacks two hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal incident tracking, escalation, and materiality assessment processes, making it primarily about cybersecurity risk management procedures. References to vendors and third-party service providers are incidental components of that internal process, not the central focus.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred, the disruption to IT systems, the investigation, containment, remediation, and notification actions. It also includes a materiality statement, but the incident narrative is the central focus.


reasoning: The paragraph describes the company's internal cybersecurity practices—monitoring, security tools, and employee training—so it is primarily about risk management processes. It contains no qualifying firm-specific facts, named standards, dates, firms, tools, or other verifiable details beyond generic security practices.


reasoning: The paragraph is primarily about the company's own cybersecurity risk management activities—testing, audits, threat assessments, penetration testing, and red-team exercises—even though external experts are involved. It is not centered on oversight of vendor risk, but on internal process design and evaluation.


reasoning: The paragraph focuses on cyber insurance coverage and its potential limits, which fits Strategy Integration rather than incident description or risk process. It provides no firm-specific dates, amounts, named insurers, or other qualifying specific facts.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk assessment and safeguard processes, including how risks are assessed and tested, rather than focusing on board oversight or the qualifications of a specific individual. Although it names a committee and the CISO, those details support a broader discussion of the company's risk management function.


reasoning: The paragraph is primarily about what management does in operating the company’s cybersecurity assessment and management processes—such as budgeting, staffing, integrating cyber into risk management, and incident preparation—rather than describing board oversight or the qualifications of a specific individual. Although management roles are mentioned, the focus is on the function and activities of the cybersecurity program.


reasoning: The paragraph is centered on a materiality conclusion that identified cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, the company’s business, results, or financial condition. The reference to risk factors is secondary and does not add substantive incident or process detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and the standards it uses, which fits Risk Management Process. It names recognized frameworks but does not provide company-unique roles, dates, tools, firms, or quantified details, so it is Sector-Adapted.


reasoning: The paragraph is primarily about Board and committee oversight of cybersecurity, with the Board and Audit Committee as the main subjects. It includes one firm-specific fact—the involvement of a CISO—but otherwise consists largely of standard governance disclosure.


reasoning: The paragraph is a standalone materiality assessment stating that known cybersecurity threats and previously identified incidents have not materially affected the company’s business strategy, results, or financial condition. It does not describe an incident or a risk management process; the cross-reference to Risk Factors does not change the main focus.


reasoning: The paragraph focuses on the company's internal cybersecurity risk assessment and management processes, including the framework and incident response plan it uses. It is not about board oversight, management qualifications, or a specific incident.


reasoning: The paragraph is primarily about the board of directors' oversight of cybersecurity risk and how executive officers report material incidents to the board. Although it briefly mentions the CEO's experience, the main focus is board-level oversight rather than a specific management cybersecurity role.


reasoning: The paragraph describes an actual cybersecurity event—a phishing scam—and the company’s response actions, which makes Incident Disclosure the best fit. Although it also includes a materiality statement, the main substance is the incident itself and what was done afterward.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment, incident response, training, and monitoring processes. Although third-party selection is mentioned, it is only one component of the broader internal risk management program rather than the central topic.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred and that unauthorized access to company systems took place, which makes Incident Disclosure the best fit. Although it also includes materiality language, the main focus is the incident narrative itself.


reasoning: The paragraph is centrally about how the company evaluates and manages cybersecurity risks arising from vendors, including assessments and contractual requirements imposed on higher-risk vendors. That makes Third-Party Risk the best fit rather than general risk management.


reasoning: The paragraph primarily describes the company's internal escalation and response process for significant cybersecurity threats, making it a risk management process disclosure rather than a role-focused biography or board oversight paragraph. It includes firm-specific facts such as cybersecurity-specific roles and a named Risk Committee, but lacks two clearly hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph's main point is a boilerplate materiality/risk statement that cybersecurity threats could materially affect the company's operations, strategy, results, or financial condition. Although it mentions the cybersecurity program, it does not describe substantive internal processes and instead emphasizes potential business impact and a cross-reference to Risk Factors.


reasoning: The paragraph primarily describes the company's general cybersecurity risk management approach as part of its overall risk management program, including identifying, prioritizing, monitoring, and mitigating risks. Although the Board is mentioned, the main focus is the company's internal risk management process rather than board oversight details.


reasoning: The paragraph focuses on the company's internal cybersecurity risk assessment and mitigation processes, including integration into overall risk management, rather than on board oversight or the qualifications of a specific executive. The mention of the Vice President of IT is incidental to describing how the process operates.


reasoning: The paragraph is primarily about oversight by the board of directors and Audit Committee, making board governance the central topic. It contains no qualifying specific facts because the committee, CEO reference, and generic update cadence are all excluded under the specificity rules.


reasoning: The paragraph is about committee-level oversight, with the Committee receiving reports and updates from management on cybersecurity matters. It contains only generic governance language and no qualifying specific facts such as named roles, named committees, dates, firms, tools, or quantified details.


reasoning: The paragraph describes the company's internal cybersecurity practices—penetration testing, vulnerability assessments, and classification of findings—so it is primarily about risk management processes. It contains no qualifying specific facts such as named frameworks, roles from the allowed list, dates, firms, tools, or quantifiable verifiable details.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred, its operational disruption, data exfiltration, and post-incident remediation actions. It is Firm-Specific because it includes a specific month/year tied to the incident, but does not contain two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph is primarily a materiality and business-impact disclosure, stating that prior threats and incidents have not materially affected the company and noting the absence of certain cyber insurance coverage. It does not describe a specific incident or focus on governance or management roles.


reasoning: The paragraph primarily describes the company’s internal cybersecurity governance and execution processes: who oversees them, what the committee approves, how incidents are escalated, and which team implements strategy. Although specific roles are named, the focus is on the functioning of the cybersecurity program rather than the qualifications or background of an individual manager.


reasoning: The paragraph is primarily about which management roles lead cybersecurity efforts and their relevant experience, so Management Role is the best fit. It includes firm-specific roles and a quantified experience statement, but not two or more hard verifiable facts of the type required for Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident involving employee interactions with suspicious websites and notes containment and investigation results, making Incident Disclosure the best fit. It includes no qualifying specific facts such as dates, named firms, products, roles, or quantified details, so the specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes Tripadvisor’s internal management structure and processes for assessing, monitoring, and mitigating cybersecurity risk, rather than board oversight or a specific individual’s qualifications. It includes firm-specific named committees and a concrete cross-functional team structure, which makes it Firm-Specific.


reasoning: The paragraph’s main focus is the materiality and business impact of cybersecurity matters, including a statement that no 2023 threats materially affected the company and a forward-looking materiality caution. Although it briefly references a past incident and response actions, that incident mention supports the broader materiality discussion rather than serving as the primary incident narrative.


reasoning: The paragraph is centered on the Board's oversight role, with the Board as the grammatical subject receiving information and reviewing cybersecurity matters. It contains only generic governance language and no qualifying specific facts such as named committees, roles, dates, frameworks, or verifiable details.


reasoning: The paragraph is about board-level oversight responsibilities for cybersecurity, with the Audit Committee and Board of Directors as the subjects. It contains only generic governance language and no qualifying specific facts such as named non-generic committees, cyber-specific roles, dates, frameworks, or quantified details.


reasoning: The paragraph is primarily about how the Board and its committee receive reports and briefings on cybersecurity, making board oversight the central topic. The only qualifying specific fact is the mention of the Chief Information Officer; the references to the Board, the Committee, and external experts are otherwise generic.


reasoning: The paragraph describes the company’s internal cybersecurity awareness and employee training activities, which are part of its risk management process. It does not focus on board oversight, management qualifications, third-party oversight, or any actual cybersecurity incident.


reasoning: The paragraph is primarily about the company's internal cybersecurity risk management structure and how cyber risks are assessed and managed within its ERM-related processes. Although it names reporting lines and roles, the focus is on the function of the program rather than the qualifications or background of a particular executive.


reasoning: The paragraph primarily describes a real cybersecurity incident affecting a third-party intermediary, including what happened, the operational disruption to claims processing, and remediation/restoration steps. It also includes multiple independently verifiable facts, including named firms and exact dates, which makes it Quantified-Verifiable.


reasoning: The paragraph’s most specific substantive statement is that XPLR’s board oversees the provision of outsourced IT and cybersecurity services, making board oversight the best-fit category. It is firm-specific because it names particular affiliated entities—NEE Management and NEER—in connection with XPLR’s cybersecurity-related arrangements.


reasoning: The paragraph focuses on the board of directors' oversight of cybersecurity risk and management's day-to-day supervision, making board oversight the primary topic. It contains only generic governance language with no qualifying specific facts such as named committees, roles, frameworks, dates, or quantified details.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk assessment, reporting, and ERM integration processes. Although it references the Board and specific roles, those references are part of the broader description of the company's risk management process rather than the main subject.


reasoning: The paragraph is primarily about board-level oversight, with the Board of Directors and Audit Committee as the subjects overseeing cybersecurity risk. It contains only generic governance language and standard briefing cadence, with no qualifying specific facts under the rubric.


reasoning: The paragraph focuses on the potential business, legal, financial, and reputational impacts of cybersecurity incidents rather than governance, management roles, or specific risk management processes. It is entirely generalized and contains no company-specific facts, dates, named roles, frameworks, or other qualifying details.


reasoning: The paragraph focuses on how the company organizes and runs its cybersecurity risk management program, rather than on the qualifications of a named individual or on board oversight. It includes a firm-specific team composition spanning IT, finance, legal, and operations, which makes it more specific than generic boilerplate.


reasoning: The paragraph is centered on named management roles, their reporting lines, and their cyber responsibilities, making Management Role the best fit. It includes firm-specific role titles and reporting structure, but no two hard verifiable facts such as dates, dollar amounts, or named vendors/tools.


reasoning: The paragraph primarily describes the company's internal cybersecurity-related processes for threat awareness, personnel notification, training, and risk identification/assessment. Although it mentions consultants reporting to the Chief Financial Officer, the focus is on process activities rather than a management person's qualifications or board oversight.


reasoning: This paragraph primarily describes a real cybersecurity incident, including when it was discovered, the unauthorized access, containment and remediation actions, operational disruption, and status of recovery. Although it also includes a materiality statement, the main focus is the incident narrative itself.


reasoning: This paragraph primarily describes a real cybersecurity incident, including when it occurred, what systems were affected, and the company's response and findings. It includes a specific incident date and a company-specific reference to the Aurora acquisition systems, but not two hard verifiable facts sufficient for Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident, including unauthorized access to an employee email account, fraudulent diversion of company funds, detection, and resulting impact. Although it includes incident details, it does not contain qualifying specific facts such as a precise date, named firm, named system/product, or quantified loss.


reasoning: The paragraph primarily describes the company’s internal incident assessment and escalation process, which makes it a risk management process disclosure. Although the Audit Committee and Board are mentioned, they appear as escalation points rather than the main subject of the paragraph.


reasoning: The paragraph is about the board of directors overseeing significant risks and related risk-management processes, making board oversight the central topic. It contains only generic governance language with no qualifying specific facts.


reasoning: The paragraph focuses on the potential business and financial consequences of cybersecurity-related regulatory non-compliance, rather than describing governance, management roles, or specific risk management processes. It contains only generic statements with no firm-specific details, named frameworks, dates, roles, or verifiable facts.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including ERM integration, policies, and controls, rather than focusing mainly on board oversight. It is Firm-Specific because it includes a named committee and a named framework, though it does not include two hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph centers on the ISO's reporting responsibilities and escalation role, making management's role the primary topic. Although the Board and BRCC are mentioned, they are described mainly as recipients of the ISO's reporting and escalation process.


reasoning: The board of directors is the grammatical subject and the paragraph focuses on its oversight of cybersecurity-related risks, which fits Board Governance. It contains only generic governance language with no qualifying specific facts such as named committees, roles, dates, frameworks, or quantified details.


reasoning: The paragraph primarily describes the company's own cybersecurity and risk management processes, including how cyber risk is evaluated and incorporated into broader risk programs. Although third-party providers are mentioned, vendor oversight is presented as one component of the company's internal process rather than the central topic.


reasoning: The paragraph is centrally about how the company assesses and imposes security expectations on third-party vendors and contractors, which fits Third-Party Risk. It contains no qualifying specific facts such as named vendors, dates, frameworks, tools, or other firm-unique details.


reasoning: This paragraph describes the effects and resolution status of an actual cybersecurity incident, including operational continuity and system restoration, so it is best categorized as Incident Disclosure. It includes a specific restoration date and identifies named services affected by the incident context.


reasoning: The paragraph primarily describes the company’s internal cybersecurity function and responsibilities—risk assessment, security controls, and incident response—rather than focusing on the qualifications or reporting line of a specific individual. The referenced information technology manager is incidental to the description of the process-oriented security team.


reasoning: The paragraph describes the company’s internal reporting process for cybersecurity risk within its risk management program, rather than focusing on a specific management individual or making the board committee the grammatical subject. It includes a firm-specific named committee, the Enterprise Risk and Compliance Committee.


reasoning: The paragraph is primarily about the company's internal cybersecurity management function—specifically the CSC's day-to-day responsibility to monitor, manage, and integrate cybersecurity risk practices into business processes. It is not board oversight and is not focused on an individual's qualifications, so Risk Management Process is the best fit.


reasoning: The paragraph is a standalone materiality assessment stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company, which fits Strategy Integration. The cross-reference to Risk Factors does not add substantive process, governance, or incident detail.


reasoning: The paragraph is primarily about the company’s internal cybersecurity risk assessment, monitoring, testing, training, and incident response processes. Its only qualifying specific fact is the named NIST Cybersecurity Framework, which supports a Sector-Adapted specificity rating rather than a firm-unique one.


reasoning: The paragraph is primarily about board-level and committee oversight of cybersecurity risk, with the Board and Audit Committee as the subjects. It contains only generic governance language and no qualifying specific facts such as named non-generic committees, cyber-specific roles, dates, or quantified details.


reasoning: The paragraph primarily describes the company's internal governance structure and process for evaluating and addressing cybersecurity risks, with board oversight mentioned only incidentally. It does not focus on the board as the acting subject or on qualifications of a cybersecurity-specific management role.


content_category: None/Other

reasoning: This paragraph is only a generic statement that the company, as a start-up with limited operations, faces cybersecurity risks and describes common attack methods and consequences. It does not describe governance, management roles, a risk management process, third-party oversight, strategy integration, or any actual incident.


reasoning: The paragraph is only a general statement about the importance of IT systems, communications networks, and data security to the business, without describing governance, management roles, risk management processes, third-party oversight, strategy impacts, or any actual incident. It is therefore best treated as non-substantive background disclosure.


reasoning: The paragraph's main point is a materiality conclusion that known cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, the company. The rest is only a cross-reference to a risk factor, not a description of governance, management, processes, or a specific incident.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management oversight and review process, even though management is the subject. It does not identify a specific cybersecurity executive or provide qualifications, so it is better classified as Risk Management Process rather than Management Role.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk management and incident response process, including monitoring, response, remediation, and materiality assessment. Although management is mentioned, the focus is on what the function does rather than on any specific cybersecurity-qualified role or individual.


reasoning: The paragraph is centered on named management roles and their responsibilities for cybersecurity-related activities, making Management Role the best fit. While it touches on risk management activities, the primary focus is who in management is responsible rather than the broader process itself.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk assessment, auditing, monitoring, and certification activities, which makes it a risk management process disclosure. It also includes multiple verifiable firm-specific facts, including a long-held ISO 27001 certification, a specific period-end date, and a quantified expansion of certification scope.


reasoning: The paragraph primarily describes the company's general approach to assessing, identifying, and managing cybersecurity risk through policies, standards, processes, and investments. Although it briefly mentions board and management oversight and includes a materiality statement, the main focus is the company's internal cybersecurity risk management program.


reasoning: The paragraph is centered on the experience, credentials, and roles of cybersecurity-related management personnel, so it fits Management Role. It includes multiple verifiable facts, including named cybersecurity roles and quantified years of experience, which supports Quantified-Verifiable specificity.


reasoning: The paragraph is centered on the CISO’s background, qualifications, and the experience profile of the supporting information security team, so it is primarily about management roles rather than process. It includes multiple firm-specific, numeric facts about the CISO and team composition, supporting a Quantified-Verifiable rating.


reasoning: The paragraph is primarily about identified management personnel responsible for cybersecurity and their backgrounds, responsibilities, and interactions. Although it briefly mentions reporting to the Audit Committee and program topics, the main focus is on management roles rather than board oversight or the risk process itself.


reasoning: The paragraph is primarily about board-level oversight of cybersecurity risk, with the board and Audit Committee as the main subjects. Although management responsibilities are mentioned, the disclosure remains focused on governance structure and uses only generic roles and committees without firm-specific details.


reasoning: The paragraph’s main point is a materiality assessment: cybersecurity threats have not materially affected the company, but a material incident could affect business strategy, results of operations, or financial condition. The reference to risk factors is ancillary and does not change the paragraph from a strategy/materiality disclosure.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management program, including how risks are assessed, monitored, and managed, with board and management references serving as supporting context. Because it identifies cybersecurity-specific management roles (CIO and CISO), it is more than generic boilerplate and is firm-specific.


reasoning: The paragraph primarily describes the company’s internal cybersecurity incident reporting, escalation, recovery, and materiality assessment processes, which fits Risk Management Process. Mentions of the CISO, CIO, Board, and Audit Committee are secondary to the description of the process itself.


reasoning: The paragraph is primarily about management personnel coordinating cybersecurity oversight and reporting, rather than describing the company’s cyber processes themselves or making the board the main actor. Although the audit committee and board are mentioned, the management roles are the grammatical subjects throughout.


reasoning: The paragraph primarily describes the company's own cybersecurity risk assessment and oversight processes, with third-party providers mentioned as one component of that process rather than as the central topic. It does not include qualifying firm-specific facts under the provided rules; the consultants and auditors are unnamed and the cadence/details are generic.


reasoning: The paragraph’s main point is the potential business and operational impact of cybersecurity incidents affecting the company or related parties, which fits Strategy Integration rather than a description of governance or risk processes. It contains no firm-specific details, named roles, frameworks, dates, or other qualifying facts.


reasoning: The paragraph is primarily about how the company organizes and operates its internal cybersecurity function—maintaining the program, monitoring technology trends, and overseeing training—so it is best categorized as Risk Management Process. It includes firm-specific organizational details, including a named Cybersecurity Team and the CTO's participation.


reasoning: This paragraph is primarily a materiality/cross-reference statement about whether cybersecurity risks have affected or are reasonably likely to affect the company’s business strategy, results of operations, or financial condition. It does not describe governance, management roles, or a specific incident.


reasoning: The paragraph primarily focuses on the ISO as a person—describing the role and emphasizing experience and certifications—so Management Role is the best fit. It also contains multiple verifiable facts, including a cybersecurity-specific title, quantified experience, and named certifications.


reasoning: This paragraph is principally about board-level oversight of cybersecurity, with the board and its committee as the grammatical subjects. It describes how the board supervises cyber risk through a specifically named cybersecurity risk committee.


reasoning: The paragraph is primarily about the CISO’s role and qualifications, with the board oversight reference included only briefly at the end. It contains multiple firm-specific, externally checkable facts about the cybersecurity leader, including the named role, CISSP credential, and quantified experience.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk assessment, monitoring, testing, disaster recovery, and integration into enterprise risk management, which fits Risk Management Process. Although the Board is mentioned, it is not the main subject of the paragraph.


reasoning: The paragraph describes the company’s internal cybersecurity practices and policy review process, making it a risk management process disclosure. It does not identify any named framework, role, committee, firm, date, tool, or other qualifying specific fact.


reasoning: The paragraph is anchored on the CIO as a person—his reporting line, experience, and certification—so Management Role is the best fit, even though it also mentions cybersecurity activities performed under his direction. It includes firm-specific facts about the CIO and his CISSP certification, but not enough clearly qualifying hard verifiable facts to reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity controls and operational practices, such as monitoring, vulnerability management, configuration management, and threat detection, so it is best classified as Risk Management Process. It does not include qualifying specific facts like named frameworks, products, firms, dates, or other firm-unique details, making it Generic Boilerplate.


reasoning: The paragraph is primarily a materiality assessment stating that known cybersecurity threats and prior incidents have not materially affected the company, while noting such risks could do so in the future. The cross-reference to risk factors is secondary and does not change the main focus from strategy/materiality disclosure.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, specifically its incident response planning and procedures for detection, analysis, containment, and recovery. The reference to an 'IT Leader' does not make management roles the main subject, and no qualifying firm-specific facts are provided.


reasoning: The paragraph describes the company's internal cybersecurity program, controls, and policies for identifying, assessing, and managing cyber risk, which fits Risk Management Process. Its only qualifying specific detail is the reference to the NIST Cybersecurity Framework, with no firm-unique roles, dates, or other verifiable company-specific facts.


reasoning: The paragraph identifies a specific management role and its responsibility for leading the cybersecurity function, making management the primary subject. Although the Audit Committee is mentioned, those references are standard governance context rather than the main focus.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk identification and assessment activities—monitoring threats, using tools, audits, and assessments—rather than focusing on board oversight or an actual incident. Although management roles are mentioned, the substance is about the process they carry out, not the individuals' qualifications or backgrounds.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk identification, assessment, monitoring, mitigation, and program maintenance processes. Although it briefly mentions board and Audit Committee updates, the main focus is on management's ongoing cybersecurity processes rather than board oversight or a specific management individual's qualifications.


reasoning: The paragraph describes the company's internal cybersecurity controls and operational security measures, so it is best categorized as Risk Management Process. Although it lists multiple security practices, it does not include qualifying specific facts such as named frameworks, named tools/products, dates, roles, or other firm-unique verifiable details.


reasoning: The paragraph describes the company's internal cybersecurity and risk assessment processes, including monitoring and enterprise-wide risk assessment, rather than board oversight, management qualifications, third-party risk, or a specific incident. It contains only generic process language with no qualifying specific facts or named standards.


reasoning: The paragraph describes the company's internal cybersecurity activities and planning—defense, detection, remediation, policies, and response planning—so it fits Risk Management Process. It contains only generic process descriptions and no qualifying specific facts such as named roles, frameworks, dates, firms, tools, or quantified details.


reasoning: The paragraph focuses on the company’s internal cybersecurity processes, including policies, risk assessments, monitoring, incident response, mitigation, and training. Its only qualifying specific detail is alignment to the NIST 800-171 framework, which makes it sector-adapted rather than firm-specific.


reasoning: The paragraph describes the company's internal cybersecurity program and the activities used to identify, assess, investigate, and mitigate cyber threats and incidents. Although teams are mentioned, the focus is on operational processes rather than board oversight, a specific management role, or a particular incident.


reasoning: The paragraph primarily describes the company’s internal incident identification, assessment, response, documentation, and escalation process under its data security event plan. Although board-level escalation is mentioned, the main subject is the operational cybersecurity process rather than board oversight.


reasoning: The paragraph is primarily about the Board of Directors' expected oversight of cybersecurity risk and updates it will receive from management, making board governance the central topic. It contains no qualifying specific facts such as named cyber roles, non-generic committees, dates, frameworks, or quantified details.


reasoning: The paragraph focuses on potential business, reputational, regulatory, and cost impacts from future cyber-attacks rather than describing governance, management roles, or the company’s cybersecurity processes. It also does not describe an actual incident, only possible material effects and compliance-related costs.


reasoning: The paragraph describes the company's internal cybersecurity controls and monitoring practices, so it is best categorized as Risk Management Process. It lists common security measures, but does not include qualifying specific facts such as named frameworks, roles, committees, dates, vendors, tools, or other firm-unique details.


reasoning: This paragraph is about the CISO’s qualifications, experience, and credentials, so it is chiefly about a management role rather than processes. It includes multiple verifiable facts, including a cybersecurity-specific title, quantified experience, and named certifications.


reasoning: The paragraph is centrally about oversight of third-party service providers, including vendor risk assessments and contractual cybersecurity requirements, which makes Third-Party Risk the best fit. It does not include qualifying specific facts such as named firms, dates, tools, or unique roles, so the specificity is Generic Boilerplate.


reasoning: The paragraph is primarily about management responsibility for cybersecurity, with particular emphasis on the CISO's role and qualifications. Although it mentions the cybersecurity program's oversight activities, the distinctive focus is the management role rather than the process itself.


reasoning: The paragraph primarily describes the company's internal incident monitoring, escalation, assessment, and remediation processes, so it is best categorized as Risk Management Process. Although it mentions an Information Security Officer and reporting to committees, the focus is on how the incident response process operates rather than on governance oversight or the qualifications of a specific person.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk management structure and ERM integration, rather than focusing on board oversight or the qualifications of a particular executive. It includes firm-specific organizational details such as named cyber roles and a GRC function, but no two hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk identification and monitoring activities, so it is about process rather than the CFO as a person. The only named role is CFO, which is generic under the rubric, and the rest consists of standard, non-specific practices and unnamed third-party support.


reasoning: The paragraph refers to actual prior cyber-related incidents and describes a response action taken after identifying them, which fits Incident Disclosure better than general risk-process language. It includes two specific quarter-end dates tied to those disclosures, making the paragraph Quantified-Verifiable.


reasoning: The paragraph is primarily about Board-level oversight, describing the Board’s receipt of a cyber report and delegation of oversight responsibilities. Its only qualifying specific fact is the reference to fiscal year 2024; the Audit Committee references are generic and do not increase specificity.


reasoning: The paragraph is primarily about board-level and committee oversight of cybersecurity, with the Board and its delegated committee as the grammatical subjects. It does not focus on management qualifications or internal process details, so Board Governance is the best fit.


reasoning: The paragraph is primarily about the company’s internal cybersecurity risk management activities, including monitoring threats, assigning day-to-day responsibility, analyzing threat information, and escalating risks through internal councils. Although it mentions a CISO and governance bodies, those references support the description of the process rather than making management biography or board oversight the main subject.


reasoning: The paragraph’s central theme is cybersecurity leadership and oversight, with the Board described as overseeing cybersecurity and receiving updates from the CIO and CISO. Although it also mentions operational security practices, the governance structure is the most prominent framing.


reasoning: The paragraph is primarily about the vCISO’s role, reporting line, and qualifications, with the ISSC mentioned in support of that description. It is not mainly about board oversight or general risk processes, so Management Role is the best fit.


reasoning: The paragraph refers to actual cyber-related incidents that the company had previously disclosed and notes a response action taken after identifying the incident, which fits incident-related disclosure more than general process discussion. It includes two specific reporting dates, making the disclosure quantified/verifiable under the stated rules.


reasoning: The paragraph primarily describes the company's internal cybersecurity response and monitoring processes, including how the IRT and IT leadership coordinate prevention, detection, mitigation, remediation, and incident response. Although the Board is mentioned, it is only as a reporting recipient rather than the main subject.


reasoning: The paragraph describes an actual cybersecurity event, including when it occurred and response actions taken, so it is best classified as Incident Disclosure. Its specificity comes from the specific timing in late May 2023, but it lacks a second hard verifiable fact needed for Quantified-Verifiable.


reasoning: The paragraph is chiefly about management personnel and management-led cyber responsibilities, qualifications, and team structure, with only a brief closing reference to reporting to the Audit Committee. It includes firm-specific role and team details, but not two qualifying hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph is primarily about oversight structure for cybersecurity, led by the board of directors and supported by the Audit Committee, with the CDC described as part of that governance process. It is firm-specific because it identifies a named cybersecurity-related committee and its specific cross-functional composition.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk identification, monitoring, detection, and response processes, including how cyber risk is embedded in enterprise risk management. Although much of the language is process-oriented boilerplate, the named threat-intelligence and hygiene services make it firm-specific.


reasoning: The paragraph primarily identifies the cybersecurity leader, including the CISO role and reporting structure, which makes Management Role the best fit. Although it also describes the program's functions, the role identification and leadership framing are the central features.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management activities, including monitoring, controls, training, threat intelligence, and testing. Although it briefly mentions vendor and third-party risk, that is only one component of the broader internal program rather than the central topic.


reasoning: The paragraph describes the company's internal cybersecurity practices and controls, including testing, training, incident response, and vendor risk management, so the main topic is its risk management process. The mention of third-party risk is only one component of the broader internal program, not the central focus.


reasoning: The paragraph is primarily about a specific management executive’s responsibilities and qualifications, not the company’s cybersecurity processes generally. It identifies a named management role and provides a specific experience detail, making it firm-specific.


reasoning: The paragraph is primarily about oversight by the audit committee and board reporting, so board-level governance is the main topic. It includes a firm-specific cybersecurity-related management role (Chief Information Officer), which makes it more specific than generic boilerplate.


reasoning: This paragraph describes general cybersecurity risk exposure and threat factors, but it does not discuss governance, management roles, internal risk management processes, third-party oversight practices, incident details, or strategy/materiality conclusions. The language is broad and could apply to many companies without firm-specific detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, specifically how it evaluates and costs protective measures to reduce security risks. It contains no named framework, role, committee, date, or other firm-specific detail.


reasoning: The paragraph primarily describes the company’s internal cybersecurity capabilities and operational processes—such as SOC visibility, threat detection, threat hunting, and vulnerability scanning—rather than focusing on the CISO’s qualifications or board oversight. The mention of a dedicated CISO is a firm-specific organizational fact, which elevates the paragraph above generic boilerplate.


reasoning: This paragraph does not describe an actual cybersecurity incident or a cyber risk management practice; it merely states that no reportable incidents occurred. Under the rubric, absence-of-incident language is best treated as None/Other rather than Incident Disclosure.


reasoning: The paragraph is primarily about the Board's oversight of cybersecurity risk, with the Board as the grammatical subject, so Board Governance is the best fit. It includes a named non-generic committee ('cybersecurity committee'), which makes it firm-specific.


reasoning: The paragraph focuses on the company’s internal cybersecurity risk management activities—threat intelligence, benchmarking, audits, and use of external resources to inform processes and resource allocation. Although it names government agencies, it does not include qualifying firm-specific facts from the allowed list such as named cyber roles, committees, dates, tools, firms, or quantified details.


reasoning: The paragraph is centrally about overseeing cybersecurity risks arising from third-party service providers and using security criteria in their selection and oversight, which fits Third-Party Risk. It includes no named frameworks, roles, committees, firms, dates, or other qualifying specific facts.


reasoning: The paragraph primarily describes a real cybersecurity incident involving Change Healthcare, including what happened, the operational disruption to billing and collections, the mitigation step of using an alternative intermediary, and the ongoing evaluation of impact. Although it also includes materiality language, the main substance is the incident narrative and response.


reasoning: The paragraph primarily describes the company’s internal escalation and notification process for cybersecurity threats and incidents, including how potential material incidents are reviewed for disclosure. Although it mentions the Audit Committee, Board, and a director’s experience, those references are secondary to the discussion of the incident escalation process.


reasoning: The paragraph is primarily about the company's approach to assessing and managing cybersecurity risk, including threats to its IT systems and operations. Although it mentions board oversight and the Vice President of IT, those references are secondary to the overall description of the company's internal risk management posture.


reasoning: The paragraph is principally about the Board's oversight of cybersecurity risk management and the supporting role of the Audit Committee, so Board Governance is the best fit. The only named committee is the Audit Committee, which is generic under the rules, and the remaining details do not add qualifying firm-specific facts.


reasoning: The paragraph primarily describes the company’s internal process for reassessing systems, maintaining safeguards, and continuously evaluating cybersecurity risks. Although it mentions the head of IT, the focus is on what the function does rather than the person’s qualifications or role details.


reasoning: The paragraph primarily describes the company's internal cybersecurity activities—monitoring, audits, penetration testing, and incident response planning—so it is about the risk management function rather than the CIO as a person. It includes one firm-specific fact because a cybersecurity-relevant management role (CIO) is identified.


reasoning: The paragraph primarily describes an actual past cybersecurity-related event involving a compromised employee email account, a fraudulent wire transfer request, and the company’s response actions, which makes Incident Disclosure the best fit. It does not include qualifying firm-specific facts from the allowed list, such as exact dates, named firms, named tools/products, or cybersecurity-specific roles.


reasoning: The paragraph is primarily about the board of directors' oversight of cybersecurity risk, with the board and audit committee as the governing subjects. It does not include any qualifying specific facts such as named non-generic committees, cyber-specific roles, dates, frameworks, or quantified details.


reasoning: The paragraph is primarily about the Board of Directors' and Audit Committee's oversight of cybersecurity risk, so Board Governance is the best fit. The references to an employee handling day-to-day oversight are secondary and generic, and no qualifying firm-specific facts are provided.


reasoning: Although the paragraph begins with management's role, it primarily describes the company's cybersecurity activities and processes—risk assessments, controls, incident response planning, policy development, and compliance—rather than identifying specific executives or qualifications. It contains no qualifying specific facts such as named roles, frameworks, committees, dates, vendors, tools, or quantified details.


reasoning: The paragraph focuses on the potential business and financial impact of cybersecurity threats and incidents, using material adverse effect language rather than describing governance, management roles, or specific risk management processes. It does not describe any actual incident or include any company-specific factual detail.


reasoning: The paragraph primarily describes the company's own cybersecurity policies, processes, and operational controls, with third-party providers mentioned only as a component of that internal program. Because the vendors are not the central topic of oversight requirements imposed on them, this fits Risk Management Process rather than Third-Party Risk.


reasoning: The paragraph primarily describes oversight and reporting to the Board of Directors regarding cybersecurity matters, which fits board-level governance. Although CEO and management are mentioned, the disclosure is not about a specific management cybersecurity role or qualifications.


reasoning: The paragraph describes the company's internal cybersecurity practices, including policies, training, employee testing, and breach-response procedures, so it is principally about its risk management process. Although third parties are mentioned, vendor oversight is not the central topic.


reasoning: The paragraph's most specific substantive content is the identification and qualifications of the Vista CIO and the management-level committee structure around cybersecurity oversight. Although the Board is mentioned, the paragraph mainly details management oversight roles and the CIO's experience rather than board actions.


reasoning: The paragraph focuses on Board and Audit Committee oversight, reporting, and education regarding cybersecurity, making Board Governance the best fit. It includes one firm-specific fact—a cybersecurity-relevant management role (CTO)—but otherwise consists mostly of standard governance language.


reasoning: The paragraph describes the company's internal cybersecurity awareness, training, and phishing testing activities, which are elements of its own risk management process. It does not identify any qualifying specific facts such as named frameworks, dates, quantified details, or clearly unique programs beyond generic training descriptions.


reasoning: The paragraph is primarily about management's responsibility and qualifications for overseeing cybersecurity, rather than describing specific cybersecurity processes or board oversight. However, it refers only to a generic 'management team' and unnamed personnel/consultants, with no qualifying specific facts.


reasoning: The paragraph is primarily about who in management is responsible for cybersecurity and the qualifications of those individuals, which makes Management Role the best fit. It includes multiple verifiable facts, including quantified experience and named prior employers.


reasoning: The paragraph primarily describes the company’s own cybersecurity risk mitigation measures and system architecture, including limiting system access and isolating its website and file server. References to third parties are incidental to explaining internal controls, so this is best categorized as Risk Management Process.


reasoning: The paragraph focuses on the company's internal incident evaluation and escalation process, making it a risk management process disclosure rather than a description of the CISO's qualifications or board oversight. The mention of the CISO is a firm-specific cybersecurity role, which raises specificity above generic boilerplate.


reasoning: The paragraph focuses on board-level oversight, with the Audit Committee as the subject reviewing and overseeing cybersecurity policies and procedures. It contains no qualifying specific facts because 'Audit Committee' is generic and there are no named frameworks, roles, dates, or other firm-specific details.


reasoning: The paragraph is about the company's own cybersecurity measures to protect systems and data, which fits internal risk management processes. It is highly generic and contains no named roles, frameworks, committees, dates, systems, firms, or quantified details.


reasoning: The paragraph is centered on a named oversight committee as the grammatical subject, describing its role in overseeing cybersecurity-related risk within ERM and receiving cybersecurity reports. The named committee makes the disclosure firm-specific rather than generic boilerplate.


reasoning: The paragraph is primarily about Board and committee oversight of cybersecurity risk, with the Board and its committees as the subject. It includes firm-specific governance details by naming non-generic committees involved in cybersecurity oversight.


reasoning: The paragraph primarily describes the company's incident response and escalation process, making it a risk management process disclosure rather than a personnel-focused management role discussion. It includes a firm-specific fact by naming the CISO as part of that process.


reasoning: The paragraph is primarily about how cybersecurity threats and incidents are escalated to the Audit Committee and, when appropriate, the full Board, making board-level oversight the central topic. Although the CISO is mentioned, the focus is not on the individual's qualifications but on governance reporting channels.


reasoning: The paragraph primarily describes management reporting to the audit committee about cybersecurity matters, making board-level oversight the main topic. It contains only generic governance and reporting language, with no qualifying specific facts such as named cyber roles, non-generic committees, dates, or named frameworks.


reasoning: The paragraph is centered on the Information Security Officer as a management role, including that role’s responsibilities and qualifications, even though it also mentions broader cybersecurity activities. It includes a cybersecurity-specific title, which makes the disclosure firm-specific.


reasoning: The paragraph’s main focus is the materiality assessment and potential business, legal, and financial effects of a prior cyber incident, rather than the incident narrative itself. Although it references the March 2020 ransomware attack, the dominant disclosure is that known cyber threats have not materially affected and are not reasonably likely to materially affect the company.


reasoning: This paragraph is a standalone materiality assessment stating that cybersecurity threats and prior incidents have not materially affected the company’s business, results, or financial condition. The references to risk factors and future uncertainty are ancillary and do not describe governance, management roles, or a specific incident.


reasoning: The paragraph primarily describes the company's internal cybersecurity program, controls, and risk mitigation processes, with management titles included only as part of how the program operates. It is not chiefly about the qualifications or background of those individuals, so Risk Management Process is the best fit.


reasoning: The paragraph primarily describes the company's internal cybersecurity monitoring, detection, incident response, and escalation processes. Although third parties and the Board are mentioned, they are supporting elements rather than the central topic.


reasoning: The paragraph discusses a real cybersecurity breach and the company’s response, including customer notifications and a related SEC investigation, so it is principally an incident disclosure. It includes two verifiable specifics: the named Progress software and the February 26, 2024 document request date.


reasoning: The paragraph primarily centers on the CIO as the leader of cybersecurity risk management, including the CIO's reporting line and relevant experience, which makes Management Role the best fit. Although it also mentions NIST-based review activity, the grammatical and substantive focus is the management role rather than the process itself.


reasoning: The paragraph is primarily about how the Board and its Audit Committee oversee cybersecurity risk, making board oversight the main subject. It includes firm-specific management role facts (CIO and CISO), but those roles are mentioned in service of the committee’s oversight function rather than as the focus of the paragraph.


reasoning: The paragraph is chiefly about oversight by a board committee, making Board Governance the best fit. It includes a firm-specific management role, the vCIO, but otherwise contains largely standard governance language.


reasoning: The paragraph is primarily about the CIO’s responsibility, experience, and qualifications, so it is best categorized as Management Role rather than a general process description. It includes multiple verifiable details about that role, including years of experience and named certifications, which elevates it beyond firm-specific disclosure.


reasoning: The paragraph is primarily about the officer’s qualifications, expertise, and background, so it is about a management role rather than the company’s cybersecurity processes. It includes a firm-specific cybersecurity leadership title, which makes it more specific than generic boilerplate.


reasoning: The paragraph is primarily about the company’s internal risk management structure and processes for identifying, assessing, managing, and monitoring risks, including cybersecurity. Although the CISO is mentioned, the focus is on the enterprise risk management function rather than the qualifications or reporting line of a management individual.


reasoning: The paragraph is centered on the CIO and CISO as individuals—their reporting relationship, experience, and credentials—so it is best classified as Management Role. It includes multiple verifiable facts such as named cybersecurity roles, quantified years of experience, and named certifications, which makes it Quantified-Verifiable.


reasoning: The paragraph is primarily about how cybersecurity oversight is structured and delegated from the Board, making Board Governance the best fit. Although it includes management and operational details, those details are presented in service of explaining the governance chain.


reasoning: The paragraph primarily recounts actual cybersecurity incidents, including when they occurred, what systems/data were affected, and response actions taken. Although it also mentions immaterial costs and materiality, the main substance is the incident narrative itself.


reasoning: The paragraph primarily describes the effects of a specific cybersecurity incident, including affected systems, containment actions, restoration, and remediation timing, which makes Incident Disclosure the best fit. It also includes multiple externally verifiable dates and dollar amounts, supporting Quantified-Verifiable specificity.


reasoning: The paragraph is centered on a management officer's reporting responsibility to the board on cybersecurity matters, which fits Management Role more than Board Governance. It does not include any qualifying specific facts such as a cybersecurity-specific title, named committee, framework, date, or quantified detail.


reasoning: The paragraph's main point is that essential information systems are managed or provided by third parties, including BD, making third-party dependence the central topic. It does not describe the company's internal cyber processes or an incident.


reasoning: The paragraph describes an actual cybersecurity event, including when it occurred, what happened, and the company's response actions, so it is best categorized as Incident Disclosure. It includes one qualifying specific fact—a specific time reference—making it Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred, what was accessed, and response actions taken afterward. Although it ends with a risk/materiality reference, the core content is the incident narrative itself.


reasoning: The paragraph is centered on cybersecurity risk from third-party service providers and the company's due diligence and security requirements for those vendors. It does not provide named firms, dates, frameworks, or other qualifying specific facts.


reasoning: The paragraph primarily describes the company's internal cybersecurity controls, monitoring, incident response, training, risk assessment, and related policies, which fits Risk Management Process. Although vendors are mentioned, vendor oversight is only one component of the broader internal program rather than the central topic.


reasoning: The paragraph is primarily about oversight by the Audit Committee, including how it is briefed and what it receives from management, so Board Governance is the best fit. It includes a firm-specific cybersecurity role fact—the Chief Information Security Officer—even though the rest is largely standard governance language.


reasoning: The paragraph is primarily about how the Board of Directors receives cybersecurity reporting and oversight information, making board oversight the central topic. It contains no qualifying specific facts after filtering out generic board references, generic cadences, and unnamed experts.


reasoning: The paragraph primarily describes the company's own data storage and handling practices for customer information, which fits Risk Management Process. Although third parties are mentioned, the focus is not on vendor oversight but on how the company stores, exports, and protects data.


reasoning: The paragraph’s main point is the existence of cyber risk and the statement that a past ransomware attack had a material adverse impact, which is a materiality/business-impact disclosure rather than an incident narrative. Although it references a past event, it does not primarily describe what happened in the incident.


reasoning: The paragraph’s main point is a materiality/no-material-incidents conclusion rather than describing a cybersecurity program or a specific incident, which fits Strategy Integration under the tiebreaker rules. It includes two specific dates, which are hard verifiable facts sufficient for Quantified-Verifiable specificity.


reasoning: The paragraph primarily describes management's cybersecurity responsibilities and program activities—risk identification, incident response coordination, policy assessment, and reporting—rather than focusing on board oversight or an individual executive's qualifications. It includes a firm-specific governance detail by naming the Cybersecurity Committee.


reasoning: The paragraph focuses on management-led oversight, identifying specific management roles and the committees they lead, rather than board oversight or a general process description. The named cybersecurity/privacy roles and non-generic committees make the disclosure firm-specific.


reasoning: The paragraph primarily describes the escalation and reporting of cybersecurity matters to board-level bodies and the Board, making board oversight the central theme. Although management roles are mentioned, they are presented mainly as part of the reporting chain into those governance bodies.


reasoning: The paragraph is mainly about the company's internal cybersecurity function and activities—risk assessment, monitoring, remediation, compliance testing, and training—rather than board oversight or an individual's qualifications. It includes firm-specific facts such as the named cybersecurity sub-committee and the stated combined 45 years of experience, but not two hard verifiable facts that would support a Quantified-Verifiable rating.


reasoning: The paragraph primarily identifies the CISO's role and reporting responsibilities, along with the management-level Risk Committee the CISO chairs. Although it also mentions board-level oversight, the main substance centers on management responsibility rather than the board itself.


reasoning: The paragraph focuses on the Chief Technology Officer’s background, qualifications, and prior experience, so it is about a management person rather than the company’s cybersecurity processes. It includes multiple specific, verifiable biographical facts, supporting a Quantified-Verifiable rating.


reasoning: The paragraph identifies management-level structures responsible for assessing and managing cybersecurity risk, rather than describing board oversight or detailed risk processes. The named Enterprise Risk Management Committee is a firm-specific governance fact.


reasoning: The paragraph focuses on a board committee's oversight role, describing how it receives cybersecurity reporting and materials. It is firm-specific because it identifies a cybersecurity-specific management role, the CISO, but does not include two or more hard verifiable facts.


reasoning: The paragraph is primarily about the company’s own cybersecurity risk management activities, including internal responsibilities, assessments, testing, and remediation planning. Although it ends with a materiality statement, the main subject is the firm’s internal risk management process rather than strategy or incident disclosure.


reasoning: The paragraph describes the company's own cybersecurity risk assessment, monitoring, and threat-detection practices, so it is primarily about internal risk management processes. Although it references banking regulators and FFIEC guidance, it does not include qualifying firm-specific facts or a recognized framework from the specified standards list.


reasoning: The paragraph is primarily about who at the board level oversees cybersecurity, how that oversight shifted in 2025, and how the Sustainability & Safety Committee receives updates. Although it also mentions the CIO and internal processes, board oversight is the central focus.


reasoning: The paragraph focuses on the company's internal cybersecurity practices, especially employee awareness, training, simulations, and policy attestation, which makes Risk Management Process the best fit. It includes a firm-specific named policy, which raises it above generic boilerplate.


reasoning: The paragraph is chiefly about the company’s internal incident response and escalation process, including how incidents are handled and how materiality is assessed. It is not centered on board oversight, a management leader’s qualifications, or a specific disclosed incident.


reasoning: The paragraph is centered on the qualifications and background of a specific management role rather than on the company’s cybersecurity processes, so Management Role is the best fit. It includes a firm-specific cybersecurity-related title, but lacks enough hard verifiable details to rise to Quantified-Verifiable.


reasoning: The paragraph is centered on the CISO as a person—his role, experience, career background, and qualifications—rather than on cybersecurity processes. It includes firm-specific management details, including the cybersecurity-specific role and a specific appointment date.


reasoning: The paragraph is chiefly about the CTO as the person responsible for cybersecurity, including his reporting line and qualifications, so Management Role is the best fit. It contains multiple company-specific, externally checkable facts about the named executive's background and experience.


reasoning: The paragraph is primarily about how the company’s cybersecurity function operates—who manages it and what the team does in detection, assessment, classification, escalation, and reporting—so it is best categorized as Risk Management Process rather than Management Role. It includes firm-specific details such as the named CIRT and its leadership structure, but does not provide two clear hard verifiable facts of the type needed for Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes and program activities—policy implementation, monitoring, incident prevention/mitigation, and coordination with IT—rather than focusing on board oversight or a person's qualifications. It is firm-specific because it identifies named internal governance bodies and a cybersecurity-specific role (CISO).


reasoning: The paragraph is primarily about the company's own cybersecurity risk management processes, including ERM integration and use of industry frameworks, so Risk Management Process is the best fit. Although board oversight is mentioned, it is secondary to the description of internal risk management design and operation.


reasoning: The paragraph is primarily about board-level oversight and governance of cybersecurity, including board and audit committee responsibilities and updates. Although it includes the CTO’s role and qualifications, those details support the broader discussion of board oversight rather than making management the main subject.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk monitoring and escalation process—prevention, detection, mitigation, remediation, and reporting—rather than board oversight or an individual executive's qualifications. It includes a firm-specific fact through the named Risk Management Steering Committee.


reasoning: The paragraph is mainly about the company’s internal incident response process, including the existence and contents of its incident response plan. Although it also mentions a physical security event and a no-material-cyber-incidents statement, the central topic is the company’s response planning process rather than board oversight, management roles, or a disclosed cybersecurity incident.


reasoning: The paragraph primarily describes how the company’s cybersecurity program is assessed and reviewed through internal audit, third-party review, and regulatory examination, which is a description of internal risk management processes. Although board-level bodies are mentioned, the focus is not on board oversight itself but on the assessment process surrounding the cybersecurity program.


reasoning: The paragraph is primarily about the company's incident response and vulnerability management processes, including how incidents are escalated and reported. Although management and a board committee are mentioned, they appear as components of the process rather than the main subject of governance or personnel disclosure.


reasoning: This paragraph focuses on the qualifications, experience, and credentials of named management cybersecurity/technology leaders, especially the CDIO and CISO, rather than on the company's cyber processes. It includes multiple verifiable facts, including quantified years of experience and specifically named certifications.


reasoning: The paragraph mainly describes the company’s internal cybersecurity governance and risk management processes, including how management committees review reports, policies, and ERM integration. Although management roles are named, the focus is on how the process operates rather than on the qualifications or background of a specific person.


reasoning: This paragraph is primarily about the qualifications, background, and experience of named management personnel responsible for technology and cybersecurity functions, so it fits Management Role. It includes multiple verifiable numeric experience facts and named cybersecurity-related roles, which elevates it to Quantified-Verifiable.


reasoning: The paragraph is primarily about ADT's internal cybersecurity risk assessment and mitigation activities within its ERM program, so the main topic is the company's risk management process rather than the CISO as a person. It includes firm-specific details such as the CISO role and use of SecurityScorecard, but lacks two clearly qualifying hard verifiable facts under the decision test needed for Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal cybersecurity function and controls—its information security program and technical protection methods—rather than focusing on board oversight or the qualifications of a particular executive. Board-reporting channels are mentioned, but they are secondary to the description of how the company manages cybersecurity risk.