reasoning: The bulk of the paragraph narrates an actual cybersecurity incident at Change Healthcare — describing the threat actor's access, the operational disruption to Bioventus's billing and claims processes, remediation steps (alternative intermediary), and the ongoing investigation. Although it opens and closes with materiality assessments, the incident narrative is the dominant content. Multiple hard verifiable facts (named firms Change Healthcare and UnitedHealth Group, named product Exogen, specific dates March 7 and March 18, 2024) easily exceed the two-fact QV threshold.

thinking:
Let me analyze this paragraph carefully.

This paragraph from Bioventus Inc. discusses:
1. A materiality assessment (no material cybersecurity risks)
2. The Change Healthcare incident - a third-party vendor incident affecting their operations
3. Operational impact - billing/collections disrupted
4. Remediation steps - alternative claim processing
5. Another materiality assessment at the end

This is a complex paragraph. Let me think about the dominant category.

The paragraph describes:
- A third-party incident (Change Healthcare/UnitedHealth Group)
- The impact on Bioventus's operations

- Materiality assessments

The primary content is about what happened with Change Healthcare and how it affected Bioventus. This is describing an actual incident - but it's a third-party's incident, not Bioventus's own incident. The paragraph describes the operational impact and includes materiality conclusions.

Looking at the tiebreakers:
- It describes what happened (Change Healthcare incident, unauthorized access, disruption to billing)
- It discusses business impact (delayed cash remittances, disrupted billing)
- It includes materiality conclusions

The dominant content here is actually about an incident that occurred at a third party and its impact on Bioventus. This is a blend of Incident Disclosure and Strategy Integration. The paragraph describes what happened AND assesses whether it's material to their business, ultimately concluding it wasn't a material cybersecurity risk despite the operational disruption. Looking at the tiebreaker criteria more carefully, the paragraph does describe what happened at Change Healthcare—the breach, how the threat actor gained access, and the operational disruption to billing—which makes up the bulk of the text. Even though materiality frames the opening and closing, the incident narrative itself is substantial enough that Incident Disclosure is the better fit.

Now I'm checking for specific, verifiable facts that would qualify for the Quantified-Verifiable category. I can identify several: Change Healthcare and UnitedHealth Group as named entities, the Exogen device as a specific product, and the two dates—March 7 and March 18, 2024. That's well over the threshold of two QV-eligible facts, so this clearly qualifies as Quantified-Verifiable.

fact: Change Healthcare named as affected third-party vendor

fact: UnitedHealth Group named as parent company

fact: Exogen device named as related product

fact: March 7, 2024 — date UnitedHealth Group issued statement

fact: March 18, 2024 — expected date to begin restoring service


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal cybersecurity risk management program and its basis on recognized frameworks (NIST CSF, CIS controls), making it Risk Management Process. It names specific frameworks but contains nothing unique to this company—no firm-specific roles, tools, dates, or numbers—so it is Sector-Adapted.

provider: anthropic

generationId: agent-sdk

stage: benchmark

fact: NIST Cybersecurity Framework (CSF)

type: framework

fact: Center for Internet Security (CIS) critical security controls


content_category: Board Governance

reasoning: The Committee is the grammatical subject receiving cybersecurity reports from management, making this Board Governance. All terms are generic—'the Committee,' 'management,' 'annual reports'—with no named roles, frameworks, or firm-specific facts from the IS list.

thinking:
Classify this paragraph.

The paragraph describes the Audit Committee receiving reports from management about cybersecurity. The Committee is the grammatical subject receiving reports. This is about board/committee oversight.

Content category: Board Governance - The Committee (likely Audit Committee based on context) is the subject, receiving reports on cybersecurity posture.

Specificity: Let me check the facts.
- "The Committee" - generic governance term, on the NOT list
- "annual reports" - generic cadence
- "management" - generic

No specific facts from the IS list. No named frameworks.

This looks like generic boilerplate language without substantive detail.


content_category: Incident Disclosure

reasoning: The paragraph is predominantly an incident narrative: it describes the discovery of unauthorized access, activation of response protocols, containment measures, operational disruption, and regulatory notification — all hallmarks of Incident Disclosure. A materiality assessment is embedded ('does not currently believe… will materially impact'), but it is subordinate to the extensive incident description. Specificity is Firm-Specific: the specific date (April 5, 2024) is one QV-eligible hard fact, but only one — 'Targus' is a subsidiary/company self-reference (NOT list), and 'external cybersecurity counsel and consultants' are unnamed. One hard fact yields Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a detailed incident disclosure describing what happened at Targus (a subsidiary). Let me break it down:

- Specific date: April 5, 2024
- Named entity: Targus (subsidiary)
- Describes unauthorized access, response actions, containment, business disruption
- Includes a materiality assessment
- Mentions regulatory notification and law enforcement

Category: The paragraph primarily describes what happened in a cybersecurity incident - the discovery, response, containment, and ongoing recovery. There's a materiality assessment embedded, but the dominant content is the incident narrative. → **Incident Disclosure**

Now I'm checking the specificity of the details. The date April 5, 2024 is concrete and verifiable, but "Targus" is a company self-reference that doesn't count toward the QV threshold. The external counsel and consultants mentioned are unnamed, so they don't add specificity either. That leaves me with just one qualifying fact, which puts this at Firm-Specific level rather than QV.

fact: April 5, 2024 — date incident was discovered


reasoning: The paragraph lists key elements of the company's cybersecurity program—risk assessments, a security team, external service providers, awareness training, an incident response plan, and third-party risk management—all describing internal processes. No named frameworks, roles (CISO/CIO), tools, firms, dates, or quantified facts appear; every element uses generic language that could apply to any company.

thinking:
Classify this paragraph.

Content: Lists key elements of cybersecurity program - risk assessments, security team, external service providers, training, IR plan, third-party risk management. This is about the company's internal cybersecurity processes.

Category: Risk Management Process - describes internal processes, tools, methodologies.

Specificity: Let me check for specific facts.
- No named frameworks (NIST, ISO, etc.)
- No named roles (CISO, CIO, etc.) - just "a security team"
- No named tools, firms, dates, numbers

- All terminology is generic and could describe any organization's standard cybersecurity practices.

This is Generic Boilerplate.


content_category: Strategy Integration

reasoning: The paragraph opens with an explicit materiality assessment ('have not to date materially affected us... business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Item 1A Risk Factors. No firm-specific facts are present — the healthcare industry mention and quoted risk factor title are generic contextual language.

thinking: Materiality assessment paragraph with cross-reference.


reasoning: The paragraph describes the company's internal cybersecurity awareness training and phishing simulation programs — these are internal processes. No named frameworks, tools, firms, specific dates, or cybersecurity-specific roles are mentioned. 'Monthly' is a generic cadence, and phishing exercises and role-based training are common practices on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity awareness training programs - monthly training, phishing exercises, role-based training for higher-risk positions. This is about internal processes/programs.

Category: Risk Management Process - describes internal cybersecurity training and monitoring processes.

Specificity: Let me check for specific facts:
- "monthly cybersecurity awareness training" - "monthly" is a generic cadence
- "regular phishing awareness exercises" - common practice
- "role-based security training" - common practice
- No named frameworks, tools, firms, dates, or numbers

No IS-list facts. No named standards.

This looks like generic boilerplate.


category_confidence: medium

reasoning: The paragraph's framing is 'cybersecurity governance structure' with the Board and Audit Committee establishing the oversight hierarchy into which all other roles and teams fit — the board/committee content opens and frames the entire structure. However, it heavily overlaps with Management Role (named CISO with credentials) and Risk Management Process (operational teams). For specificity, three QV-eligible hard facts exist: 'since 2015' (date), 'since 2001' (date), and 'Penn State University' (named university in credential context).

thinking:
Let me analyze this paragraph carefully.

This is a long paragraph that describes the cybersecurity governance structure across multiple levels: Board, Audit Committee, CISO, Information Security Governance team, Cybersecurity Risk Management Team, and Incident Response Team.

**Content Category:**
This paragraph spans multiple categories - Board Governance, Management Role, and Risk Management Process. I need to determine the dominant category.

The paragraph covers:
- Board of Directors oversight (Board Governance)
- Audit Committee oversight (Board Governance)
- CISO named individual with background (Management Role)

- Information Security Governance team (Management Role/Risk Management Process)
- Cybersecurity Risk Management Team (Risk Management Process)
- Incident Response Team (Risk Management Process)

The paragraph's primary communicative purpose is to describe the overall governance structure. It's an overview that touches on board, management, and operational teams. The opening sentence frames it as "cybersecurity governance structure."

The Board/Audit Committee sections are Board Governance. The CISO section is Management Role. The remaining teams are more organizational/process. This is a tough call since the paragraph gives roughly equal weight to board oversight and management/operational structure, but the framing is about governance structure overall. The CISO bullet with the named individual seems to be a key focal point.

Looking at the full hierarchy from board down through operational teams, the opening explicitly frames this as "cybersecurity governance structure," which suggests Board Governance is the dominant category. The board and committee oversight form the primary framework into which everything else fits. Though the CISO section is detailed with named credentials, the overall structure is still anchored by board-level governance.

Now I'm checking the specific facts to verify what qualifies as information-sensitive content: the CISO title and Casey O'Malley's name are both named roles and individuals, the tenure dates of 2015 and 2001 are specific dates that could be QV-eligible, and Penn State University is a named institution.

fact: CISO title (Casey O'Malley)

fact: Casey O'Malley named as CISO

fact: IT management positions since 2015

fact: Employed in cybersecurity field since 2001

fact: Bachelor of Science in Information Technology from Penn State University

fact: Information Security Governance team

fact: Cybersecurity Risk Management Team


reasoning: The paragraph describes an actual cybersecurity incident — a ransomware attack on a specific date that impacted operational systems and caused service delays. While the latter portion discusses costs and materiality (Strategy Integration territory), the incident narrative with specific details (date, attack type, operational impact) is the anchor content from which the financial discussion flows. Specificity is Firm-Specific: one QV-eligible hard fact (exact date December 15, 2020) plus a named internal event identifier, but only one QV-eligible fact prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Forward Air Corp's 10-K filing.

The paragraph describes a past ransomware incident (December 15, 2020), its impacts, costs, and then makes a materiality assessment. Let me determine the dominant category.

Content: It describes an actual incident (ransomware on Dec 15, 2020), its impact (service delays), costs, and then a materiality statement plus cross-reference.

The paragraph has mixed content - incident narrative AND strategy/materiality. The incident description (date, type, impact) takes up significant space, but the latter portion discusses costs and materiality.

Looking at the sentence breakdown, the incident itself gets only one specific sentence with the date and what occurred, while the financial impact and materiality assessment take up more space. The incident is concrete but brief, whereas the strategic implications and cost discussion dominate the overall paragraph. the rest builds upon. So I'm settling on Incident Disclosure as the primary classification, though I recognize Strategy Integration could work too. The paragraph does describe the actual event—the date, the type of incident, the operational consequences—which pushes it toward incident disclosure rather than pure financial analysis.

Looking at the specificity now: I have the exact date of December 15, 2020, which counts as a hard fact. The incident is named as "Ransomware Incident" and described by type, but there are no named external firms, dollar amounts, or headcount figures. That gives me just one QV-eligible fact from this passage.

Since there's only one QV-eligible fact, this falls into Firm-Specific classification rather than QV.

fact: December 15, 2020

fact: Ransomware Incident (named internal event)


content_category: Management Role

reasoning: The ISO is the grammatical subject performing the primary action (reporting to management and the BRCC), which per Rule 2 ('Management role reports TO the board → Management Role') points to Management Role. The paragraph's primary content is reporting lines and escalation structure rather than board oversight activities or the person's qualifications. Two firm-specific facts (cybersecurity-specific ISO title + named non-generic BRCC committee) but neither is QV-eligible, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes reporting lines: the ISO reports to management and the BRCC, and escalation to the full Board. The heading says "Reporting to Board of Directors." The primary actor is the ISO (Information Security Officer), but the paragraph is about the reporting/escalation structure to the board.

Let me think about category. The ISO is the grammatical subject performing the reporting action, but the purpose is about keeping the board informed - this is about governance oversight structure. The heading "Reporting to Board of Directors" frames it as board governance. But Rule 2 says "Management role reports TO the board → Management Role."

The ISO is the subject reporting upward to the board committee, which fits the pattern of a management role reporting to the board. So this should be categorized as Management Role, even though the focus is on the reporting structure rather than the individual's qualifications or background. The ISO is the grammatical subject here, so this falls under Management Role. ISO and BRCC are both specific named entities that belong on the IS list, and there's no quantifiable data like dates or headcounts, so no QV applies. This is a firm-specific fact about their reporting structure.

fact: ISO (Information Security Officer) — cybersecurity-specific title

fact: BRCC (Board Risk and Compliance Committee) — named non-generic committee


reasoning: The paragraph describes the company's internal risk assessment processes, technical safeguards, and committee meeting cadence. The CISO is mentioned only as attribution for who leads the committee — the substantive content is about what the program does (risk assessments, tabletop exercises, penetration testing), making this Risk Management Process per the person-vs-function test. The named non-generic committee (Information Security Steering Committee) and CISO title are firm-specific facts, but no QV-eligible hard verifiable facts (specific dates, dollar amounts, headcounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security Steering Committee led by CISO, meeting quarterly, conducting risk assessments, tabletop exercises, penetration testing.

Category: This is about internal processes - risk assessment, technical safeguards, committee meetings. The CISO is mentioned as attribution for who leads the committee, but the paragraph is about what the program does. Person-vs-function test: remove "led by our CISO" and it still makes sense as process description. → Risk Management Process

Specific facts:
- "Information Security Steering Committee" - named internal program/committee? This seems like a named non-generic committee → Firm-Specific

- "CISO" is a cybersecurity-specific title, quarterly meetings are just a generic cadence, and tabletop exercises plus penetration testing are standard practices, so none of those qualify as list items.

The committee name and CISO role are firm-specific details but don't meet QV eligibility since there are no dates, financial figures, headcounts, third-party vendors, tools, or certifications mentioned. This lands at Firm-Specific (3) on the specificity scale.

fact: Information Security Steering Committee ("Security Committee")

fact: Chief Information Security Officer (CISO)


reasoning: The paragraph's primary content is the composition and organizational role of the Cybersecurity Steering Committee — identifying who sits on it and their titles. This is management-level structure (who the people are and their responsibilities), not a description of processes, tools, or frameworks. The CSC is the grammatical subject throughout. The named non-generic committee (CSC), cybersecurity-specific role (CISO), and specific departmental composition are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, named tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: Describes a Cybersecurity Steering Committee (CSC) with specific membership, its responsibilities for monitoring/managing cyber risks, and integrating cybersecurity into business processes.

Category: This is about a management committee structure. The CSC is the grammatical subject. It's not the Board - it's a management-level committee. The paragraph describes who sits on it and what it does. The person-vs-function test: this is about the committee's composition and responsibilities. It's more about organizational structure (who the members are) than about processes/tools/frameworks. The primary content is the committee membership and its role - this is Management Role (management committees responsible for cybersecurity).

Now I'm checking the specificity of the details. The committee name and the CISO title are specific, but most of the other roles listed—CFO, CHRO, General Counsel, and the others—are standard corporate titles without any distinguishing information. Looking at verifiable facts, I don't see any dates, metrics, named tools, or certifications that would make this quantifiable. The named committee and role titles themselves aren't QV-eligible since they're just organizational designations.

What makes this firm-specific is the actual composition of the committee—the particular mix of departments and roles like Legal, Compliance, and Finance working together in this structure. That's a concrete organizational detail tied to this company's governance model.

fact: Cybersecurity Steering Committee (CSC)

fact: Group Vice President, IT and CISO

fact: Committee composition: EVP CFO, EVP CHRO, SVP General Counsel, SVP Global Operations, SVP Chief Accounting Officer, VP Internal Audit


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of third-party service providers — vendor questionnaires, due diligence, audit reports, and contractual security terms. This is squarely Third-Party Risk since the entire paragraph describes requirements imposed on and assessments of external vendors. No named frameworks, firms, tools, dates, or quantified facts appear; all practices described (questionnaires, due diligence, contract terms) are generic and common across filings.

thinking:
Classify this paragraph.

Content: About third-party/vendor oversight - risk-based approach, vendor questionnaires, due diligence, audit reports, contract terms. Central topic is vendor oversight → Third-Party Risk.

Specificity: No named frameworks, no named tools, no specific dates, no numbers, no named firms. Vendor questionnaires, due diligence, contract terms are all generic practices. No IS-list facts. → Generic Boilerplate.


reasoning: The paragraph describes the company's use of external service providers to evaluate and enhance its own cybersecurity policies and procedures. Per Rule 3, external assessors hired to serve the company are Risk Management Process, not Third-Party Risk (which requires vendor oversight to be the central topic). No named firms, frameworks, roles, dates, or other specific facts are present — all language is generic and interchangeable across filings.

thinking:
Let me classify this paragraph.

Content: Describes engagement with external service providers as part of cybersecurity program. They help evaluate/enhance security policies and procedures.

Category: This is about third-party engagement, but the external providers are serving the company (helping evaluate and enhance the company's own policies). Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." This is Risk Management Process.

Specificity: No named frameworks, no named firms, no specific roles, no dates, no numbers. "External service providers" is generic. Everything here is boilerplate language.

So this falls under generic boilerplate.


reasoning: The board of directors is the grammatical subject overseeing cybersecurity risks, with delegation to the audit committee — classic Board Governance. All elements are generic: 'board of directors,' 'executive officers,' 'audit committee,' and 'day-to-day management' appear on the IS-NOT list, with no cybersecurity-specific roles, named frameworks, or firm-specific facts.

thinking:
Classify this paragraph.

The paragraph is about board oversight of cybersecurity risks. The board is the grammatical subject. It mentions the audit committee and board oversight function.

Content category: Board Governance

Specific facts: "audit committee" is generic, "board of directors" is generic, "executive officers" is generic. No cybersecurity-specific roles, no named frameworks, no dates, no numbers.

Specificity: Generic Boilerplate


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks to its systems and data. No named frameworks, roles, tools, dates, or other specific facts are present — the language is entirely generic and could apply to any company.

thinking:
Classify this paragraph.

Content: Describes the company's information security processes for identifying, assessing, and managing cybersecurity risks. This is about internal processes/program description.

Category: Risk Management Process - describes risk assessment methodology and what the program covers.

Specificity: No named frameworks, no named roles, no specific facts. Everything is generic - "various information security processes," "identify, assess and manage," etc. The definition of "Information Systems and Data" is just describing scope in generic terms.

Generic Boilerplate.


reasoning: The paragraph introduces the CISO, describes their credentials (CISSP, 20+ years of experience), and establishes their scope of responsibility, making the person the primary subject. While the first sentence lists program functions and the third sentence mentions Audit Committee oversight, the dominant communicative purpose is identifying who manages cybersecurity and what qualifies them. Two QV-eligible hard facts (named certification CISSP + specific years of experience) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three parts:
1. CISO manages the information security program, team responsibilities
2. CISO's credentials (CISSP, 20 years experience)
3. Audit Committee oversight

Person-vs-function test: The paragraph mentions what the program does (strategy, policy, standards, architecture, processes, assessing/managing risks) AND the person's credentials (CISSP, 20 years). It's mixed.

The first sentence is about the function - what the CISO's team does. The second sentence is about the person - credentials and experience. The third sentence is about board governance.

Looking at the structure more carefully, the opening sentence focuses on the program and its functions, but the real emphasis seems to be on establishing who's in charge and their qualifications. The credentials and reporting line to the Audit Committee are what make this primarily about the Management Role category rather than just describing the program itself. I'm checking the qualifications against the verifiable criteria—CISSP is a named certification and over 20 years is a specific number, so that's two quantified-verifiable facts that push this into the Quantified-Verifiable category.

fact: CISO (Chief Information Security Officer)

fact: CISSP certification

fact: Over 20 years of experience in IT and cybersecurity

type: quantified


specificity_confidence: medium

reasoning: The paragraph's primary subject is the Board and Audit Committee's oversight of cybersecurity risk, with the VP IT mentioned in the subordinate context of reporting TO the board/committee. The VP IT title qualifies as a firm-specific cybersecurity role per the IS list ('VP of IT/Security'), but Audit Committee and generic cadences ('regular basis,' 'at least annually,' 'periodic') are on the NOT list and do not add specificity.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, Audit Committee role, VP IT reporting to senior management and Audit Committee, Audit Committee reporting to Board.

Category: The primary subject is the Board and Audit Committee's oversight structure. The VP IT is mentioned in the context of reporting TO the board/committee. The board/committee is the frame. → Board Governance

Specific facts:
- "VP IT" — this is a named role but is it cybersecurity-specific? The IS list includes "VP of IT/Security." "VP IT" is essentially "VP of IT." Looking at the NOT list: "Head of IT", "IT Manager", "Director of IT" are listed as NOT specific.

The IS list explicitly includes "VP of IT/Security," and "VP IT" maps to that category, so I'll count it as a cybersecurity-specific title even though it's borderline.

Looking at the rest of the content, "Audit Committee" is generic and excluded, and the cadence language like "annually" and "periodic" doesn't add specificity. That leaves just the VP IT role as a firm-specific fact, giving me one Firm-Specific item. There are no quantifiable facts—no dates, amounts, headcounts, or named entities.

fact: VP IT (cybersecurity-specific title on IS list)


reasoning: The paragraph's dominant content is a narrative of actual cybersecurity incidents — the September 2022 Rockstar Games network intrusion and the 2K Games vendor platform compromise — describing what happened, what was accessed, and response actions. While it opens with a materiality assessment and closes with cost language, the bulk of the text is incident narrative. Specificity is Firm-Specific: 'September 2022' is a specific date (IS-list fact), but subsidiary names (Rockstar Games, 2K Games) and the company's own game title (Grand Theft Auto) are company self-references per the NOT list and do not count as QV-eligible, leaving only one QV-eligible hard fact (the date, counted once) — insufficient for Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Take Two Interactive's 10-K filing.

This paragraph contains multiple elements:
1. A materiality assessment ("none of these threats or incidents...have materially affected the Company")
2. Description of actual incidents - September 2022 network intrusion at Rockstar Games, unauthorized access to 2K Games vendor platform
3. Costs mentioned as immaterial

The dominant content is the description of actual cybersecurity incidents - the September 2022 Rockstar Games breach and the 2K Games vendor platform compromise. These are detailed incident narratives with dates, specific subsidiaries, and what happened.

Now I'm checking what counts as a specific, verifiable fact versus a company self-reference. The September 2022 date and the Grand Theft Auto product name are concrete specifics, but I need to reconsider whether subsidiary names like Rockstar Games and 2K Games should count as hard facts or if they fall under the exclusion for company self-references. Looking at the guidance, subsidiary names are explicitly listed as excluded, so those don't add to the specificity count. So I need two QV-eligible facts, and September 2022 gives me one. The question is whether Rockstar Games and 2K Games count—they're subsidiaries that identify which systems were compromised, which seems different from just self-referential company names. Grand Theft Auto is their own product, not a third-party security tool, so that doesn't fit the QV criteria.

Looking at what's actually verifiable here, September 2022 is the only hard fact that clearly meets the QV list. That makes this Firm-Specific (3), not QV.

fact: September 2022 network intrusion

fact: September 2022 vendor platform compromise


reasoning: The paragraph's primary content is organizational structure: the Information Security Team's reporting line to the CIO and its composition (Director of Information Security, managers, analysts). While ERM integration is mentioned in the opening clause, the dominant focus is on who manages cybersecurity and how the management structure is organized — management structure rather than process description. CIO and Director of Information Security are cybersecurity-specific roles on the IS list, reaching Firm-Specific, but named roles do not count toward QV.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity risk management as part of ERM, the Information Security Team's role, reporting to CIO, and team composition.

Category: This describes both the risk management process (ERM integration) and management structure. The paragraph mentions ERM integration briefly, then focuses on who manages it - the Information Security Team, their reporting line (to CIO), and team composition.

Person-vs-function test: The paragraph describes organizational structure - who the team is, who they report to, team composition. But it's not about a specific person's credentials/background. It describes the function's structure.

The CIO serves as the reporting line, and I'm seeing the team's composition laid out. Looking at what's dominant here - the paragraph opens with cyber risk being integrated into ERM, but the bulk of it focuses on the organizational structure: which team owns this function, their reporting relationship to the CIO, and who comprises the team. That makes this primarily about management role rather than the risk management process itself. The ERM context is just the setup.

Now I'm checking the specificity. The CIO and Director of Information Security are both cybersecurity-specific roles that appear on the standard list, so this qualifies as firm-specific information. Named roles don't push it into the quantified verification category, so I'm landing on Firm-Specific as the classification.

fact: Chief Information Officer (CIO)

fact: Director of Information Security

fact: Team composed of Director of Information Security, managers, and security analysts


reasoning: The paragraph contains an explicit materiality assessment ('are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. The first sentence is a generic no-assurance disclaimer. No named frameworks, roles, dates, or firm-specific facts appear — purely boilerplate language.

thinking:
Let me analyze this paragraph.

The paragraph has two main parts:
1. A disclaimer about no assurance their cybersecurity program will be effective
2. A statement that cybersecurity threats "are reasonably likely to materially affect" the company, with a cross-reference to Risk Factors

The second sentence contains a materiality assessment - it says cyber threats "are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition." Per Rule 6, this is Strategy Integration.

Specificity: No named frameworks, no firm-specific facts, no dates, no numbers. Generic boilerplate language. → Generic Boilerplate.


reasoning: The paragraph describes the company's cybersecurity risk management program, its integration into overall risk management, and its alignment with NIST CSF — all hallmarks of Risk Management Process. The mention of 'third-party cybersecurity professionals' is generic (unnamed), and no firm-specific facts from the IS list are present, so the named NIST framework anchors this at Sector-Adapted.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity risk management program, mentions internal and third-party professionals, references NIST CSF. This is about processes/program, not about specific people or board oversight.

Category: Risk Management Process - describes internal processes, framework adoption, ERM integration.

Specificity: Names NIST CSF (framework). No firm-specific facts from the IS list. "Third-party cybersecurity professionals" is generic/unnamed. No CISO or specific roles mentioned.

→ Sector-Adapted (Level 2) - names NIST but nothing unique to this company.

fact: National Institute for Standards and Technology Cybersecurity Framework (NIST CSF)


reasoning: The paragraph describes the company's internal risk assessment methodology, audit practices, vulnerability scanning, and ISO 27001 certification — all core Risk Management Process content. It contains multiple QV-eligible hard facts: a specific date for certification origin (2014), a specific reporting period (December 31, 2024), and a quantified scope expansion (two additional locations).

thinking:
Let me analyze this paragraph.

Content: Describes risk assessments, internal audits, vulnerability scans, ISO 27001 certification details.

Category: Risk Management Process - describes internal processes, methodologies, tools.

Specific facts:
- ISO 27001 certification maintained since 2014 - this is a certification claim (firm-specific) AND "since 2014" is a specific date
- December 31, 2024 - specific date
- "two additional locations" - quantified
- Transition to latest version of the standard

QV check: specific date (since 2014), specific date (December 31, 2024), "two additional locations" (quantified). That's multiple hard verifiable facts → Quantified-Verifiable.

I'm confirming this qualifies as Quantified-Verifiable since it contains multiple checkable elements: the 2014 certification date, the December 31, 2024 deadline, the count of two additional locations, and the named ISO 27001 certification itself.

fact: Maintained ISO 27001 certification since 2014

fact: Year ended December 31, 2024 — completed transition to latest version of the standard

fact: Two additional locations added to certification scope

fact: Since 2014


reasoning: The paragraph opens with a substantive description of the CIO as a person — reporting line to CEO, professional experience at public companies, and CISSP certification — then frames the subsequent process description as operating 'under the direction of the CIO.' While the process content (risk analysis, controls, training, strategy) occupies more text, the paragraph's organizing principle is the CIO and their qualifications, making Management Role the dominant category. For specificity, CIO is a cybersecurity-specific title (Firm-Specific), and CISSP is one QV-eligible fact, but there is no second QV-eligible fact (no specific dates, dollar amounts, headcounts, named firms, or named tools), so it remains Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. First sentence: About the CIO - their reporting line, experience, and CISSP certification. This is about the person.
2. Second and third sentences: About what the IT department does - analyzes risks, considers trends, implements controls, conducts training, drives strategies, communicates to board.

Person-vs-function test: If I remove the CIO's title, credentials, and reporting line, the remaining content describes what the IT department does (processes). The paragraph starts with the person but transitions to the function.

Which is dominant? The first sentence is about the person (Management Role).

The second and third sentences are about processes (Risk Management Process). The process description is longer and more detailed. Actually, re-reading this - the first sentence establishes the CIO's qualifications and reporting structure, then "Under the direction of the CIO" pivots to describing the department's substantive activities: risk analysis, controls implementation, training, and strategy communication. These processes would remain meaningful even without the person's credentials mentioned. So this is a mixed paragraph where the person's role anchors the description, but the bulk of the content focuses on what the function actually does.

Looking at the volume and substance, the process description dominates - it takes up roughly twice the space and detail of the person's qualifications. The first sentence does provide meaningful management context with the reporting line to CEO and CISSP credential, but the codebook's Rule 1 says to assign the dominant category. Comparing to Case 6, where a CISO is mentioned only as attribution before pivoting to the program's activities, this feels similar - the person is the entry point, but the real content is the Risk Management Process. I'll categorize this as Risk Management Process since that's where the substantive detail lies. I'm reconsidering the codebook's person-versus-function distinction—the example shows a CISO with minimal credentials followed by process description, but our paragraph leads with substantial qualifications before the process content. The structure centers on establishing who the CIO is first, then what happens under their direction, which feels like the paragraph's organizing principle even though process takes up more space. I'll stick with Management Role because the framing fundamentally depends on introducing this person and their authority. The first sentence is clearly about the person—the CIO's reporting line, experience, and certification—which makes Management Role defensible, even though the rest describes processes. I'm going to commit to Management Role since the paragraph's structure and opening are fundamentally organized around the role itself.

Now I'm checking the specificity level. The CIO title is on the IS list, and the CISSP certification is a named qualification that counts as QV-eligible. The reporting relationship and background at public companies are there too, but that vague reference doesn't add QV-eligible detail. With only one clear QV-eligible fact, this lands at Firm-Specific.

fact: CIO (cybersecurity-specific leadership title)

fact: Reports directly to the CEO


reasoning: The paragraph's central topic is oversight of external service providers — risk assessments during onboarding, requiring security measures, and contractual breach-notification obligations imposed ON vendors. No named frameworks, firms, tools, dates, or quantified details appear; all language is generic ('robust policies,' 'thorough risk assessments,' 'strong security measures').

thinking:
Let me classify this paragraph.

Content: About third-party vendor oversight - risk assessments during onboarding, requiring security measures, contractual obligations for breach notification.

Category: Third-Party Risk - the central topic is oversight of external parties (SaaS providers and service partners). Requirements imposed ON vendors.

Specificity: No named frameworks, no named firms, no specific dates, no numbers. "third-party software as a service providers" is generic. "robust policies and procedures", "thorough risk assessments", "strong security measures" - all generic. No IS-list facts.

→ Generic Boilerplate (1)


reasoning: The paragraph contains an explicit materiality assessment ('have not been materially affected by risks from any known cybersecurity threats... business strategy, results of operations and financial condition'), which per Rule 6 makes it Strategy Integration even though boilerplate. The appended cross-reference to Risk Factors does not change the classification. No specific facts from the IS list are present—only generic boilerplate language and a standard cross-reference.


reasoning: The paragraph is mixed between Board Governance (audit committee oversight, reporting cadence, escalation protocols) and Management Role (CDTO, CIO, and third-party CISO consultant credentials, experience, education, reporting structure). The second half of the paragraph is dominated by detailed credential information about specific management personnel—who they are, their years of experience, degrees, and industry backgrounds—making Management Role the dominant category via the person-vs-function test. Two QV-eligible hard facts (over 25 years experience, approximately 15 years experience) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

This is a long, multi-topic paragraph. Let me identify the content:

1. Management is responsible for cybersecurity program
2. Audit committee oversees enterprise risk/cybersecurity risks
3. Audit committee receives reports from cybersecurity leaders semi-annually
4. Audit committee reports to full board
5. Board considers IT/cyber expertise for audit committee membership
6. Cyber Incident Response Plan includes escalation protocols
7. Recently hired Chief Digital and Technology Officer
8. CDTO supported by management-level committee and cybersecurity team
9. CDTO and CIO each have over 25 years of IT experience in manufacturing/consumer goods

10. CIO has degree in Management Information Systems, both have MBAs
11. Third-party consultant provides CISO advisory services
12. Consultant has ~15 years experience including as CISO at other public manufacturing companies

The paragraph mixes board governance oversight with details about management credentials and experience. The content is split between audit committee responsibilities and reporting structures on one side, and the qualifications of the CDTO, CIO, and external CISO advisor on the other. Both the CDTO and CIO bring substantial IT backgrounds with advanced degrees, while the third-party consultant adds specialized cybersecurity leadership experience from similar manufacturing environments. The detailed credentials and experience levels—25 years, advanced degrees, MBAs, 15 years as a CISO—really do push this toward Management Role as the dominant category, even though the board governance framing is substantial. The specificity about personnel is what distinguishes this paragraph, so I'm settling on Management Role with moderate confidence.

Now I'm checking which facts qualify as quantified-verifiable: the "over 25 years" and "approximately 15 years" of experience are both specific numbers that meet the threshold, while the generic degree names and industry context don't. That gives me two QV-eligible facts, so this falls into Quantified-Verifiable.

fact: Chief Digital and Technology Officer

fact: Chief Information Officer

fact: Third-party consultant providing CISO advisory services

fact: CDTO and CIO each have over 25 years of information technology experience

fact: CISO consultant has approximately 15 years of experience in cybersecurity leadership


reasoning: The paragraph describes the company's cybersecurity program activities: cross-functional approach, training, audits, and third-party engagement. The CISO is mentioned as attribution ('led by our chief information security officer') but the substantive content is about what the program does. Applying the person-vs-function test, removing the CISO reference leaves a complete process description. One IS-list fact (CISO) elevates to Firm-Specific, but no second QV-eligible hard fact exists.

thinking:
Let me analyze this paragraph.

Content: Describes the IT security team led by CISO, cross-functional approach, training, audits, and third-party engagement. This is about what the program does - processes, activities. The CISO is mentioned as attribution. Applying the person-vs-function test: remove "led by our chief information security officer" and the paragraph still describes the program's activities. → Risk Management Process.

Specificity:
- "chief information security officer" → CISO is on the IS list → Firm-Specific
- "internal audit team" → generic

- "consultants or other third parties" → generic/unnamed
- No named frameworks, no dates, no dollar amounts, or named firms/tools

Since there's only one IS fact (CISO) and no second QV-eligible fact, this qualifies as Firm-Specific.

fact: chief information security officer (CISO)


reasoning: The paragraph opens with an explicit materiality assessment ('not identified any indication of a cybersecurity incident that would have a material impact on our business and consolidated financial statements'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, firm-specific facts, or verifiable details are present—the language is boilerplate materiality disclaimer.

thinking: Materiality assessment + cross-reference to Risk Factors.


reasoning: The paragraph's primary content describes what the Cybersecurity Program and CISO's organization do — monitoring, risk assessments, threat analysis, security tools, tabletop exercises, phishing exercises, and training. The Audit Committee oversight and CIO/CISO mentions are attributional; removing the titles, the paragraph still functions as a process description (person-vs-function test → function). The CIO and CISO are cybersecurity-specific titles on the IS list, elevating to Firm-Specific, but neither is QV-eligible, and no other QV facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: ERM integration, board oversight (Audit Committee), management roles (CIO, CISO), and risk management processes. I need to determine the dominant category.

Let me break it down:
- Sentence 1: Risk management process (ERM integration, Cybersecurity Program)
- Sentence 2: Mixed - Audit Committee oversight + CIO/CISO management
- Sentence 3-4: What the CISO's organization does (processes, monitoring, risk management)

- Sentence 5: Strategy includes risk assessments, tools, exercises, training

The bulk of the paragraph describes what the program/CISO's organization DOES - processes, monitoring, tools, strategies. The person-vs-function test: remove the titles and the paragraph still describes processes. The board mention (Audit Committee) is one clause. The CIO/CISO are mentioned but as attribution for what the program does.

Category: **Risk Management Process** - the dominant content is about internal processes, monitoring, tools, and methodologies.

Specificity:
- CIO: cybersecurity-specific title ✓ IS
- CISO: cybersecurity-specific title ✓ IS
- "Audit Committee" - generic governance body, not firm-specific
- Named internal program: "Information Technology Security and Compliance organization" / "Cybersecurity Program" - generic program name, no unique identifier
- No named frameworks, no dates, no dollar amounts, no named firms/tools

The CIO and CISO titles are the only firm-specific facts here. They're cybersecurity-specific roles on the IS list, but they're not QV-eligible because they're named positions rather than quantifiable facts. There are no dates, dollar amounts, named frameworks, or specific tools mentioned.

Category: **Firm-Specific** (CIO and CISO are cybersecurity-specific titles on the IS list)

fact: Chief Information Security Officer (CISO)


reasoning: The paragraph describes an actual cybersecurity incident (November 2023), its operational disruption, data exfiltration of employee and patient information, and extensive remediation actions taken afterward—all hallmarks of Incident Disclosure. While it also touches on ongoing risk and a soft materiality mention, the dominant content is the incident narrative and response. Only one QV-eligible hard fact (specific month/year), so it reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Ardent Health's 10-K filing.

Content: Describes a specific cybersecurity incident in November 2023, its impact (disruption, data exfiltration), costs, and remediation actions taken afterward. Also mentions ongoing risks.

Category: This is primarily about an actual incident and the response/remediation. The paragraph describes what happened, the impact, and what changes were made afterward. This is Incident Disclosure - it describes the event, its scope, response actions, and remediation.

Wait - let me reconsider. The paragraph starts with the incident but then spends most of its text on remediation changes (enhanced SOC visibility, training, detection tools, vulnerability management, AI technologies).

The materiality language ("may materially impact") reinforces this is a significant disclosure. The core content is the incident narrative plus the remediation actions taken in response, which per the codebook falls under Incident Disclosure since it includes incident response actions. For QV eligibility, I've got the specific date in November 2023, but the Security Operations Center is just a generic program name, and while "Cybersecurity Incident" appears capitalized as a named event, there are no named third-party firms, specific tools, dollar amounts, or headcounts mentioned. So the only QV-eligible fact here is the specific date.

Since I need at least two hard verifiable facts for QV and only have one, this qualifies as Firm-Specific disclosure.

fact: November 2023


reasoning: The paragraph describes an actual cybersecurity incident (employee interactions with suspicious websites), its containment, and forensic investigation outcome. While it includes a materiality conclusion ('no material impact'), the dominant content is the incident narrative—what happened and how it was responded to. However, it contains no specific dates, named firms, named tools, or other IS-list facts; 'forensic investigation' and 'promptly contained' are standard incident language on the NOT list.

thinking:
Classify this paragraph.

Content: Describes an actual cybersecurity incident (employee interactions with suspicious websites), containment, forensic investigation, and a materiality assessment (no material impact).

Category: This describes what happened in an incident - nature, response, and impact assessment. The dominant content is the incident narrative. The materiality conclusion ("no material impact") is subordinate to the incident description. → Incident Disclosure

Specificity: Let me check for specific facts:
- No specific dates (just "during the reporting period")
- No named firms
- No named tools
- No dollar amounts or headcounts

- No cybersecurity-specific titles or named frameworks, and the language like "forensic investigation" and "suspicious websites" is too generic to count as concrete details.

No IS-list facts found. → Generic Boilerplate


reasoning: The paragraph primarily describes internal risk management processes — evaluating, redesigning, implementing, and monitoring safeguards. The CIO mention is incidental attribution ('to manage the risk assessment and mitigation process'); removing the role reference leaves the process description intact, so this is about the function, not the person. The CIO is a cybersecurity-specific title on the IS list, triggering Firm-Specific; the CFO is generic C-suite and does not count as a second fact for QV.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up processes (re-design, implement, maintain safeguards, address gaps, monitor effectiveness) and mentions resource allocation and personnel including CIO reporting to CFO.

Category: The paragraph describes internal processes (evaluate, re-design, implement, maintain, monitor safeguards). The CIO mention is attribution - "to manage the risk assessment and mitigation process." The bulk is about what the company does processwise. Person-vs-function test: remove "including our Chief Information Officer who reports to our Chief Financial Officer" and the paragraph still describes processes. → Risk Management Process

The CIO is a cybersecurity-specific role that qualifies as firm-specific, while the CFO is a generic executive title. The reporting relationship between them is an organizational detail unique to this firm. Since there's only one QV-eligible hard fact here, this lands as Firm-Specific.


reasoning: The paragraph describes the company's own internal security processes — penetration testing and vulnerability assessments with a scoring methodology. No named frameworks, named firms ('leading service providers' is unnamed), named tools, specific dates, or cybersecurity-specific roles from the IS list appear, leaving this as generic boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes penetration testing and vulnerability assessment processes - internal security activities.

Category: Risk Management Process - describes the company's own internal processes (penetration testing, vulnerability assessments, scoring methodology).

Specificity: Let me check for facts.
- "annual penetration testing" - generic cadence
- "leading service providers" - unnamed entities (NOT list)
- "internal and external vulnerability assessments" - common practices
- "combination of scores and internal business metrics" - generic description
- "information security team" - not a cybersecurity-specific title from the IS list

No named frameworks, no named roles from IS list, no specific dates, no named firms, no named tools.

This is generic boilerplate language without specific details or named entities.


reasoning: The paragraph's primary content is about who manages the cybersecurity program — the composition of the management team (specific departments: IT, finance, legal, operations) and what they supervise (internal personnel with cybersecurity experience and retained consultants). While it touches on program scope, the grammatical subject and focus is the management team's identity and structure. The named departmental composition (IT, finance, legal, operations) is a firm-specific fact per the IS list, but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes management team composition (senior staff from IT, finance, legal, operations) leading cybersecurity risk management program, supervising internal security personnel and retained consultants.

Category: This is about what the management team DOES - leading the cybersecurity risk management program and supervising personnel/consultants. The person-vs-function test: if I remove the management team reference, the paragraph still describes program leadership and supervision activities. But wait - it does describe the composition of the team ("IT, finance, legal, and operations") and mentions personnel qualifications ("prior work experience in cybersecurity").

Actually, the primary content is about who manages the program and how it's structured - the management team's composition and what they oversee.

The grammatical subject is "our management team" and it describes their composition and supervisory role. This feels like Management Role - it's about who the people are (team from multiple departments) and what they oversee. The departments listed (IT, finance, legal, operations) are specific composition details, and there's no CISO or cybersecurity-specific title mentioned, which suggests it's more about the organizational structure than a dedicated security function. So this is Management Role - the paragraph focuses on who manages the program through this cross-departmental team composition.

Looking at the specificity: the team composition across IT, finance, legal, and operations is a concrete, firm-specific detail, while "prior work experience in cybersecurity" is too generic, and the retained consultants are unnamed and vague. There are no named roles, frameworks, dates, or numbers to anchor this further. That one specific fact about departmental composition makes this Firm-Specific.

fact: Management team comprised of IT, finance, legal, and operations departments


reasoning: The entire paragraph is about the CISO as a person — their years of experience, certifications, and career background — making this clearly Management Role per the person-vs-function test. Multiple QV-eligible hard facts are present: specific years of experience ('over 20 years') plus multiple named certifications (CISSP, CISM, PCI ISA & PCIP), easily exceeding the two-fact threshold for Quantified-Verifiable.

thinking:
Classify this paragraph.

This is about the CISO's qualifications, experience, certifications, and career history - clearly about the person, not the function.

Content category: Management Role

Specific facts:
- CISO (cybersecurity-specific title)
- "over 20 years" of experience (specific number)
- CISSP certification
- CISM certification
- PCI ISA & PCIP certifications

QV-eligible: "over 20 years" (years of experience as specific number) + CISSP + CISM + PCI ISA/PCIP (named certifications) = multiple hard verifiable facts → Quantified-Verifiable

fact: CISO (cybersecurity-specific title)

fact: over 20 years of information technology experience

fact: CISSP certification

fact: CISM certification

fact: PCI ISA & PCIP certifications


reasoning: The paragraph's primary structure identifies specific management roles (President of P&T, CDO, senior-most cybersecurity employee) and then enumerates their scope of responsibilities, making management accountability the communicative purpose. However, the responsibilities listed (hiring, budgets, integrating, overseeing, communicating, preparing) are functional/process-oriented, creating tension with Risk Management Process — the person-vs-function test is borderline since the framing is 'here are the people and what they're responsible for' rather than 'here is what the program does.' President of P&T and CDO are firm-specific cybersecurity-relevant titles not found at every company, triggering Firm-Specific, but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes management team members and their responsibilities for cybersecurity. Names President of P&T, CDO, and "senior-most employee responsible for cybersecurity management." Then lists their responsibilities which are process-oriented.

Person vs function test: The paragraph mentions roles but then describes what they DO (hiring, approving budgets, integrating, overseeing, communicating, preparing). If I remove the role titles, the paragraph still describes processes. But the paragraph's primary purpose is identifying WHO leads the cybersecurity processes and what their responsibilities are - it's about the management structure.

Actually, looking more carefully: the paragraph names specific roles (President of P&T, CDO) and describes their responsibilities.

The core tension here is whether this is fundamentally about the people in charge or the processes they manage. The opening establishes the management team, but everything that follows describes functional responsibilities. Even if I strip away the titles, the substance remains process-focused—hiring, budgeting, integrating, overseeing. Yet the paragraph's structure and opening sentence center on identifying who's accountable, which suggests the person-focused framing is primary. The paragraph identifies specific management positions—President of P&T and Chief Digital Officer—along with their cybersecurity responsibilities, which makes this firm-specific information. There are no quantifiable values like dates or dollar amounts, so it's not QV. This is Management Role, Firm-Specific.

fact: President of P&T

fact: CDO (Chief Digital Officer)


reasoning: The paragraph describes integration of cybersecurity risk assessment into the company's overall ERM process and prioritization/mitigation of threats. The VP of IT is mentioned as attribution for who performs the work, but the substantive content is about the process itself (person-vs-function test: remove the title and the paragraph still describes risk management activities). 'Vice President of IT' is a general IT leadership title analogous to 'Director of IT' on the NOT list, not a cybersecurity-specific role. No named frameworks, dates, tools, or other specific facts remain after validation.

thinking:
Classify this paragraph.

Content: Describes integration of cybersecurity into ERM, mentions VP of IT working with management to prioritize risk management and mitigate threats.

Category: The paragraph is about risk management processes - integration into ERM, prioritizing risk management, mitigating threats. The VP of IT is mentioned but as attribution for who does the work. The person-vs-function test: remove "our Vice President of IT" and replace with "the Company" - it still makes sense as a process description. → Risk Management Process.

Wait - "Vice President of IT" - is this a cybersecurity-specific title? The IS list includes "VP of IT/Security".

I'm checking the lists now. "VP of IT/Security" appears in the IS category, but "Vice President of IT" without the security component aligns more with the generic IT leadership titles in the NOT list like "Director of IT" and "IT Manager". The NOT list even explicitly excludes "Associate Vice President of IT" as generic IT leadership, so a straight "Vice President of IT" falls into that same bucket. This isn't a cybersecurity-specific role.

Specificity: No

This confirms it—no named frameworks, specific dates, or tools mentioned, and "VP of IT" is just generic IT leadership per the exclusion list. "Management" is equally vague. This is boilerplate content.


reasoning: The paragraph's primary subjects are the Board of Directors and Audit Committee, describing their oversight role, delegated responsibilities, and how they receive cybersecurity updates. The CISO is mentioned in the subordinate role of reporting TO the committee, keeping this Board Governance. The CISO title is a cybersecurity-specific role (IS list), elevating to Firm-Specific, but 'Audit Committee' and 'quarterly' are on the NOT list and don't count further.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, Audit Committee delegation, CISO presents to Audit Committee quarterly.

Category: The Board and Audit Committee are the primary subjects. The CISO is mentioned in context of reporting TO the board. This is Board Governance.

Specificity:
- "Audit Committee" - NOT list (generic)
- "CISO" - IS list (cybersecurity-specific title) → Firm-Specific
- "quarterly" - NOT list (generic cadence)

Only one IS fact (CISO). No QV-eligible facts (no dates, dollars, headcounts, named firms, named tools, named certs).

So this classifies as Firm-Specific.

fact: CISO presents updates to the Audit Committee


reasoning: This is a materiality assessment — the company concludes that no cybersecurity risks are expected to significantly affect operations, financial condition, or business objectives. Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate. No specific facts, named frameworks, or firm-specific details are present.


reasoning: The paragraph describes the company's internal cybersecurity risk management program — ERM integration, framework adoption, monitoring controls, vulnerability assessments, disaster recovery, and business continuity. While the Board is mentioned in the context of ERM oversight, the primary subject and communicative purpose is the description of processes and controls. It names ISO and NIST CSF frameworks but contains no firm-specific facts (no named roles like CISO, no specific dates, no named tools/vendors, no quantified details), keeping it at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity risk management program - ERM integration, framework adoption (ISO, NIST CSF), controls implemented, vulnerability assessments, disaster recovery, business continuity. The Board is mentioned but as context for ERM integration, not as the primary subject. The paragraph is fundamentally about the company's internal processes.

Category: Risk Management Process - the paragraph describes internal cybersecurity processes, framework adoption, controls, vulnerability management, disaster recovery.

Specificity: Names ISO and NIST CSF frameworks → at least Sector-Adapted. Any firm-specific facts? Let me check the IS list:

- No cybersecurity-specific titles (CISO, CTO, etc.)
- No named non-generic committees
- No specific dates
- No named tools/products
- No named third-party firms
- No specific numbers

The paragraph names frameworks (ISO, NIST) but nothing unique to this company. The practices described (monitoring, log collection, threat hunting, vulnerability scans, penetration tests, disaster recovery) are all generic/common practices.

Specificity: Sector-Adapted (Level 2)

fact: ISO (International Organization for Standardization)

fact: NIST Cybersecurity Framework


reasoning: The paragraph's primary content describes what happened in an actual cybersecurity incident: a forensic investigation concluded that a threat actor gained unauthorized access during a specific date range and may have acquired data. The trailing materiality language is secondary and still inconclusive ('have not yet determined'), making the incident narrative the dominant communicative purpose. Only one QV-eligible hard fact (specific date range), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes a completed forensic investigation of a specific cybersecurity incident (August 5-8, 2025), what the threat actor did, scope identification, and then discusses materiality assessment that's still pending, plus a forward-looking risk statement.

Category: The paragraph starts by describing what happened in an incident (forensic investigation complete, dates, unauthorized access, data acquisition). Then it transitions to materiality assessment. The dominant content is the incident narrative - dates, what happened, scope. The materiality portion is secondary. → **Incident Disclosure**

Specificity:

Looking at what's actually verifiable here, I've got the specific date range as a concrete fact, but the incident name itself isn't really a quantifiable detail. There are no named organizations, tools, dollar figures, or employee counts mentioned. That single date reference gives me one firm-specific fact, which puts this in the Firm-Specific category rather than Quantifiable.

fact: August 5-8, 2025 — specific date range of unauthorized access


reasoning: The paragraph describes the company's own internal cybersecurity processes—monitoring tools, incident response planning, and employee training—making it Risk Management Process. No named frameworks, tools, roles, dates, or other specific facts appear; all language is generic and could apply to any company.

thinking:
Classify this paragraph.

Content: Describes internal cybersecurity processes - monitoring, tools, incident response plan, employee training. This is about the company's own internal processes.

Category: Risk Management Process

Specificity: No named frameworks, no named tools, no named roles, no specific dates or numbers. "continuous monitoring," "fundamental plan," "training for employees" are all generic practices. No IS-list items.

Generic Boilerplate.


reasoning: The paragraph's central topic is oversight of third-party vendors/service providers — describing the vendor management program, risk assessment tiers, security questionnaires, and contractual obligations imposed on vendors. The specific departmental composition (corporate security, product security, and legal teams) is a firm-specific fact identifying unique organizational structure, but there are no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Third-party risk management is the central topic here.

Specific facts:
- "corporate security, product security, and legal teams" - specific team/department composition
- vendor security questionnaire, evaluation process details

This is clearly Third-Party Risk since vendor oversight is the central topic.

For specificity: The mention of "corporate security, product security, and legal teams" is a specific team composition (✓ IS list). No named frameworks, no QV facts. → Firm-Specific.

fact: corporate security, product security, and legal teams evaluate vendor cybersecurity risks


reasoning: The paragraph assesses the business impact of cybersecurity by stating no incidents have resulted in operational interruptions or breaches, functioning as an implicit materiality assessment. It parallels the codebook example 'We have not identified any cybersecurity incidents or threats that have materially affected us' → Strategy Integration. The specific reporting period 'year ended December 31, 2024' is a firm-specific date, yielding one IS-list fact.

thinking:
Classify this paragraph.

The paragraph states the company has not experienced any cybersecurity incidents. This is a statement about the absence of incidents and their impact on business operations.

Content category: This is a materiality/impact assessment - stating no incidents have materially affected operations. Per Rule 6 and the codebook, materiality disclaimers go to Strategy Integration. But this isn't exactly a materiality disclaimer - it's saying "no incidents occurred." Let me think...

Actually, this says they haven't experienced incidents that resulted in interruptions or breaches. This is closer to an incident history disclosure (absence of incidents). But per the codebook, Incident Disclosure requires description of actual events.

Since no actual incident occurred here, I'm looking at this as a statement about cybersecurity's impact on business operations rather than a specific incident report. The language mirrors the codebook examples about incidents not materially affecting the company, which points to Strategy Integration as the appropriate category.

I notice the reference to "the year ended December 31, 2024" - that's a specific reporting date, which would qualify this as Firm-Specific under the IS criteria. So this falls under Strategy Integration with Firm-Specific detail.

fact: year ended December 31, 2024


reasoning: The paragraph describes the company's internal cybersecurity program, team responsibilities (information security team and data privacy team), and incident handling processes. It is entirely about functions and activities — identifying, monitoring, evaluating, mitigating threats — making it Risk Management Process. No named frameworks, specific titles (CISO/CIO), dates, tools, numbers, or other firm-specific facts appear; 'information security team' and 'data privacy team' are generic team names, not cybersecurity-specific titled roles from the IS list.

thinking:
Let me analyze this paragraph from Peloton's 10-K filing.

Content: Describes the company's cybersecurity program, information security team, and data privacy team responsibilities. Details what the information security team does (reviews incidents, identifies threats, evaluates/prioritizes, investigates/mitigates, administers response procedures, implements safeguards).

Category: This is about internal processes and team functions. The person-vs-function test: this describes what the teams DO, not who the people are. → Risk Management Process

Specificity: Let me check for specific facts:

- "information security team" — generic team name
- "data privacy team" — generic team name
- No named frameworks, no named tools, no dates, no numbers, no named individuals, no cybersecurity-specific titles (CISO, CIO, etc.)
- No named standards

Everything here is generic process description. → Generic Boilerplate


reasoning: The paragraph's dominant content describes an actual cybersecurity incident: its timing (November 2023), the response actions (investigation, remediation, law enforcement coordination, individual notification), and its resolution. While it opens and closes with materiality assessments and cross-references, the bulk of the text narrates what happened in the incident, making Incident Disclosure the primary communicative purpose. Specificity is Firm-Specific: 'November 2023' is one hard verifiable date, but the remaining details use generic incident language ('external cybersecurity experts', 'law enforcement', 'remediation measures') with no named firms, tools, or additional hard facts to reach QV.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains multiple elements:
1. A materiality assessment ("have not materially affected")
2. A description of an actual cybersecurity incident (November 2023)
3. Incident response actions (investigation, remediation, notification)
4. Forward-looking materiality statement
5. Cross-references to other filing sections

The dominant content is the incident narrative - it describes what happened in November 2023, the response actions taken, and the resolution. The materiality framing bookends the incident description, but the bulk of the paragraph is about the incident itself.

Per the tiebreaker rules: "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"

So this is categorized as Incident Disclosure. The November 2023 date is the only concrete verifiable fact here - everything else relies on generic incident response language like external experts and law enforcement involvement, which makes this Firm-Specific rather than Quantified/Verified.

fact: November 2023 cybersecurity incident


reasoning: The paragraph primarily describes the company's own internal cybersecurity program, risk management integration, and evaluation processes. Third-party risk is mentioned as one component of the broader program (per Rule 3: third parties as one component of internal program → Risk Management Process). No named frameworks, standards, cybersecurity-specific roles, dates, tools, or other facts from the IS list appear — 'mandatory cybersecurity regulatory requirements' names no specific regulation, 'Utility Members' is a company self-reference, and 'energy commodity risks' is generic sector language.

thinking:
Let me analyze this paragraph.

Content: Describes a comprehensive cybersecurity program, mandatory regulatory requirements, risk management programs addressing enterprise and energy commodity risks, evaluation of cybersecurity risks including third-party service providers, requirements imposed on third parties, and utility members having independent programs.

Category: This spans Risk Management Process and Third-Party Risk. The paragraph starts with internal program description, then moves to third-party risk considerations. Let me assess dominance - roughly half is about internal processes and half about third-party oversight. The third-party content is substantial (requirements imposed ON vendors, different protections required). But the opening frames it as the company's own program, and third-party is presented as a component. Per Rule 3: "Third parties mentioned as ONE component of internal program → Risk Management Process." The paragraph frames third-party as part of their broader risk evaluation.

→ Risk Management Process.

Now checking the specificity level - there are no named regulations, frameworks, or standards mentioned. "Enterprise and energy commodity risks" uses sector language but doesn't reference any specific standard. "Utility Members" is just a company-specific term for Tri-State's cooperative structure. No cybersecurity titles, committees, or concrete numbers appear anywhere. This reads as generic boilerplate that could describe almost any utility's approach.

→ Generic Boilerplate, Specificity 1.


reasoning: The bulk of the paragraph describes an actual cybersecurity incident at Change Healthcare and its operational impact on Bioventus (disrupted billing, claims processing delays, identification of alternative intermediary), making Incident Disclosure dominant over the bookending materiality assessments. Three QV-eligible hard verifiable facts are present: two named third-party firms (Change Healthcare, UnitedHealth Group) and one named product (EXOGEN device).

thinking:
Let me analyze this paragraph carefully.

The paragraph contains multiple elements:
1. A materiality disclaimer ("have not encountered any risks from cybersecurity threats that have materially affected...")
2. A detailed description of the Change Healthcare incident - naming Change Healthcare, UnitedHealth Group, the EXOGEN device, describing what happened, the impact on billing/collections
3. A concluding materiality assessment specific to the Change Healthcare incident

This is a complex paragraph. Let me apply the category tiebreakers:

- The paragraph DESCRIBES what happened in an incident (Change Healthcare breach, impact on claims processing)
- But the incident happened to a THIRD PARTY (Change Healthcare), not to Bioventus itself

- The paragraph discusses the impact on Bioventus's operations from a third-party incident
- There's a materiality conclusion at the beginning and end

Looking at the tiebreakers:
- "Paragraph DESCRIBES what happened in an incident" → Incident Disclosure
- "Paragraph ONLY discusses financial cost, insurance, or materiality of an incident WITHOUT describing the event" → Strategy Integration

This paragraph actually describes the incident (what Change Healthcare experienced, how it affected Bioventus's operations) AND includes materiality assessments. The dominant content is the incident narrative - describing what happened with Change Healthcare, how it impacted Bioventus's billing processes, what Bioventus did in response (found alternative intermediary, resumed claims). The materiality statements frame the narrative but don't overshadow the detailed incident description itself.

The core question is whether the primary purpose is describing the actual event or assessing its materiality. Since the paragraph spends most of its space on what happened and how Bioventus responded, rather than just stating financial impact or insurance coverage, this leans toward Incident Disclosure - it's narrating a real cybersecurity event affecting the company's operations, even though the incident originated with a third party. I'm weighing whether the materiality framing or the detailed incident narrative is the dominant purpose here. The paragraph opens and closes with materiality assessments, but the bulk of the text walks through what happened with Change Healthcare—the specific impacts on Bioventus operations and the response actions taken. That incident description is too detailed to be just a brief mention, so Incident Disclosure feels like the right primary category.

For specificity, I've got three named entities that are verifiable facts: Change Healthcare and UnitedHealth Group as third-party firms, plus the EXOGEN device as a named product—that's solid ground for QV eligibility.

fact: Change Healthcare named as third-party intermediary involved in incident

fact: UnitedHealth Group named as parent company of Change Healthcare

fact: EXOGEN device named as product whose claims were affected


reasoning: The paragraph describes the company's internal cybersecurity processes — risk assessment, incident response procedures, employee training, monitoring — making it a Risk Management Process disclosure. 'Management and Strategy' is brief attribution, not a description of a person's qualifications. Third-party selection is one component among many internal processes, not the central topic. No named frameworks, cybersecurity-specific titles, dates, tools, or other specific facts appear; all practices described (risk assessment, training, monitoring) are generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - risk assessment, third-party selection, incident response procedures, training, monitoring. The subject is "Management and Strategy" describing what the company does.

Category: Risk Management Process - describes internal processes, tools, methodologies. Third-party mention is one component, not central. Management is mentioned briefly as attribution.

Specificity: Let me check for specific facts:
- No named frameworks
- No cybersecurity-specific titles (just "Management and Strategy", "information technology team")
- No named tools, firms, dates, numbers

- Generic practices like risk assessment, training, monitoring, and incident response with no specialized terminology or concrete details

This is Generic Boilerplate.


reasoning: The paragraph briefly describes a phishing incident then pivots to the main point: a materiality assessment ('did not identify any cybersecurity threats that have materially affected… our business strategy, results of operations, or financial condition'). Per the tiebreaker rule, a brief mention of a past incident plus a materiality conclusion as the main point is Strategy Integration. The year '2024' is one specific date fact, reaching Firm-Specific but not QV (no second hard verifiable fact).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes: (1) a phishing incident in 2024, (2) remediation actions, (3) a materiality assessment, and (4) a generic risk disclaimer.

Category analysis:
- Incident elements: phishing scam, loss, remediation (additional procedures, new checking accounts)
- Strategy Integration elements: materiality assessment ("did not identify any cybersecurity threats that have materially affected...")
- The paragraph starts with an incident description, then pivots to materiality assessment

Using the tiebreaker rules:
- "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"

- But the incident details are fairly brief, and the materiality conclusion is the main takeaway. The phishing scam and remediation steps are mentioned primarily to support the materiality statement that no threats have materially affected the company. This leans toward Strategy Integration.

Looking at the specificity now: "2024" gives us a concrete year, which counts as a specific date similar to "fiscal 2025" on the IS list. The phishing scam itself is generic, and "materially affected" is standard audit language. So I'm seeing one firm-specific fact here—the year—which puts this in the Firm-Specific category.

fact: 2024 (year of phishing incident)


reasoning: The board and Audit Committee are the grammatical subjects receiving updates and discussing cybersecurity oversight with senior management, making this Board Governance. All elements are generic: 'Audit Committee' is standard governance, 'periodic' and 'annual' are generic cadences, 'CEO' is generic C-suite, and no named frameworks, cybersecurity-specific roles, or firm-specific facts appear.

thinking:
Let me analyze this paragraph.

Content: Board and Audit Committee receive updates, annual discussions with senior management including CEO, company strengthening risk management procedures.

Category: The board and Audit Committee are the grammatical subjects performing oversight actions. This is Board Governance.

Specificity: Let me check the facts:
- "board of directors" - generic (NOT list)
- "Audit Committee" - generic (NOT list)
- "periodic updates" - generic cadence (NOT list)
- "annual basis" - generic cadence (NOT list)
- "CEO" - generic C-suite (NOT list)

- "senior management" - generic (NOT list)

No named frameworks, no firm-specific facts from the IS list. Everything here is generic governance language.

→ Generic Boilerplate (1)


reasoning: The paragraph assesses potential material adverse effects of cybersecurity incidents on operations and results, which constitutes a materiality-adjacent statement about business impact. However, it reads more like risk-factor language than a formal materiality assessment. It mentions customers and suppliers facing threats (touching Third-Party Risk) but the dominant thrust is about potential material impact on business performance, aligning with Strategy Integration. No specific facts, frameworks, or firm-specific details are present.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risks, with both serving as grammatical subjects performing oversight actions. All elements are generic: 'Audit Committee' is standard governance, 'Board of Directors' is generic, and 'periodic basis' is a vague cadence — none qualify as specific facts under the IS list.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee and Board of Directors oversee cybersecurity risks, review controls, risk management, governance, and incident disclosures.

Category: Board Governance - the grammatical subjects are the Audit Committee and Board of Directors performing oversight functions.

Specificity: Let me check the facts:
- "Audit Committee" - on the NOT list (generic governance)
- "Board of Directors" - on the NOT list
- "periodic basis" - generic cadence, on the NOT list
- No named frameworks, no specific dates, no named roles from the IS list

- This falls into generic boilerplate language without specific details or named entities.


reasoning: The paragraph's primary content is about management personnel and organizational structure: the VP of IT's qualifications and experience, the COO's leadership roles, team composition, and reporting lines to the Audit Committee. While some process elements are mentioned (developing/implementing the security program, monitoring incidents), these are subordinate to describing who the people are and how they are organized. Only one QV-eligible fact (15 years of experience) prevents escalation to Quantified-Verifiable, but multiple firm-specific facts (cybersecurity-specific titles, named internal team, specific departmental composition) clearly place this at Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph is about management roles and their responsibilities regarding cybersecurity. Let me apply the person-vs-function test.

The paragraph describes:
- VP of Information Technology's experience (15 years) and role leading the information security program
- Team composition including IT Systems & Security Administrator
- Working with Legal department
- COO leading Cybersecurity Incident Management Team
- Cross-functional team composition (Internal Audit, Legal, IT, Risk Management, Accounting)
- COO reporting to Audit Committee

There's a mix here.

The VP of IT's qualifications and the COO's leadership role are clearly person-focused, but the real emphasis is on organizational structure—who reports to whom, how teams are composed, and the reporting lines. This is fundamentally about the management hierarchy and how cybersecurity responsibilities are distributed across the organization rather than about specific security processes or functions.

Looking at what qualifies as a quantifiable fact, I see the "over 15 years of relevant work experience" is the only concrete metric here. The other details—the VP of IT/Security title, the named Cybersecurity Incident Management Team, the cross-functional team composition—are all specific and named, but they're not quantifiable in the way the codebook defines it. So there's really just one QV-eligible fact in this entire paragraph. I'm checking the second QV-eligible fact more carefully—"over 15 years" is specific, but I need to verify if there's anything else that qualifies. Looking through the details again: no third-party vendors mentioned by name, no specific tools or software, no dates, no financial figures, no certifications listed. That confirms just one QV fact, so this lands in Firm-Specific territory.

fact: Vice President of Information Technology

fact: IT Systems & Security Administrator

fact: Cybersecurity Incident Management Team

fact: Cross-functional team: Internal Audit, Legal, Information Technology, Risk Management and Accounting


reasoning: The paragraph describes the company's internal cybersecurity program — continuous monitoring, third-party tools (firewalls, EDR, encryption), and employee training. These are all internal processes, making it Risk Management Process. No named frameworks, no named products/vendors, no specific dates or numbers — all generic security practices that could apply to any company.

thinking:
Let me analyze this paragraph from Eva Live Inc's 10-K filing.

Content: Describes a multi-layered cybersecurity program with continuous monitoring, third-party security tools, employee training. This is about internal processes and tools.

Category: Risk Management Process - describes the company's own internal cybersecurity processes, tools, and methodologies.

Specificity: No named frameworks, no named tools/products, no specific dates, no named firms, no specific numbers. "EDR", "firewalls", "encryption" are generic practices. "Third-party security assessments" is unnamed.

This falls into generic boilerplate territory—the kind of standard language most companies include without much differentiation.


reasoning: The paragraph describes the company's own internal cybersecurity processes — control requirements for change management, patching, MFA, data backup, and continuous monitoring. The outside consultants serve the company's IT activities (not vendor oversight as a central topic), and the Audit Committee mention is a brief subordinate clause, not the primary focus. No named frameworks, cybersecurity-specific roles, dates, numbers, or other IS-list facts are present; all items (common practices, 'outside consultants', 'Audit Committee', 'management') fall on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - control requirements, change management, patching, MFA, data backup, security monitoring. Mentions "outside consultants" but as part of internal program, not vendor oversight. Brief mention of Audit Committee reporting at end.

Category: Risk Management Process - the paragraph is about the company's own internal processes and controls. The outside consultants serve the company's IT activities. The Audit Committee mention is brief/subordinate.

Specificity: Let me check for specific facts:
- "outside consultants" - unnamed, NOT list
- "Audit Committee" - NOT list (generic governance)

- "management" - NOT list
- Practices listed (change management, patching, MFA, data backup, security monitoring) - common practices, NOT list
- No named frameworks, no named roles (CISO etc.), no dates, no numbers, no named firms/tools

No IS-list facts remain. No named standards either. → Generic Boilerplate (1)


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected... our business strategy, results of operations, or financial condition'), which per Rule 6 triggers Strategy Integration. It also notes the absence of cyber insurance coverage, reinforcing the strategic/financial focus. All language is boilerplate with no named entities, frameworks, dates, or firm-specific facts.

thinking:
Let me analyze this paragraph from FOXO Technologies Inc.

Content: This paragraph contains a materiality assessment ("have not materially affected... our business strategy, results of operations, or financial condition"), mentions past threats/incidents generically, notes lack of cyber insurance, and has forward-looking risk language.

Category: The dominant content is the materiality disclaimer per Rule 6 → Strategy Integration. The paragraph explicitly assesses whether cybersecurity risks have materially affected business strategy, results of operations, or financial condition. There's also a mention of no cyber insurance coverage.

Specificity: Let me check for specific facts:
- No named frameworks, tools, firms, dates, dollar amounts, headcounts

- No cybersecurity-specific roles mentioned
- The insurance statement just notes the absence of coverage without any details
- This is entirely generic boilerplate language

→ Generic Boilerplate (1)


reasoning: The Board of Directors and Audit Committee are the grammatical subjects overseeing cybersecurity risk, with briefing cadence described — classic Board Governance. No firm-specific facts remain after filtering: 'Board of Directors', 'Audit Committee', 'independent directors', and 'quarterly' are all on the NOT list as generic governance language and generic cadences.

thinking:
Let me analyze this paragraph.

Content: Board and Audit Committee oversight of cybersecurity risks, briefing cadence, committee composition.

Category: Board Governance - the Board and Audit Committee are the grammatical subjects performing oversight.

Specificity: Let me check the facts:
- "Board of Directors" - generic (NOT list)
- "Audit Committee" - generic (NOT list)
- "composed entirely of independent directors" - generic
- "quarterly" - generic cadence
- No cybersecurity-specific roles, no named non-generic committees, no dates, no numbers, no named firms/tools

No named standards either. This is Generic Boilerplate.


reasoning: The Board is the grammatical subject throughout, performing oversight actions: reviewing the cybersecurity risk profile, receiving incident updates, and approving policy changes. No specific facts from the IS list are present — 'Board,' 'IT staff,' and generic cadences like 'prompt and timely' are all on the NOT list.

thinking:
Let me classify this paragraph.

Content: Board oversight of cybersecurity - Board receives information about incidents, reviews policies. The Board is the grammatical subject throughout.

Category: Board Governance - clear, the Board is the subject performing oversight actions.

Specificity: Let me check for specific facts.
- "Board" - generic governance, NOT list
- "IT staff" - generic, not cybersecurity-specific title
- No named frameworks, no dates, no named roles like CISO, no named committees beyond generic Board

No IS-list facts. No named standards. → Generic Boilerplate (1)


reasoning: Management is the grammatical subject throughout, describing its oversight responsibilities, charter adoption, training, and reporting relationship to the Board. However, no cybersecurity-specific titles (CISO, CIO, etc.) are named—only generic 'Management'—and the paragraph describes no specific processes, tools, or frameworks. The person-vs-function test is ambiguous since there is no identifiable person at all, but the paragraph's communicative purpose is defining management's organizational role and responsibilities rather than describing internal cybersecurity processes. No facts from the IS list are present; 'Management,' 'Board,' and generic cadences like 'periodically' are all on the NOT list.

thinking:
Let me analyze this paragraph.

Content: "Management oversees..." - management is the subject, describing their role in cybersecurity risk management. They adopted a charter, review/discuss with Board, may receive training, report to Board.

Category: This is about management's role but it's very generic. No named roles (CISO, CIO, etc.) - just "Management." It describes what management does in terms of process oversight and reporting to the board.

Person-vs-function test: This is about the function, not about any person. There's no named individual, no credentials, no specific role title. "Management" is generic.

Looking at the content more carefully, it's describing what management does—overseeing cybersecurity risk management, adopting a charter, reviewing with the board, and reporting back. There are no specific cybersecurity titles mentioned, and "Management" itself is too generic to be a named role. This is really about a management function rather than a person or defined role.

The paragraph is fundamentally about management's organizational responsibilities and their reporting relationship to the board, not about specific risk management processes or frameworks. Since there are no named frameworks, specific roles, dates, or concrete facts—just generic terms like "Management," "Charter," and "Board"—this falls into Generic Boilerplate.