reasoning: The paragraph's primary content is organizational structure: which committees exist, who sits on them (CTO, COO/CRO, CCO), and how they report to each other. While it mentions what the cybersecurity committee is responsible for (strategy, risk assessment, incident response), these are listed to define the committee's charter, not to describe processes in detail. The grammatical subjects are management-level committees and roles, not the board. CTO is a cybersecurity-specific title and both the ERM committee and cybersecurity committee are named non-generic committees on the IS list, yielding Firm-Specific. No QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes ERM committee oversight, cybersecurity committee, CTO membership, reporting structure.

Category: This is about management committees and their roles. The ERM committee and cybersecurity committee are the subjects. The CTO is mentioned as a member. This is about management structure and oversight - Management Role seems right since it's about who oversees what, committee composition, reporting lines.

Wait - let me reconsider. The paragraph describes committees and their functions. The ERM committee "oversees the firm's risk management process." The cybersecurity committee "directly oversees the firm's cybersecurity program and is responsible for cybersecurity strategy, risk assessment and management, and incident response management."

Applying the person-versus-function test here: the core of this is organizational structure—who sits where and what reporting lines exist. Even though the committees' responsibilities are mentioned, the substance really hinges on the committee composition and the CTO's role within that structure. This is Management Role. The CTO is a cybersecurity-specific title worth noting for specificity.

Now checking what qualifies as firm-specific: the CTO appears on the IS list, so that's firm-specific. Both the cybersecurity committee and ERM committee are named, non-generic committees that appear on the IS list. The COO, CRO, and CCO are generic C-suite titles that don't count. Quarterly is a standard cadence. For the QV check, I don't have any hard verifiable facts like dates, dollar amounts, headcounts, or named certifications—just role and committee names. So this lands as Firm-Specific based on the multiple IS facts: the CTO role, the cybersecurity committee, and the ERM committee.

fact: ERM committee oversees risk management including cybersecurity

fact: Cybersecurity committee directly oversees cybersecurity program

fact: CTO is a member of the cybersecurity committee


content_category: Third-Party Risk

category_confidence: high

specificity_confidence: high

reasoning: The entire paragraph is about oversight of third-party service providers — onboarding assessments, contract renewal reviews, security requirements imposed on vendors, and investigating vendor incidents. This is squarely Third-Party Risk as vendor oversight is the central topic. No named frameworks, tools, firms, dates, roles, or quantified details are present; the practices described (risk assessments at onboarding, requiring providers to meet security requirements) are generic and could apply to any company.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Content: About third-party service provider management - risk assessments at onboarding/renewal, security requirements imposed on providers. Central topic is vendor oversight.

Category: Third-Party Risk - the entire paragraph is about oversight of third-party service providers.

Specificity: No named frameworks, no named tools, no dates, no dollar amounts. No cybersecurity-specific titles. The paragraph describes generic vendor management practices. → Generic Boilerplate.


content_category: Strategy Integration

reasoning: The paragraph contains an explicit materiality assessment ('have not had a material impact on our operations, business strategy, or financial results'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, roles, dates, or other specific facts are present — pure boilerplate materiality language.

thinking:
Strategy Integration - materiality assessment is present.

Specificity: No named standards, no firm-specific facts. Generic boilerplate.


reasoning: The paragraph's primary communicative purpose is a materiality assessment — stating that no cybersecurity threats have materially affected or are reasonably likely to materially affect business strategy, results of operations, or financial condition. Per Rule 6, this is Strategy Integration even though boilerplate and accompanied by a cross-reference to Risk Factors. The third-party experts mention is subordinate. No firm-specific facts from the IS list are present.

thinking:
Let me analyze this paragraph.

Content: mentions third-party security experts for incidents, states no material incidents, makes materiality assessment, cross-references Risk Factors.

The dominant content is the materiality assessment ("not aware of any existent cybersecurity threats that would materially affect... business strategy, results of operations or financial conditions"). Per Rule 6, this is Strategy Integration.

Specificity: No named standards, no firm-specific facts from the IS list. The materiality language is boilerplate. Cross-reference is noise. → Generic Boilerplate.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal cybersecurity programs — safeguards, threat identification, risk management objectives — making it Risk Management Process. It names the NIST CSF as a guiding framework but provides no firm-specific facts beyond that; 'b1BANK' is a company self-reference (NOT list), and the program descriptions are generic. This yields Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity programs aligned with NIST, establishing safeguards, focusing on threats. This is about internal processes/programs.

Category: Risk Management Process - describes framework adoption, program structure, safeguards.

Specific facts:
- NIST Cybersecurity Framework → named standard → Sector-Adapted
- "b1BANK" → company self-reference → NOT list
- Named internal program? "Program(s)" is generic

Decision test:
1. Two+ hard verifiable facts? No.
2. Any IS-list fact? Let me check...

The paragraph lacks cybersecurity-specific titles, named committees, specific dates, or named tools—just a company self-reference and one named standard. Since NIST Cybersecurity Framework is a verifiable named standard, that's the key fact here.

fact: National Institute of Standards and Technology Cybersecurity framework (NIST CSF)

type: framework


reasoning: The paragraph's central topic is oversight of third-party providers — reviewing, monitoring, pre-engagement assessments, and ensuring compliance with cybersecurity standards. These are requirements imposed ON vendors, making this Third-Party Risk rather than Risk Management Process. No named frameworks, roles, dates, firms, or other specific facts appear; 'appropriate members of management' is generic.

thinking:
Classify this paragraph.

Content: About reviewing/monitoring third-party providers, assessments before engagement, ongoing monitoring for compliance with cybersecurity standards.

Category: Third-Party Risk - the central topic is oversight of external parties. Requirements imposed ON vendors (compliance with cybersecurity standards).

Specificity: No named frameworks, no named roles (just "appropriate members of management" which is generic), no dates, no specific facts.

This reads as generic boilerplate without concrete implementation details.


reasoning: The paragraph makes an explicit materiality assessment ('no cybersecurity incidents... had a material impact on our business strategy, results of operations or financial condition'), which is Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. The specific fiscal year-end date (December 31, 2023) is one hard fact, placing it at Firm-Specific.

thinking:
Classify this paragraph.

It contains a materiality assessment ("no cybersecurity incidents... had a material impact on our business strategy, results of operations or financial condition") → Strategy Integration per Rule 6.

Specificity: "December 31, 2023" is a specific date. That's one hard fact. Any others? No named firms, no dollar amounts, no headcounts. Cross-reference to Risk Factors is generic. So one specific date → Firm-Specific.

fact: year ended December 31, 2023


content_category: Board Governance

reasoning: While the first sentence names VP of Strategic Initiatives and CFO as program overseers, the bulk of the paragraph is about the Board of Directors' overall risk oversight responsibility and the Audit Committee's role in monitoring cybersecurity risk, receiving updates, and briefing the full Board — making the board/committee the dominant grammatical subject and primary actor. No cybersecurity-specific titles (CISO, CIO, CTO, VP of IT/Security) appear; 'VP of Strategic Initiatives' and 'CFO' are not on the IS list, and 'Audit Committee' and 'Board of Directors' are generic governance terms on the NOT list, leaving no qualifying specific facts.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses both management roles (VP of Strategic Initiatives and CFO) and board governance (Board of Directors, Audit Committee oversight). The primary focus is on the oversight structure - the Board has overall responsibility, delegated to Audit Committee, which receives updates from management. The board/committee is the primary actor for most of the paragraph.

Category: Board Governance - The Board and Audit Committee are the primary subjects for most of the paragraph. The first sentence mentions VP and CFO but in context of introducing who reports to the board. The rest is about Audit Committee monitoring, receiving updates, and updating the full Board.

Actually, I need to reconsider the specificity here. The VP of Strategic Initiatives isn't a cybersecurity-specific role—it's not on the list of IS roles like CISO or CTO. The CFO is generic C-suite, and both the Audit Committee and Board of Directors are standard governance bodies without named frameworks. So while the paragraph opens with management oversight, the dominant focus is on generic board governance structures rather than specialized cybersecurity roles or frameworks.


reasoning: The paragraph describes the company's framework adoption (CIS Critical Security Controls) and its alignment with NIST, ISO 27000, and FFIEC — all internal risk management methodology. It names multiple recognized standards (CIS, NIST, ISO 27000 series, FFIEC), triggering Sector-Adapted, but contains no firm-specific facts beyond stating adoption of these frameworks; no specific dates, headcounts, named tools, or cybersecurity-specific roles are present.

thinking:
Classify this paragraph.

Content: Describes the company's use of CIS framework, alignment with NIST, ISO 27000, FFIEC. This is about internal processes/framework adoption.

Category: Risk Management Process

Specificity: Names CIS Critical Security Controls, NIST, ISO 27000, FFIEC. These are named frameworks. But does it contain firm-specific facts? The company says it "uses" the CIS framework - that's a firm-specific claim (they adopt it). Let me think...

"Uses the CIS Critical Security Controls framework" - this is a certification/adoption claim specific to this company.

Actually, I need to distinguish between naming a framework versus holding a certification. The codebook treats "We maintain ISO 27001 certification" as Firm-Specific because that's a concrete achievement, whereas simply saying "We follow NIST CSF" is just naming a standard that many companies use. Here, the paragraph mentions multiple frameworks—CIS, NIST, ISO 27000, FFIEC—but doesn't claim any specific certification or unique implementation detail beyond adopting these sector-wide standards. That makes this Sector-Adapted rather than Firm-Specific.


reasoning: The paragraph contains an explicit materiality assessment ('have not had a material impact on the Company's operations, business strategies or financial results'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No named standards, firm-specific facts, or verifiable details are present — purely boilerplate materiality language.

thinking:
Classify this paragraph.

Content: Materiality assessment + forward-looking caveat + cross-reference to Risk Factors.

The key sentence: "To date, these risks, threats or attacks have not had a material impact on the Company's operations, business strategies or financial results" — this is an explicit materiality assessment → Strategy Integration per Rule 6.

The cross-reference doesn't change it per the codebook.

Specificity: No named standards, no firm-specific facts, pure boilerplate materiality language → Generic Boilerplate.


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity — vendor selection, contractual requirements, and risk-weighted assessment of vendors. No named standards, frameworks, specific roles, or firm-specific facts are present; the language is generic and could apply to any company.


reasoning: The paragraph describes an internal access control practice (granting access to authorized personnel, regular review), which is a component of the company's own cybersecurity risk management process. It contains no named frameworks, roles, tools, dates, or any firm-specific details — it is entirely generic language that could appear in any filing.

thinking:
Classify this paragraph.

This describes a generic access control practice. No named frameworks, no firm-specific details, no named roles or tools.

Content: It's describing an internal security practice (access control) - Risk Management Process.

Specificity: Completely generic boilerplate. No named standards, no specific facts.


reasoning: The Audit Committee is the grammatical subject throughout, driving oversight, reviewing reports, and governing security decisions — classic Board Governance. Management roles (CCO/CAO, CISO) are mentioned in subordinate context of reporting to the board committee. The CISO title and the specific attendee composition of committee meetings are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) appear, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The paragraph describes the Audit Committee's oversight of cybersecurity, mentions CCO/CAO and CISO roles, their reporting structure, meeting frequency, and attendees.

Category: The Audit Committee (board committee) is the primary grammatical subject throughout. The paragraph is about board-level oversight. While it mentions management roles (CCO/CAO, CISO), these are in the context of who reports to the Audit Committee. → Board Governance

Specificity: Let me check for specific facts:
- CISO → cybersecurity-specific title ✓ IS

- CCO/CAO (chief compliance & audit officer) → not on the IS list as cybersecurity-specific
- "at least four times a year" → generic cadence ("quarterly" equivalent)
- CLO, CFO, corporate controller, associate general counsel → generic C-suite titles
- The meeting attendee list includes specific composition: CCO/CAO, CISO, CLO, CFO, corporate controller, associate general counsel → this is a specific team/department composition ✓ IS

The CISO title is clearly IS-specific, and the detailed attendee roster represents a concrete organizational structure. The CCO/CAO reporting relationship to the Audit Committee is also a specific governance fact, even if the title itself isn't cybersecurity-exclusive.

For QV eligibility, I need hard verifiable facts like dates, dollar amounts, or named entities—generic cadences and role titles don't qualify. The meeting composition and CISO involvement give me firm-specific facts, but I'm short on the quantifiable data needed for QV classification.

This lands at Firm-Specific (3).

fact: CISO (chief information security officer)

fact: CCO/CAO (chief compliance & audit officer) with CISO as direct report

fact: Meeting attendees: CCO/CAO, CISO, CLO, CFO, corporate controller, associate general counsel


category_confidence: medium

reasoning: The paragraph describes external cybersecurity firms engaged to support the company's own security engineering, assessments, and audits. Per Rule 3, external assessors hired to serve the company are Risk Management Process, not Third-Party Risk. However, no named firms, frameworks, dates, or other specific facts are present—'leading cybersecurity firms' and 'regular assessments' are generic and appear on the NOT list.

thinking:
Classify this paragraph.

Content: describes engaging external cybersecurity firms for security engineering, assessments, and auditing. The central topic is about using third-party firms for security purposes. But wait - are these firms serving the company's own security (like external assessors hired to test the company), or is this about vendor oversight?

Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)". These firms are engaged to help with the company's own security - engineering, operations, assessments, audits. They serve the company. So this is Risk Management Process.

But wait - actually, re-reading: "engages leading cybersecurity firms to assist with its security engineering and operations; provide independent evaluations; audit and provide advice." These are external firms being used as part of the company's own security program.

So this falls under Risk Management Process. The language is vague though - "leading cybersecurity firms" without naming them, "regular assessments" without specifics, no mention of particular frameworks or methodologies. This reads as generic boilerplate rather than substantive detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes—assessments, audits, penetration testing, employee training, regulatory monitoring—all integrated into overall risk management. Third parties are mentioned as one component, not the central topic. No named frameworks, cybersecurity-specific roles, tools, firms, dates, or quantified facts appear; all items are common practices from the NOT list.

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

Content: Describes how cybersecurity risk is integrated into overall risk management, lists internal processes (assessments, audits, penetration testing, training, monitoring). Third parties are mentioned as one component, not the central topic.

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

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No cybersecurity-specific titles (CISO, CIO, etc.) - "internal IT Audit, IT security" are generic departments

- No named tools, firms, dates, or numbers
- Practices like penetration testing, employee training, and privacy reviews are standard industry activities
- Third party assessments and governance reviews lack any identifying details

This looks like generic boilerplate with no concrete, verifiable facts that would distinguish it from standard disclosure language.


reasoning: The paragraph's primary communicative purpose is explaining how cybersecurity risk management is structured for a trust entity with no employees — the Sponsor relies on BlackRock's ERM framework. While the board receiving periodic reports is a Board Governance element, the dominant content is the risk management structure and ERM integration. No IS-list facts are present: 'BlackRock' is the parent/sponsor (organizational self-reference), 'ERM framework' is a generic program name, 'Board of Directors' and 'periodically' are both on the NOT list.

thinking:
Let me analyze this paragraph from iShares Gold Trust (IAU), a trust entity that has no officers, directors, or employees.

The paragraph explains:
1. The Trust has no officers/directors/employees
2. The Sponsor (BlackRock subsidiary) manages the Trust
3. The Sponsor relies on BlackRock's ERM framework for cybersecurity
4. The Board of Directors of the Sponsor receives periodic reports on cybersecurity

This is an interesting case. The trust itself has no operations or employees, but it's not a SPAC - it's a gold trust. The paragraph is setting up context about how cybersecurity oversight works through the Sponsor/BlackRock structure.

Now I'm categorizing the content - this touches on both governance and risk management, but the real focus is on the structural arrangement. Since the Trust itself has no employees, the paragraph is essentially explaining the chain of responsibility: the Sponsor handles cybersecurity through BlackRock's ERM framework, and the Sponsor's board gets regular updates. That makes this primarily a governance piece about who oversees what, even though risk management processes are mentioned. The paragraph is primarily about Risk Management Process since it explains how cybersecurity risk management actually operates for this entity through BlackRock's ERM framework, even though it also touches on board governance with the reporting element. This isn't a case of no program—it's a legitimate cybersecurity structure routed through the Sponsor, so Risk Management Process is the dominant category here.

Looking at specificity, I'm not finding any IS-list facts: BlackRock is really just an organizational self-reference (the parent company managing the trust) rather than a named third-party firm, the ERM framework is generic, the board governance language is generic, and there are no named cybersecurity frameworks or specialized titles mentioned.

But reconsidering the overall framing—the paragraph establishes that the Trust has no internal staff and the Sponsor handles everything, then describes how cybersecurity risk management is structured through periodic reporting and an ERM framework. That Risk Management Process angle seems more central than just Board Governance, though it's borderline.

I'm settling on Risk Management Process as the dominant category with moderate confidence, since this is really a structural paragraph explaining how the entity's cybersecurity oversight works.


reasoning: The paragraph contains an explicit materiality assessment ('have not encountered cybersecurity incidents or challenges that have materially affected or are reasonably likely to materially affect our company, strategy, results of operations or financial condition'), which per Rule 6 makes this Strategy Integration. The first sentence about management's judgment on process adequacy supports the strategic assessment. No specific facts from the IS list are present — 'IT consultant' is unnamed, and the materiality language is boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. Management's judgment about processes being appropriate
2. A materiality disclaimer

The materiality disclaimer is explicit: "have not materially affected or are reasonably likely to materially affect our company, strategy, results of operations or financial condition" → Strategy Integration per Rule 6.

The first sentence discusses management's judgment about processes, mentioning an "IT consultant." But the dominant content is the materiality assessment.

Specificity: "IT consultant" is unnamed → generic. The materiality language is boilerplate. No named frameworks, no specific facts from the IS list.

So this is generic boilerplate—the materiality language is standard language without concrete details or named frameworks.


reasoning: The Audit Committee is the grammatical subject throughout, receiving updates, materials, and incident reports from management — classic board oversight disclosure. All details are generic: 'Audit Committee' is standard governance, 'quarterly' is a generic cadence, 'General Counsel' and 'Information Technology team' are not cybersecurity-specific titles on the IS list, and no named frameworks, firms, or specific facts appear.

thinking:
Let me analyze this paragraph.

Content: The paragraph describes the Audit Committee receiving updates from management about cybersecurity. The Audit Committee is the grammatical subject throughout - it receives updates, receives materials, receives information. This is about board-level oversight.

Category: Board Governance - the Audit Committee (board committee) is the subject performing oversight actions.

Specificity analysis:
- "Audit Committee" - NOT list (generic governance)
- "quarterly" - NOT list (generic cadence)
- "Information Technology team" - not a cybersecurity-specific title
- "General Counsel" - NOT list (generic C-suite)

- "third-party assessments" - NOT list (unnamed entities)
- "incident response plan" - NOT list (generic program name)

After filtering, no facts from the IS list remain. No named standards either. This falls into generic boilerplate.


specificity_confidence: medium

reasoning: The paragraph's primary purpose is a materiality assessment — it explicitly states the company 'does not believe that risks from cyber security threats or attacks have materially affected the Company since 2017,' making it Strategy Integration per Rule 6. The cross-reference to Risk Factors does not override the materiality conclusion. Two specific dates (2016 and 2017) referencing actual cyber attacks are independently verifiable hard facts, reaching the QV threshold.

thinking:
Let me analyze this paragraph.

Content: This paragraph makes a materiality assessment ("does not believe that risks from cyber security threats or attacks have materially affected the Company since 2017"), references past cyber attacks in 2016 and 2017, and includes a cross-reference to Risk Factors. The primary purpose is a materiality assessment → Strategy Integration per Rule 6.

Specific facts:
- "2016 and 2017" - specific dates referencing when cyber attacks occurred
- These are specific years → specific dates

Let me count QV-eligible facts:
- "2016" - specific date ✓
- "2017" - specific date ✓ (appears multiple times but refers to related timeframe)

- The years 2016 and 2017 are two distinct date references, making them Quantified-Verifiable facts.

fact: cyber attacks in 2016

fact: cyber attacks in 2017


reasoning: The paragraph describes the company's internal cybersecurity processes: technology risk management, control testing, risk assessments, phishing monitoring, third-party risk management program, and audit reviews. The VP, ISS is mentioned as attribution for who manages these functions, but the substantive content is about what the program does — applying the person-vs-function test, removing the role title leaves a coherent process description. The cybersecurity-specific title (VP of Information Security Systems) is the sole IS-list fact, yielding Firm-Specific but not QV.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes the company's internal cybersecurity processes extensively - risk management framework, testing, assessments, monitoring, third-party risk management program, email gateway monitoring, audits. The VP, ISS is mentioned but the paragraph is about what the function/program does, not about the person's qualifications or background. Applying the person-vs-function test: if I remove "VP, ISS" and replace with "the Company," the paragraph still makes complete sense as a process description. → Risk Management Process

Specific facts:

The title "Vice President of Information Security Systems" is a cybersecurity-specific role that qualifies as an IS-list item. I don't see any named standards like NIST or ISO, specific dates, dollar amounts, named firms, or tools mentioned - just this one role title that's relevant to the IS list. That makes this Firm-Specific (3) with one QV-eligible fact.

fact: Vice President of Information Security Systems (VP, ISS)


reasoning: The paragraph opens with an explicit materiality assessment ('not experienced a cybersecurity incident that has had a material impact to date'), which per Rule 6 triggers Strategy Integration. The subsequent enumeration of generic risk types (ransomware, data breaches, regulatory exposure) is boilerplate risk language that does not shift the category. No named frameworks, dates, tools, roles, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with a materiality assessment ("not experienced a cybersecurity incident that has had a material impact"), then lists generic risk types (ransomware, data breaches, regulatory exposure).

Category: The materiality assessment ("has not had a material impact") makes this Strategy Integration per Rule 6. The risk enumeration is generic.

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


reasoning: The paragraph opens with an explicit materiality assessment ('not aware of any cybersecurity threats that have materially affected or are reasonably likely to materially affect us, including our 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. No named frameworks, firm-specific facts, or verifiable details are present — the materiality language is boilerplate.

thinking: Materiality assessment paragraph with cross-reference.


reasoning: The paragraph's primary substantive content is an explicit materiality assessment ('not aware of any cybersecurity threats or incidents that have materially affected our business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors and forward-looking disclaimer. The mention of third-party provider incidents is brief context, not the central topic. No named standards, firm-specific facts, or hard verifiable details are present — the language is boilerplate materiality disclaimer.

thinking:
Let me analyze this paragraph.

Content: mentions third-party incidents, then makes a materiality assessment, then a forward-looking disclaimer, then a cross-reference.

Category: The core substantive claim is the materiality assessment ("we are not aware of any cybersecurity threats or incidents that have materially affected our business strategy, results of operations, or financial condition"). Per Rule 6, this is Strategy Integration. The cross-reference doesn't change that.

Specificity: No named standards, no firm-specific facts from the IS list. The materiality language is boilerplate. → Generic Boilerplate.


reasoning: The Board of Directors is the grammatical subject throughout most of the paragraph, describing its oversight role, briefing content, and update cadence — classic Board Governance. The named cybersecurity-specific role (VP of Information Services) elevates specificity to Firm-Specific, but no second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board of Directors oversight, receives updates from VP of Information Services, topics covered in briefings, plus employee training mention.

Category: The Board is the grammatical subject for most of the paragraph. "The Board of Directors, having ultimate oversight..." and "Cybersecurity information provided to the Board comprises..." - this is Board Governance. The last sentence about employee training is subordinate.

Specificity: Let me check facts:
- "Vice President of Information Services" - this is a cybersecurity-specific title? Let me check... "VP of IT/Security" is on the IS list.

"Vice President of Information Services" is close to VP of IT, so I'd consider this a cybersecurity-specific role variant. The other details—annual and periodic updates, mandatory quarterly employee training, and the Board of Directors itself—are all generic practices without specificity. The topics listed are also generic. So I'm left with one specific fact: the VP of Information Services title, which gives me Firm-Specific (3). There are no QV-eligible facts here—no dates, dollar amounts, headcounts, named firms, tools, or certifications.

fact: Vice President of Information Services


reasoning: The paragraph describes the company's recognition of cybersecurity risk categories and references the SEC regulation basis, framing it as part of their risk management approach. However, it contains no named frameworks, no firm-specific details, no specific processes — it is entirely generic language that could appear in any filing unchanged.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident — unauthorized access detected, containment steps taken, threat actor ejected — making it clearly Incident Disclosure. It contains a specific date (July 10, 2024) repeated twice but referring to the same day, and the external cybersecurity specialists are unnamed ('leading external cybersecurity specialists'). With only one distinct hard verifiable fact (the date), this reaches Firm-Specific but not Quantified-Verifiable.

thinking: Incident description with specific dates and actions taken.

fact: July 10, 2024 (detection date)

fact: July 10, 2024 (threat actor ejected date)


reasoning: The entire paragraph is about oversight of third-party service providers — their role in the cybersecurity program, the questionnaire process imposed on them, and annual review of their attestation reports. This is vendor oversight as the central topic, not a brief mention within an internal process description. No named standards (e.g., SOC 2), no named firms, no specific dates or numbers — all descriptions are generic ("detailed questionnaire," "independent attestation reports," "annual review").

thinking:
Let me analyze this paragraph from J&J Snack Foods Corp's 10-K filing.

Content: Describes third-party service provider oversight - questionnaires, attestation reports, penetration testing by third parties, vendor risk processes. The central topic is oversight of external parties.

Category: Third-Party Risk - the entire paragraph is about how the company oversees third-party service providers' cybersecurity.

Specificity: Let me check for specific facts:
- No named firms, tools, dates, dollar amounts, headcounts
- No named frameworks (SOC 2, ISO, NIST not mentioned explicitly)

- The language relies on generic terms like "independent attestation reports," "detailed questionnaire," and "annual review" without any company-specific details or named cybersecurity standards.

This is Generic Boilerplate - standard vendor oversight language without concrete facts or named frameworks.


reasoning: The paragraph is framed around Board oversight: the Board annually reviews the Information Systems Security Program, and the COO reports security incidents to the Board. The Board is the primary oversight actor in both sentences, with the COO detail subordinate to the board reporting structure. The COO (a generic C-suite title per the NOT list) does not trigger Firm-Specific, but '30 years of experience' is a specific quantified duration that qualifies as one hard fact, reaching Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes an Information Systems Security Program reviewed by the Board, and a COO with experience who reports to the Board.

Category analysis:
- Board reviews the program annually → Board Governance
- COO with 30 years experience, reports to Board → Management Role
- The program itself → Risk Management Process

The paragraph has two main elements: (1) Board reviews the program, (2) COO's experience and reporting. The Board is the subject of the first sentence. The second sentence is about the COO (management role) reporting to the Board.

This is a dual-category paragraph. The first sentence frames Board oversight of the program.

Now I'm reconsidering the structure. The opening sentence establishes Board governance over the program, while the second sentence focuses on the COO as the subject—their qualifications and reporting relationship to the Board. The COO's 30 years of experience is a personal credential. So I'm looking at whether the dominant framing is the Board's oversight role or the COO's management position. The paragraph opens with Board governance but then shifts focus to the COO as the primary subject in the second sentence.

Actually, I think the Board's oversight function is the frame that anchors both sentences—the COO's role and experience are presented as supporting details within that governance structure. So Board Governance seems like the right category here.

Now I'm checking the specificity level. The COO title itself isn't cybersecurity-specific according to the IS list, but the mention of "30 years of experience in operations and information security" does ground this in the security domain.

Looking at what qualifies as specific facts: the program name is generic, COO is a standard C-suite title, and "annually" is just a common cadence. But "over 30 years of experience" is a quantified fact that matches the IS list criteria for specific numbers. That gives me one concrete fact, which points to Firm-Specific.

fact: over 30 years of experience in operations and information security

type: quantified


content_category: Management Role

reasoning: The paragraph is roughly split between Board Governance (first three sentences: committee reports to board, board briefings, continuing education) and Management Role (last three sentences: named management team composition, responsibilities, experience). The management section is more substantive, identifying the specific team (CFO, Senior Director of IT, SVP Quality Assurance) responsible for cybersecurity, their oversight scope, and their qualifications — making Management Role the dominant category. The specific team composition (three named roles forming the cybersecurity oversight team) is a firm-specific fact analogous to 'Legal, Compliance, and Finance' on the IS list, though no individual role qualifies as a cybersecurity-specific title.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Committee reports to Board on cybersecurity (Board Governance)
2. Board receives briefings from management (Board Governance)
3. Board continuing education (Board Governance)
4. Management team roles - CFO, Senior Director of IT, SVP Quality Assurance (Management Role)
5. Team's responsibility for cybersecurity program (Management Role / RMP)
6. Management team experience (Management Role)

The first half is about Board activities, the second half shifts to management. Let me assess dominance.

Looking at the specific sentences, the Board Governance content takes up three full sentences while Management Role spans two sentences. The Board activities are more detailed and come first, so Board Governance appears to be the dominant category here, though there's a meaningful shift toward management responsibilities in the latter half. The management section with its named roles and specific responsibilities is more substantive than the generic board oversight language, so this should be classified as Management Role. Though I'm second-guessing whether "Senior Director of Information Technology" counts as cybersecurity-specific enough, the detailed identification of who's responsible and what they're accountable for makes the management focus the primary purpose here. I'm reconsidering whether the specific team composition—CFO, Senior Director of IT, and SVP Quality Assurance—actually qualifies as firm-specific. The codebook example of "Legal, Compliance, and Finance" suggests that naming these particular roles together does reveal something unique about how this company structures its cybersecurity oversight, making it firm-specific rather than generic boilerplate. So this lands as Management Role, Firm-Specific (3), though I'm less confident here—around 0.65 on specificity and 0.55 on whether it's truly a Management Role versus Board Governance.

fact: Management team composition: Chief Financial Officer, Senior Director of Information Technology, and Senior Vice President, Quality Assurance


reasoning: The paragraph describes the company's cybersecurity program across multiple domains (governance, technical safeguards, incident response, third-party risk, education, assessment/testing). While the Audit Committee and VP of IT are mentioned under a governance sub-heading, the dominant communicative purpose is a comprehensive overview of internal cybersecurity processes. The VP of Information Technology is a cybersecurity-specific title on the IS list, yielding Firm-Specific; however, all other content (firewalls, tabletop exercises, vulnerability testing, third-party assessments, training) is generic practice language with no named frameworks, tools, firms, dates, or quantified facts.

thinking:
Let me analyze this paragraph from Douglas Dynamics (PLOW) 10-K filing.

This is a long paragraph covering multiple aspects of their cybersecurity program: governance, collaborative approach, technical safeguards, incident response, third-party risk management, education, and testing/assessment.

Content Category: This paragraph describes the company's internal cybersecurity processes across multiple domains. While it mentions the Board/Audit Committee and VP of IT briefly under "Governance," the dominant content is about the company's risk management processes. The paragraph is structured around key areas of their cybersecurity program. → Risk Management Process

Looking at the specifics, I found one firm-specific fact: the Vice President of Information Technology role matches the IS list item for "VP of IT/Security." The rest—firewalls, intrusion prevention, tabletop exercises, vulnerability testing—are all generic industry practices without any hard facts like dates, dollar amounts, or named tools. → Firm-Specific (3)


reasoning: The main clause's grammatical subject is the Board of Directors, which 'discusses risks and threats' and 'inquires of management regarding design and effectiveness of controls' — classic board oversight language. The materiality assessment ('does not consider cybersecurity threats to be a material risk to the business strategy, results of operations or financial position') appears in the subordinate 'While' clause, making it contextual framing rather than the primary communicative purpose. No specific facts from the IS list: no cybersecurity-specific titles (explicitly states no CIO), no named committees beyond generic 'Board of Directors,' no frameworks, dates, or numbers.

thinking:
Let me analyze this paragraph carefully.

This is a small company (Greystone Logistics) that explicitly states they don't have a CIO and don't consider cybersecurity a material risk. But then it describes board oversight activities.

Content Category: This paragraph has two parts:
1. A materiality assessment ("does not consider cybersecurity threats to be a material risk to the business strategy, results of operations or financial position") → Strategy Integration
2. Board oversight description ("Board of Directors discusses risks... inquires of management regarding...") → Board Governance

The materiality disclaimer is significant but the dominant content is the Board's activities - "discusses risks and threats" and "inquires of management regarding design and effectiveness of controls." The board is the grammatical subject of the main clause.

I'm weighing whether the explicit materiality language using the SEC formula should override the dominant content test. The paragraph opens with two negatives—no CIO, not a material risk—then pivots to describing what the Board actually does. The materiality conclusion is clearly stated per Rule 6, but the Board's activities occupy more of the text and serve as the primary communicative focus. This feels like a close call between Strategy Integration and Board Governance, though the Board's role as the main actor and the substance of their oversight activities might tip it toward Board Governance.

Now I'm checking the specificity level. There are no named frameworks, no specific facts from the IS list, and all references are generic—"Board of Directors," "Management," no named committees or CISO. This points to Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected... business strategy, results of operations and financial condition'), which per Rule 6 is Strategy Integration even though it includes a cross-reference to Risk Factors. No firm-specific facts are present — 'In 2024' is a generic fiscal year reference and the rest is boilerplate materiality language.


reasoning: The paragraph makes an explicit materiality assessment ('have not materially affected' and 'not reasonably likely to materially affect'), which per Rule 6 is Strategy Integration even though it is 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.


reasoning: The paragraph is framed by the board's overall oversight responsibility for cybersecurity risk management, opening and closing with the board/audit committee. Management and the VP of Operations are described in a subordinate role within this governance hierarchy. The VP of Operations is not a cybersecurity-specific title per the IS list (it is a general operations role that happens to oversee cybersecurity), the Audit Committee is generic, and no named frameworks, dates, or other firm-specific facts appear, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Board has oversight, management identifies risks, VP of Operations directs cybersecurity programs, incidents reported to audit committee and board.

Category: This paragraph covers multiple topics - board oversight, management responsibility, and the VP of Operations role. The board is mentioned at the start and end, but the middle bulk describes management's responsibilities and the VP of Operations. The grammatical subjects shift: board (first sentence), management (second sentence), VP of Operations (third sentence), incidents reported to audit committee/board (fourth sentence).

The dominant topic: it's a mixed paragraph. The board frames the paragraph but the substantive content is about management processes and the VP of Operations directing cybersecurity.

Now I'm applying the categorization rules to each sentence. The first and last sentences clearly fall under board governance since they establish the board's oversight role and reporting structure. The middle sentences focus on management's risk identification process and the VP of Operations directing cybersecurity programs. The VP of Operations is really the key player here—they're the one actually directing the cybersecurity functions like prevention, detection, mitigation, and remediation. So while the board provides the governance frame, the paragraph's substance is really about how management and the VP of Operations execute the cybersecurity strategy and report back up the chain. to oversee cybersecurity. So this is NOT on the IS list. "audit committee," "board of directors," and "management" are all generic governance terms, not cybersecurity-specific. VP of Operations isn't listed either—it's a general corporate role, not a dedicated information security position like CISO or VP of IT/Security would be. There are no named frameworks, dates, or numbers here, which means after filtering out the generic governance language, nothing specific remains. This is Generic Boilerplate.


reasoning: The paragraph describes how the company's internal cybersecurity program coordinates across functional areas to identify threats and update processes — squarely about internal processes, not about any specific person or board oversight. The enumeration of specific departments (IT, legal, risk, HR, internal audit) constitutes a firm-specific team/department composition per the IS list, elevating this above Generic Boilerplate, though no second hard verifiable fact is present to reach QV.

thinking:
Let me classify this paragraph.

Content: Describes how the cybersecurity program interfaces with various departments and external partners to identify threats, and mentions regular updates to processes.

Category: This is about internal cybersecurity processes - how the program works across departments. Risk Management Process.

Specificity: Let me check for specific facts.
- "information technology, legal, risk, human resources and internal audit departments" - this is a team/department composition. Per the IS list: "Specific team/department compositions: 'Legal, Compliance, and Finance'" → this qualifies as firm-specific.

- "external third-party partners" and "regularly assess and update" are both generic language that don't add firm-specific detail.

The department composition itself is specific enough to count as a firm-specific fact per the IS list.

Specificity: Firm-Specific (3)

fact: Program interfaces with information technology, legal, risk, human resources and internal audit departments


reasoning: The Board of Directors is the grammatical subject throughout — reviewing/approving programs, monitoring risks, and adding a member with cyber expertise. This is board-level oversight disclosure. Specificity is Quantified-Verifiable: multiple hard verifiable facts including the named individual (Sara A. Schmidt), named external firm (US Foods), and named organization (West Michigan Cyber Security Consortium).

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses Board of Directors oversight of cybersecurity, including approving specific named programs (ICSPP and ICSIRP), and mentions a specific board member with cybersecurity expertise.

Content Category: Board Governance - The Board is the grammatical subject performing oversight actions (reviewing/approving programs, monitoring risks, adding a member with expertise).

Specificity: Let me check for facts.
- "ICSPP and ICSIRP" - named internal programs with unique identifiers → IS list
- "Director Sara A. Schmidt" - named individual → QV-eligible? Named individuals are specific facts

- "chief information security officer" - cybersecurity-specific title (for US Foods, but still a specific fact about the board member)
- "US Foods" - named firm
- "West Michigan Cyber Security Consortium" - named organization

I'm identifying the verifiable facts here: Sara A. Schmidt as a named individual, US Foods as a named firm, and West Michigan Cyber Security Consortium as a named organization. That gives me at least two hard verifiable facts, which qualifies this as Quantified-Verifiable.

fact: ICSPP and ICSIRP (named internal programs)

fact: Director Sara A. Schmidt

fact: CISO role (at US Foods)

fact: US Foods

fact: West Michigan Cyber Security Consortium


reasoning: The paragraph's primary content is about management's organizational responsibility for cybersecurity risk and the establishment of a committee chaired by a senior IT leader — this is about who is responsible (management structure), not about the processes themselves. 'Executive Director of Information Technology' is a generic IT leadership title per the NOT list (analogous to 'Director of IT'), and 'a committee of senior leaders' is unnamed and non-specific, so no IS-list facts survive the validation step, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Management's day-to-day risk administration, risk management framework (identification, analysis, response), committee of senior leaders chaired by Executive Director of Information Technology.

Category: This is about management's role and a committee structure. The paragraph describes who is responsible (management, a committee chaired by Executive Director of IT). It mentions a risk management framework but only briefly. The primary content is about organizational structure - who does what.

Person-vs-function test: The paragraph mentions "Executive Director of Information Technology" as chairing a committee. It's describing organizational structure (committee, who chairs it) rather than the person's credentials.

The core here is organizational structure for cybersecurity risk management - management handles day-to-day administration and has a framework in place, with oversight from a senior leadership committee. The "Executive Director of Information Technology" title suggests this falls under Management Role since it's describing the committee structure and leadership hierarchy rather than specific cybersecurity credentials like CISO or CIO. Officer, Director of IT Security, HSE Director overseeing cybersecurity." "Executive Director of Information Technology" is more like a generic IT title. It's not exactly CIO or VP of IT/Security. It's closer to "Director of IT" which is on the NOT list ("Generic IT leadership (NOT cybersecurity-specific): 'Head of IT', 'IT Manager', 'Director of IT'").

Actually, "Executive Director of Information Technology" is essentially "Director of IT" - which is on the NOT list.

But the committee of senior leaders - is this a named non-generic committee? No, it's just "a committee of senior leaders" - no specific name.

So for specificity: No IS-list facts remain after filtering. No named standards. → Generic Boilerplate.

For category: The paragraph covers both a risk management framework with the basic steps of identification, analysis, and response, plus the management structure responsible for oversight. While the framework itself is pretty generic, the main focus is really on who's accountable - management and their committee - so this lands in Management Role.


reasoning: The paragraph describes the company's internal cybersecurity processes (identify, assess, manage risks) covering various systems and data types. No named frameworks, specific roles, dates, or firm-specific facts are present — the language is generic and could apply to any company.


reasoning: The paragraph contains an explicit materiality assessment ('have not had a material impact on our operations, business strategy or financial results'), which per Rule 6 makes it Strategy Integration even though it includes a cross-reference to Risk Factors and generic forward-looking language. No named standards, firm-specific facts, or verifiable details are present.

thinking:
Materiality assessment present → Strategy Integration per Rule 6.

Specific facts: None on the IS list. Pure boilerplate materiality language.


reasoning: The paragraph's primary communicative purpose is describing how the company's risk management program is structured—from broad ERM down to cybersecurity oversight. The Director of Information Security's reporting line and committee memberships serve to illustrate program structure rather than describe the person's qualifications or background (person-vs-function test: no credentials, experience, or career history are given). Multiple firm-specific facts (cybersecurity-specific roles, named non-generic committees) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, tools) are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: ERM program description, board oversight, and management roles. Let me determine the dominant category.

Content breakdown:
1. First two sentences: describe the ERM program and cybersecurity as a component - Risk Management Process
2. "Our Board of Directors is responsible for risk oversight..." - Board Governance
3. "While our Board of Directors takes an oversight role... we rely to a large degree on management and outside consultants" - transitional
4. "Our Director of Information Security, who reports directly to our Chief Information Officer, is primarily responsible for this cybersecurity component and is a member of management's Operational Risk and IT Steering Committees, and regularly attends and presents to the Risk Committee of our Board of Directors" - Management Role

5. The paragraph establishes the cybersecurity risk management structure from the ERM framework down through the board's oversight role to the specific Director of Information Security position, with the most substantive detail focused on that director's reporting relationships and committee participation. The Director of Information Security role is the most concrete detail here, but the paragraph's real focus is explaining how the company structures its risk management program overall. I'm applying the person-versus-function test: this is fundamentally about organizational structure and reporting relationships rather than describing a specific management role in isolation. Risk Management Process seems like the right category since the paragraph is laying out how the risk management framework operates, with the management role as one structural component of that system. I'm wrestling with whether the primary focus here is the risk management program structure or the management role itself. The paragraph does open with the ERM framework, but the most substantive detail—the Director of Information Security's reporting lines and committee memberships—is what actually anchors the content. Stripping away those specifics leaves only generic context, so I think Management Role is the right call after all. All of these are company-specific details with no quantifiable metrics or external references, so they fall under Firm-Specific rather than QV-eligible.

fact: Director of Information Security

fact: Chief Information Officer (CIO)

fact: Risk Committee of the Board


reasoning: The paragraph's central topic is oversight of external vendors — due diligence reviews and contractual security requirements imposed ON third-party vendors. Despite the future-tense framing ('we will implement'), the communicative purpose is third-party risk management. No named standards, frameworks, specific roles, dates, or other facts from the IS list appear; the descriptions (due diligence, contractual requirements, robust security controls) are generic and could appear in any company's filing unchanged.

thinking:
Let me analyze this paragraph.

Content: About third-party vendor risk management - due diligence reviews, contractual requirements. The central topic is oversight of external parties.

Category: Third-Party Risk - vendor oversight is the central topic.

Note: "we will implement" - future tense, suggesting the program doesn't exist yet. But the paragraph is still about third-party risk management.

Specificity: No named standards, no firm-specific facts. Generic descriptions of due diligence and contractual requirements. No named roles, no specific frameworks.

Check IS list: Nothing qualifies.

There's no mention of specific cybersecurity roles, governance committees, dates, or particular tools either. No standards are cited by name. This is generic boilerplate language.


reasoning: The paragraph discusses cybersecurity insurance coverage as part of the company's risk mitigation strategy, which falls under Strategy Integration (insurance, financial impact mitigation). No specific amounts, named insurers, deductibles, or other firm-specific details are provided — it is a generic statement that could apply to any company.

thinking: Classify this paragraph about cybersecurity insurance.


reasoning: The paragraph's primary communicative purpose is identifying who leads cybersecurity at the company — senior management, IT staff, and a third-party partner — along with the partner's qualifications (21 years of experience) and the coordination/reporting structure between them. While continuous monitoring and meetings are mentioned, they serve to describe how these parties interact rather than detailing substantive internal processes or tools. The 21 years of experience is one specific quantified fact (Firm-Specific), but no second QV-eligible hard fact is present to reach Quantified-Verifiable. The third-party partner is unnamed, senior management is generic, and no cybersecurity-specific titles (CISO, CTO, etc.) appear.

thinking:
Let me analyze this paragraph.

Content: Describes management leading cybersecurity processes, mentions a third-party business technology partner with 21 years of experience, and describes monitoring/meetings for updates.

Category: This is about management's role in cybersecurity. The paragraph describes who leads the processes (senior management + IT staff + third-party partner), the partner's experience, and the reporting/meeting structure. The person-vs-function test: it mentions senior management leading processes, describes the third-party partner's experience (21 years), and describes monitoring/meetings. It's a mix - there's some "person" content (the partner's experience) and some process content (continuous monitoring, routine meetings).

The core focus is on management structure and coordination—who's responsible for cybersecurity and how they work together, with the third-party partner's qualifications serving as evidence of capability. It's primarily about the management role with process elements woven in, so this leans toward Management Role with Risk Management Process components. Looking at the specificity here, there's really just one concrete, verifiable fact: the 21 years of experience for the third-party partner. Everything else—senior management, IT staff, the unnamed partner itself—is too generic to count. That single hard number puts this at Firm-Specific level.

fact: Third-party business technology partner has over 21 years of experience in cybersecurity and information technology


reasoning: The paragraph primarily describes internal security awareness training programs (annual training, periodic updates, regular testing) which are the company's own risk management activities. The cybersecurity insurance mention is secondary. All details are generic — no named standards, no firm-specific facts, no named insurers or dollar amounts — making this boilerplate.

thinking:
Classify this paragraph.

Content: Security awareness training + cybersecurity insurance policy purchase.

Category: The paragraph describes two things: (1) security awareness training programs (Risk Management Process) and (2) cybersecurity insurance (Strategy Integration). The training is the dominant content (more text), but the insurance mention is also notable. Training is an internal process → Risk Management Process. Insurance → Strategy Integration. The training occupies more text, so dominant category = Risk Management Process.

Wait, let me reconsider. The insurance is a brief mention. The training is the main content. But both are fairly generic. Let me think about which is dominant - the training description takes up most of the paragraph. → Risk Management Process.

The insurance purchase is a strategic decision, but it's not vendor oversight. The paragraph splits roughly 70/30 between training and insurance, making training the dominant element. Looking at the specificity, both components are generic—the training mentions standard practices like periodic updates and regular testing, while the insurance reference lacks any named insurer or specific amounts. → Generic Boilerplate.


reasoning: The paragraph transitions from brief Board Governance content (committee reports, board briefings) to a dominant focus on the management team responsible for cybersecurity: it names a specific individual (R. LaDuane Clifton), describes the team's responsibilities, and quantifies IT staff experience (40 years combined). The person-vs-function test favors Management Role since the paragraph emphasizes who the people are and their qualifications. CFO is on the NOT list as generic C-suite, but the named individual and quantified experience are firm-specific; however only one QV-eligible fact (40 years) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Committee reports to Board about cybersecurity activities
2. Board receives briefings from management
3. Board members receive presentations on cybersecurity
4. Management team including named CFO is responsible for assessing cyber risks
5. Team supervises internal and external cybersecurity personnel
6. IT staff with 40+ years combined experience

The primary focus shifts from board activities to management's role. The named individual (R. LaDuane Clifton, CFO) and the description of team qualifications (40 years combined experience) suggest Management Role. But let me apply the person-vs-function test.

The paragraph mixes board governance elements with management responsibilities, though the bulk of the content focuses on who manages the cybersecurity program and their qualifications. However, I need to verify whether the CFO actually qualifies as a key person or falls into an excluded category.

Looking at the guidelines, generic C-suite titles like CFO don't count as cybersecurity-specific facts. But R. LaDuane Clifton is a named individual, and the "40 years of combined experience" is a concrete metric. These are firm-specific details that matter. The paragraph's primary purpose is describing the management team overseeing cybersecurity, so this falls under Management Role rather than Board Governance.

Now checking what qualifies as QV-eligible: the 40 years of experience is a specific number that fits the list, but the named individual itself isn't explicitly included in the QV criteria. So I'm left with one QV-eligible fact from this paragraph. I'm checking whether the named individual qualifies as a QV-eligible fact by comparing it against the explicit QV list, and it doesn't appear there—only the 40 years of experience counts as quantified and eligible. So this lands as Firm-Specific with just one QV fact, and the overall category is Management Role since the passage focuses on the team's qualifications and names a specific person.

fact: R. LaDuane Clifton, Chief Financial Officer, Secretary and Treasurer

fact: 40 years of combined experience


reasoning: The paragraph's primary purpose is identifying which management personnel (COO, SVP for Operations) are responsible for cybersecurity and describing their responsibilities — this is about the persons filling roles, not about the processes themselves. However, COO is a generic C-suite title (on the NOT list), and 'Senior Vice President for Operations' is a general operations title, not a cybersecurity-specific role. No named frameworks, dates, numbers, tools, or cybersecurity-specific titles appear, leaving no facts on the IS list after validation.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes management roles (COO, SVP Operations) and what they do regarding cybersecurity. Let me apply the person-vs-function test.

The paragraph mentions COO and Senior Vice President for Operations. It describes their responsibilities: hiring personnel, integrating cybersecurity into ERM, communicating priorities, reviewing security assessments.

Person-vs-function test: If I remove the titles, the paragraph describes functions - hiring, integrating risk, communicating, reviewing assessments. But the paragraph is primarily about WHO is responsible (COO, SVP Operations) and what their responsibilities are, not about the processes themselves in detail.

Looking at the opening more carefully, it frames this as process implementation with specific roles attached to it. The paragraph is fundamentally identifying which management positions own cybersecurity responsibilities, making it a Management Role category despite COO being a generic title rather than a cybersecurity-specific one.

Checking against the specificity criteria: "Senior Vice President for Operations" isn't a cybersecurity-specialized title, COO is explicitly on the NOT list, and there are no frameworks, dates, numbers, or named tools present. This leaves me with Generic Boilerplate.


reasoning: The paragraph's primary subject is the Director of IT — their responsibility for cybersecurity and their extensive experience. Two of three sentences describe the person (role assignment, qualifications), with only the final sentence shifting to team monitoring activities. Under the person-vs-function test, the paragraph is predominantly about who holds the role and their experience, making it Management Role. However, 'Director of IT' is generic IT leadership per the IS-NOT list (not a cybersecurity-specific title like CISO), and no named frameworks, dates, numbers, firms, or other specific facts appear, so specificity is Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Talks about "Director of IT" - their responsibility and experience, then shifts to what "the team" does (monitors, investigates, acts on security events).

Category: The person-vs-function test. The paragraph mentions Director of IT's responsibility and "extensive experience" - that's about the person. But then it shifts to what the team does (monitors, investigates, acts). The first two sentences are about the person (role, experience), the third is about the function. It's roughly split, but the primary subject introduced is the Director of IT and their qualifications. Actually, the second sentence says "It has extensive experience" - describing the person's qualifications.

Now I'm noticing that "Director of IT" appears on the IS NOT list as generic IT leadership, not cybersecurity-specific, so this doesn't qualify as a specific fact. Looking at the overall structure, the opening focuses on the person's role and experience, but the substance of what's described—monitoring, investigating, and responding to security events—is really about the function. The experience sentence ties to the person, but if I strip away the Director reference, the core content is about the process itself. This feels like it straddles Management Role and Risk Management Process, though the person-focused framing makes it lean toward the former.

Since there's no named framework, no specific dates or numbers, and "Director of IT" is explicitly listed as generic boilerplate, this lands squarely in Generic Boilerplate territory.


reasoning: The paragraph's most substantive claim is that no cybersecurity incidents occurred during 2024, which functions as a negative materiality/impact assessment — the company is affirming its business was unaffected. The first sentence is generic commitment language mentioning the Board incidentally, not substantive governance disclosure. The specific year '2024' is one IS-list fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Two sentences:
1. "The Company and the Board of Directors are committed to remaining updated on evolving cybersecurity regulations and best practices, as well as the development and amendment of processes to meet these changing demands."
2. "The Company did not experience any cybersecurity incident during 2024."

The first sentence is generic commitment language about staying updated on regulations and best practices. The second sentence is a statement that no incidents occurred during 2024.

Category: The second sentence is a materiality/incident assessment - stating no incidents occurred. But is this Strategy Integration or None/Other? It's not quite a materiality disclaimer ("have not materially affected..."), it's more of a factual statement about no incidents. Let me think...

The statement "did not experience any cybersecurity incident during 2024" is an incident status statement rather than a materiality assessment—it doesn't frame the lack of incidents in terms of material impact, just reports that none occurred. The first sentence's mention of the Board is incidental to its generic commitment language about staying updated on regulations. Neither sentence really fits Strategy Integration or Board Governance categories. The second sentence about no incidents in 2024 is closer to Strategy Integration since it's assessing business impact, even though it lacks the explicit "materially affected" language from the codebook examples. The first sentence remains generic commitment language, making this overall borderline between Strategy Integration and None/Other.

For specificity, "during 2024" is a concrete date reference that qualifies as Firm-Specific, but I don't have a second hard verifiable fact to reach Quantified Verification.

fact: during 2024


reasoning: The paragraph describes the company's own internal cybersecurity safeguards, training, exercises, audits, and a third-party program for supply chain resilience — all internal process descriptions. The third-party program is a component of internal risk management, not central vendor oversight. No named frameworks, specific roles, tools, firms, dates, or other facts from the IS list are present; all elements (employee training, incident response exercises, cybersecurity insurance, business continuity, unnamed experts) are generic practices applicable to any company.

thinking:
Let me analyze this paragraph.

Content: Describes technical/organizational safeguards, employee training, incident response exercises, cybersecurity insurance, business continuity, audits by internal/external experts, and a third-party cybersecurity program for supply chain resilience.

Category: This is primarily about the company's internal processes - safeguards, training, exercises, insurance, audits. The third-party program mentioned is a component of their overall risk management, not the central topic of vendor oversight. → Risk Management Process

The mention of cybersecurity insurance is brief, not the dominant topic. The third-party program is about strengthening their own supply chain resilience, which is closer to Risk Management Process (internal processes mentioning vendors as one component).

Looking at the specifics, there are no named frameworks, cybersecurity titles, or identified firms and tools—just generic references to employee training, incident response exercises, and business continuity practices. This reads as boilerplate language without concrete details or named standards.


content_category: None/Other

reasoning: The paragraph is primarily generic risk language acknowledging reliance on information systems and the threat landscape, followed by a cross-reference to Item 1A Risk Factors. The trailing sentence fragment ('Implementing an Information Security Program...') appears to be an extraction artifact from a bullet list and is entirely generic. No substantive cybersecurity disclosure — no processes described, no governance structure, no materiality assessment — just general risk acknowledgment and a cross-reference.

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

The paragraph discusses general cybersecurity risks - reliance on information systems, risk of compromise, being a high-value target as a financial services provider. It includes a cross-reference to Risk Factors and ends with a fragment about an Information Security Program.

Content: This is mostly generic risk language about cybersecurity threats. It mentions reliance on third-party systems (online banking, mobile banking providers), but the core content is general risk acknowledgment. The cross-reference to Risk Factors and the trailing fragment about an "Information Security Program" don't constitute substantive disclosure.

The bulk of this is generic risk language with a cross-reference, though there's a trailing mention of implementing an Information Security Program that hints at risk management processes, albeit in very vague terms. This puts it on the borderline between generic risk disclosure and actual risk management process description. I'm going back and forth on this classification. The paragraph is mostly generic risk acknowledgment with a cross-reference, but there's that fragment about implementing an information security program that suggests some process disclosure. The question is whether that fragment is substantial enough to warrant Risk Management Process, or if the dominant purpose—which is really just acknowledging risks and pointing elsewhere—makes this None/Other. I think the generic nature and the fragmentary quality of the program mention push this toward None/Other at Specificity 1, since there's no real substantive detail about processes or governance.


reasoning: The paragraph enumerates elements of the company's cybersecurity risk management program—risk assessments, a security team, external service providers, training, incident response plan, and third-party risk management—all describing internal processes. No named frameworks, no cybersecurity-specific role titles (just 'a security team'), no named tools, firms, dates, or quantified facts appear; every element is a generic practice that could appear in any company's filing.

thinking:
Let me analyze this paragraph from Expensify's 10-K Item 1C filing.

This is a bulleted list describing elements of their cybersecurity risk management program: risk assessments, security team, external service providers, training, incident response plan, third-party risk management.

Content Category: Risk Management Process - describes the company's internal cybersecurity processes and program elements.

Specificity: Let me check for specific facts:
- "risk assessments" - generic practice
- "a security team" - generic, not a named cybersecurity-specific role

- "external service providers" - unnamed
- "cybersecurity awareness training" - generic practice
- "cybersecurity incident response plan" - generic program name
- "third-party risk management process" - generic program name

No named frameworks, no named roles (CISO, CIO, etc.), no named tools, no dates, no numbers. Everything here is generic.

→ Generic Boilerplate (1)


reasoning: The paragraph spans Risk Management Process (risk assessments, audits, vulnerability identification, role delineation) and Board Governance (Board oversight, Director of IT reporting to Board). RMP is the dominant category as more sentences describe internal risk assessment processes, with board oversight presented as one component. 'Director of Information Technology' is a generic IT title (on the NOT list), 'the Board' is generic governance, and cadences like 'annual' and 'as needed' are generic — no specific facts remain after validation, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessments by management including Director of IT, annual audits, Board oversight, Director of IT reporting to Board, and role delineation for cybersecurity tasks.

Category analysis:
- Risk assessments, audits, vulnerability identification → Risk Management Process
- Board oversight, Director of IT reports to Board → Board Governance
- Director of IT mentioned → could be Management Role

The paragraph covers multiple topics. Let me assess dominant category:
- "Regular risk assessments... audits to identify vulnerabilities" → RMP

- "annual financial and risk assessment audits" → RMP
- "The Board has responsibility for oversight" → Board Governance
- "Director of Information Technology reports to the Board as needed" → Board Governance (board is receiving reports)
- "Clear delineation of roles and responsibilities" → RMP

The content is split between risk management processes and board governance, but the emphasis leans toward risk assessments, audits, and role clarity. The Board's oversight function is present but secondary to the operational risk management activities being described. I'm counting the sentences to determine which theme dominates—risk management processes or board governance. It's fairly balanced, but the paragraph opens with risk assessments and frames board oversight as part of the company's overall risk management approach rather than the other way around, so Risk Management Process edges out as the primary focus.

Now I'm checking whether the specific roles and titles mentioned actually qualify as cybersecurity-specific. "Director of Information Technology" is too generic—the NOT list explicitly excludes general IT leadership titles like that. "The Board" is also generic, and terms like "annual" and "as needed" are just standard cadences without specificity. There are no named frameworks, dates, firms, or concrete numbers here, so this filters down to generic boilerplate with no substantive facts remaining.


reasoning: The paragraph opens with an explicit materiality assessment ('not experienced a cybersecurity incident that resulted in a material adverse impact to our business or operations'), which triggers Strategy Integration per Rule 6. The remainder is generic hypothetical risk language about potential future breaches. No named frameworks, roles, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: First sentence is a materiality assessment ("not experienced a cybersecurity incident that resulted in a material adverse impact"). Second part is hypothetical risk language about what could happen if breached.

Category: The first clause makes a materiality assessment → Strategy Integration per Rule 6. The rest is generic risk language. The materiality assessment is the substantive content.

Specificity: No named frameworks, no specific facts from the IS list, no dates, no numbers. Pure boilerplate language. → Generic Boilerplate.


reasoning: The paragraph describes IHM's cybersecurity program that Chatham Lodging Trust relies on — risk management processes, controls, monitoring, and NIST CSF alignment. While IHM is a third party, the paragraph describes the program's processes rather than imposing vendor oversight requirements, making this Risk Management Process. IHM is a named firm (Firm-Specific), and NIST CSF is named, but only one QV-eligible fact (IHM) prevents Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Chatham Lodging Trust's 10-K filing.

Content: Describes cybersecurity strategy and program implemented by IHM (their property manager). Covers risk management processes, framework alignment (NIST CSF), controls, monitoring.

Category: This is about the company's cybersecurity processes - risk assessment, framework adoption, monitoring, controls. The fact that it's managed by IHM (a third party) is interesting, but the paragraph describes the program itself, not vendor oversight requirements imposed on IHM. → Risk Management Process

Specificity: NIST CSF is a named framework, which qualifies as Sector-Adapted, but frameworks don't count toward QV. IHM is a named third-party firm managing all the company's properties, which is a specific verifiable fact. That gives me only one QV-eligible item, so this falls short of the two hard facts needed for Firm-Specific.

fact: NIST Cybersecurity Framework alignment

fact: IHM (named property manager implementing cybersecurity program)


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration even when boilerplate. No named frameworks, firm-specific facts, or verifiable details are present — the language is standard across thousands of filings.

thinking: Materiality assessment paragraph.


reasoning: The paragraph makes an explicit materiality assessment ('materially affect... our operations'), which per Rule 6 classifies as Strategy Integration even when boilerplate. No named frameworks, roles, dates, or other specific facts are present, so specificity is Generic Boilerplate.

thinking:
Classify this paragraph.

Content: "We are not aware of any existent weakness in our systems or malware embedded in our systems that would materially affect, or are reasonably likely to materially affect, our operations."

This is a materiality assessment - explicitly assessing whether cybersecurity issues have materially affected the company. Per Rule 6 and the codebook, materiality disclaimers → Strategy Integration.

Specificity: No named frameworks, no specific facts from the IS list. Generic boilerplate materiality language.


reasoning: The paragraph's central topic is identifying and overseeing cybersecurity risks from third parties (vendors, service providers, external users), making Third-Party Risk the dominant category. It contains no named frameworks, no firm-specific facts from the IS list, and uses entirely generic language applicable to any company.

thinking:
Classify this paragraph.

Content: About third-party risk oversight - vendors, service providers, external users. Central topic is oversight of external parties' cybersecurity.

Category: Third-Party Risk - the central topic is oversight of third parties.

Specificity: No named frameworks, no specific facts from the IS list. Generic language throughout. → Generic Boilerplate.


reasoning: The paragraph leads with the VP of IT as the primary subject, devotes significant text to their qualifications (20+ years experience, degrees), and describes their team — making the person the dominant focus over the process descriptions. Applying the person-vs-function test: while framework assessments and team activities are mentioned, the paragraph's primary communicative purpose is identifying who leads cybersecurity and why they are qualified. Specificity is Firm-Specific: 'VP of IT' is a cybersecurity-adjacent title on the IS list and 'over 20 years' is a specific duration, but only one QV-eligible hard fact (the years of experience) since the degrees lack named universities and frameworks don't count toward QV.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes the VP of IT's role, qualifications, and what the team does. Let me apply the person-vs-function test.

The first sentence describes what the VP of IT does (operational oversight, works across departments). The second sentence is about the person's background (20 years experience, degrees). The third sentence describes the team. The fourth sentence describes processes (framework assessments).

The paragraph has substantial content about both the person and the function. The VP of IT's qualifications (20 years, degrees) take up significant space, but there's also process description (team of engineers, framework assessments).

Looking at the balance more carefully, the paragraph opens with and centers on the VP of IT as the leader—their role, experience, and education get prominent placement. That's two full sentences focused on the person versus one on the team and one on processes. The dominant focus is clearly on the Management Role itself.

Now checking the specificity: "Vice President, Information Technology and Facilities" is a precise title, but it's essentially a general IT leadership position, not cybersecurity-specific. According to the guidelines, that doesn't meet the threshold for inclusion. I'm checking the frameworks—ISO 27001 and the others are sector-adapted, not QV-eligible. The degrees lack named universities, and there's no mention of specific firms, dollar amounts, or dates. So I'm left with just one QV-eligible fact: the "over 20 years" duration. That's not enough to reach QV level, which requires two facts, so this stays at Firm-Specific.

fact: Vice President, Information Technology and Facilities (VP of IT)

fact: over 20 years in information technology

fact: NIST Cybersecurity Framework

fact: CIS Controls


reasoning: The paragraph's primary communicative purpose is describing the company's cybersecurity oversight structure, with the full board retaining oversight responsibility (not delegating to any committee) and CEO/Interim CFO reporting incidents to the board. While the opening sentence notes the absence of a formal program and the final sentence provides a materiality assessment (Strategy Integration), the dominant content (two of four sentences) frames the board as the ultimate oversight authority with management reporting to it. CEO and Interim CFO are generic C-suite titles (NOT list), so only 'fiscal year 2023' qualifies as a specific fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The company explicitly states it has no formal cybersecurity risk management program or formal processes. This is similar to the SPAC/no-operations case but not exactly - Jones Soda is an operating company, just a small one without a formal program.

Let me re-read the SPAC rule: "SPACs and shell companies explicitly stating they have no operations, no cybersecurity program, or no formal processes receive None/Other regardless of incidental mentions of board oversight or risk acknowledgment."

But Jones Soda is not a SPAC or shell company - it's an operating company.

The SPAC rule specifically targets companies with "no business operations," so Jones Soda's lack of a formal program doesn't automatically trigger that classification. Now I'm breaking down the different elements in this disclosure: the explicit acknowledgment of no formal program, the CEO and CFO's incident response role, the board's oversight responsibility, their incident reporting process, and the materiality assessment they conducted. The dominant theme appears to be describing the absence of formal structures alongside some basic governance elements.

Looking at this more carefully, the paragraph opens with the absence of a formal program, then describes ad hoc responsibilities and reporting flows, with a materiality statement tacked on at the end. Since this is an operating company making disclosures rather than a SPAC, I need to focus on what the paragraph is actually communicating: it's describing their minimal governance structure for cybersecurity, with the CEO and Interim CFO as the primary actors and the board providing oversight. The materiality assessment is secondary—just one sentence wrapping things up. The management structure shows the CEO and Interim CFO handling incidents and reporting to the board, which retains oversight rather than delegating responsibility. But these are generic C-suite roles, not cybersecurity-specific positions. Looking back at the company's own statement—"We do not consider that we face significant cybersecurity risk and have not adopted any formal processes"—this seems to be the key qualifier for categorizing them as None/Other, especially since Jones Soda is neither a SPAC nor a shell company.

The paragraph itself contains four distinct elements: the absence of a formal program, the governance structure with CEO/CFO handling incidents, their reporting relationship to the board, and a materiality assessment at the end. That materiality statement about not identifying material threats in fiscal 2023 could suggest Strategy Integration under Rule 6, but it's only one sentence among four, so the dominant content appears to be the lack of formal processes rather than an articulated strategy.

Looking at the core communicative purpose: the company is essentially saying they have no formal cybersecurity program, but the board maintains oversight through CEO/CFO incident reporting. The board's role as the ultimate authority and their explicit retention of oversight responsibility—rather than delegation—seems to be the organizing principle here. That points toward Board Governance as the primary category, since the paragraph's main point is describing who holds responsibility and how oversight flows through the board.

For specificity, "fiscal year 2023" is a concrete date that qualifies as Firm-Specific. The references to CEO, CFO, and the board are generic titles without names or unique identifiers, so those don't add specificity. The Interim CFO designation is just a temporary status, not a specific fact about the firm's cybersecurity approach.

Looking back at the category choice—the paragraph is dominated by governance structure and oversight responsibilities, which points to Board Governance. The materiality statement at the end is brief and secondary to the main content about who oversees what. Even though there's a compliance disclaimer, the governance framing is stronger here.

So my final categorization is Board Governance with one Firm-Specific fact: the fiscal year 2023 reference.

fact: fiscal year 2023


reasoning: The board of directors is the grammatical subject receiving cybersecurity presentations from management, making this Board Governance. No firm-specific facts appear: 'board of directors' and 'senior management team' are generic, 'regular basis' is a vague cadence, and the listed topics (threats, vulnerability assessments, network integrity testing) are common practices found on the NOT list. No named frameworks, roles, or specific details.

thinking:
Let me analyze this paragraph.

The board of directors is the grammatical subject receiving presentations. This is about board oversight of cybersecurity risks.

Content category: Board Governance - the board is the subject, receiving presentations on cyber risks.

Specificity: Let me check facts.
- "board of directors" - generic, NOT list
- "senior management team" - generic
- "regular basis" - generic cadence
- Topics listed (cybersecurity threats, vulnerability assessments, network integrity testing, infrastructure updates) - common practices, generic

No named frameworks, no firm-specific facts from the IS list. No cybersecurity-specific titles (just "senior management team").

This is generic boilerplate language with minimal specificity.


reasoning: The paragraph describes the company's ERM-integrated cybersecurity program, framework adoption (FFIEC), collaboration practices, and program review processes. While CISO and CRO roles are mentioned, they serve as attribution for program activities (collaboration with peer banks, program review) rather than describing the persons' credentials or background — the person-vs-function test points to Risk Management Process. The CISO title (cybersecurity-specific role on the IS list) elevates specificity beyond Sector-Adapted to Firm-Specific, but there are not two QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph from Stellar Bancorp's 10-K Item 1C filing.

**Content Category Analysis:**

The paragraph covers multiple topics:
1. ERM program overview (generic)
2. Board oversight mention (brief - "The Board is actively involved")
3. Framework adoption (FFIEC and other standards)
4. CISO and CRO roles, reporting lines, collaboration activities
5. Information security program review
6. General approach to cybersecurity (CIA triad)

The dominant content is about the company's risk management processes - ERM integration, framework adoption, collaboration practices, program review. The Board mention is brief.

Now I'm applying the person-versus-function test: the CISO and CRO are described in terms of what they do—collaboration, program review—rather than their qualifications or background. Removing those titles wouldn't change the substance of what's being described, which is fundamentally about the company's processes and governance structure. This points to Risk Management Process as the category.

For specificity, I'm checking what triggers firm-specific versus sector-adapted classifications. The CISO title is cybersecurity-specific and appears on the IS list, so that's firm-specific. FFIEC is a recognized framework standard that applies across the financial sector, which would be sector-adapted.

Looking at hard verifiable facts—dates, dollar amounts, headcounts, named third parties, products, or certifications—I don't see any that would qualify as QV-eligible. The CISO reference alone makes this firm-specific rather than QV, since it's on the IS list for cybersecurity-specific roles.

fact: Chief Information Security Officer (CISO)

fact: CISO reports directly to the Chief Risk Officer (CRO)

fact: Federal Financial Institutions Examination Council (FFIEC) framework


reasoning: The paragraph primarily describes internal cybersecurity processes — designing safeguards, addressing gaps, and monitoring effectiveness — with the role attribution ('Senior Director, Head of IT and Informatics' reporting to CFO) serving to explain who executes these processes rather than describing the person's qualifications or background. Applying the person-vs-function test, the substantive content is about what the company does, not who the person is. 'Senior Director, Head of IT and Informatics' falls under generic IT leadership per the NOT list (analogous to 'Head of IT' / 'Director of IT'), and CFO is generic C-suite, so no IS-list facts are present, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up activities (re-design, implement, maintain safeguards, monitor effectiveness) and then delegates primary responsibility to "Senior Director, Head of IT and Informatics" who reports to CFO.

Category: This is a mix. The first half describes risk management processes. The second half identifies a specific person/role and their reporting line. The person-vs-function test: the paragraph describes what the company does (safeguards, monitoring) and then names who is responsible. The role attribution is significant here - it names a specific title and reporting line. But the paragraph's primary content is about processes (re-design, implement, maintain, monitor safeguards) with the role as attribution for who manages these processes.

Actually, I'm seeing this as roughly split between process and organizational structure. The opening focuses on what needs to happen—redesigning and maintaining safeguards—while the second part establishes who's accountable and where they sit in the hierarchy. The reporting line to the CFO is definitely structural, but the paragraph's weight leans toward describing the work itself rather than the organizational chart.

Now I'm checking whether "Head of IT and Informatics" fits the cybersecurity-specific role list I'm working with. It's more of a general IT title compared to something like "Director of IT Security" or "CISO," which are explicitly on my reference list. That distinction matters for how I categorize this.

Since the title is generic IT leadership rather than cybersecurity-focused, and there are no specific frameworks or methodologies mentioned, this falls into Generic Boilerplate. The paragraph's main purpose is describing risk management processes with role attribution, but without the specialized credentials or named approaches that would elevate it beyond standard language.