reasoning: The paragraph centers on the Board of Directors providing oversight of the cybersecurity program and discusses update cadence and ERM integration, but it contains no firm-specific names, roles, dates, committee/team names, or other verifiable details beyond generic governance language.


content_category: Risk Management Process

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph describes the company’s internal cybersecurity awareness/learning team and its purpose, which is part of the company’s own cybersecurity program/process rather than a board/incident or third-party oversight.

provider: openai


category_confidence: high

reasoning: The paragraph describes Thermon’s own cybersecurity risk management system (identify, assess, mitigate) and its purpose. It contains no named roles, dates, standards, tools, or other firm-specific details.


reasoning: This paragraph describes a company-owned cybersecurity training and policy-communication practice, but it contains no specific roles, dates, named programs/tools, or frameworks that would make it firm-specific.


content_category: Management Role

reasoning: The paragraph describes how day-to-day cybersecurity is handled and discusses changing/outsourcing that management function. It does not name any specific cybersecurity role (e.g., CISO/CIO) or provide firm-specific programs, dates, or third parties.


content_category: None/Other

reasoning: This is a forward-looking, generic statement of security objectives with no described incident, no named roles/frameworks/systems, and no firm-specific details.


reasoning: The paragraph describes the company’s planned internal cybersecurity risk identification, assessment, and management processes as part of its broader risk management system, without naming incidents, roles, vendors, dates, or firm-specific identifiers.


reasoning: The paragraph describes the company’s internal incident response planning and testing through tabletop exercises, which is an internal risk management process rather than an incident or governance/role statement.


content_category: Strategy Integration

reasoning: The paragraph is a materiality statement about cybersecurity threats’ lack of impact and includes a cross-reference to Risk Factors, without describing any incident or internal risk management process.


reasoning: The paragraph describes the company’s internal IT/cybersecurity program elements (policies, procedures, assessments, monitoring, response plans, and testing) rather than a specific incident, board action, or vendor requirement.


reasoning: This paragraph addresses financial reimbursement via cyber insurance and notes that timing/amount are unknown, without describing the incident itself or any cyber risk management process details.


reasoning: The paragraph only addresses whether an unspecified cybersecurity incident is reasonably likely to materially impact financial condition/results, without describing what occurred. This is materiality/financial impact disclosure rather than incident or process detail.


reasoning: The paragraph describes how cybersecurity risk assessment and management processes are implemented by internal individuals. It focuses on the company’s own processes rather than an incident, board oversight, or third-party vendor requirements, and it contains no cybersecurity-specific named roles from the ✓ list or other firm-unique details.


reasoning: The paragraph describes the company’s own cybersecurity awareness and an internal risk management process (including due diligence and periodic monitoring) related to third-party providers. It does not disclose a specific incident, named roles/committees, dates, tools, vendors, or standards that would make it firm-specific.


reasoning: The paragraph describes the company’s own multi-layered cybersecurity program and states how its management is informed via processes including an incident response plan. It is internal process/disclosure rather than an actual incident, vendor oversight, or board/role identification.


reasoning: The paragraph provides a materiality conclusion about the incident’s financial/business impact but does not describe what the incident was or provide any event-specific details.


content_category: Incident Disclosure

reasoning: The paragraph describes an ongoing disruption to company systems and response activities (restoring operations, retaining experts, coordinating with law enforcement and regulators), indicating an actual incident context, even though it provides no hard incident details or dates.


reasoning: This paragraph does not describe what occurred in the incident; it only discusses potential financial/operational impacts (material disruption, revenue loss, remediation, penalties, litigation) in a generalized manner.


reasoning: The paragraph assigns responsibility for managing cybersecurity risks and related communications to specific management roles (CFO/COO/CEO). It contains no firm-unique facts, dates, tools, or named cyber governance bodies beyond generic C-suite role language.


reasoning: The paragraph is a standalone materiality conclusion about potential financial impact and does not describe any incident facts, systems, or response actions.


reasoning: This paragraph discusses potential financial/material impact and ongoing forensic investigation without providing incident details, system/data scope, dates, or named resources. The focus is on potential materiality/financial impact rather than describing what happened in the incident.


reasoning: The paragraph provides a materiality/financial-impact conclusion about the incident (no material impact on operations and not reasonably likely to materially impact financial conditions or results), without describing what occurred.


category_confidence: low

reasoning: The paragraph references notification actions related to a “matter,” but it provides no incident-specific details (what happened, scope, dates, affected systems/data) and includes only generic regulatory/law-enforcement language.


reasoning: The paragraph discusses a cybersecurity incident by describing the company’s ongoing forensic analysis and uncertainty about findings. It provides no incident-specific facts (dates, affected systems/data, impacts), so it is largely boilerplate.


reasoning: This paragraph provides a materiality/financial-impact conclusion about a cybersecurity incident without describing what happened or any technical/operational scope, which fits Strategy Integration.


reasoning: The paragraph discusses ongoing business/financial impacts and insurance-related costs stemming from a cybersecurity incident, without describing what happened or any specific incident scope/actions.


reasoning: The paragraph provides a forward-looking materiality assessment about an incident’s lack of material impact and likelihood of affecting financial conditions/results, without describing what happened or any incident scope/actions.


reasoning: The paragraph describes a cybersecurity incident outcome (threat actor accessed and exfiltrated limited data containing some personally identifiable information) and the associated notification process to affected parties and regulators.


reasoning: This paragraph is a legal boilerplate statement about waiver scope under credit/lease agreements and contains no cybersecurity-specific governance, processes, roles, incidents, or strategy disclosures.


reasoning: This paragraph is a materiality/financial-impact conclusion about a cybersecurity incident, without describing the incident details or response actions.


reasoning: The paragraph describes response steps tied to an unspecified “matter” and mentions notifications to law enforcement and regulators, but provides no incident-specific facts (what happened, scope, or dates). With no cybersecurity-specific or firm-specific details, it reads as generic incident-response boilerplate.


reasoning: The paragraph provides only a materiality conclusion about the incident’s financial/operational impact and does not describe what happened, affected systems/data, or response actions.


reasoning: The paragraph discusses the lack of material operational disruption and focuses on assessing potential impacts and remediation costs, without providing an incident narrative, affected systems/data scope, or specific incident facts.


reasoning: The paragraph centers on named management leadership changes (interim CEO assignment) at the Korean subsidiary, including a specific date and named role holder.


reasoning: This paragraph is limited to a materiality/financial impact conclusion about the incident, with no description of what happened, affected systems/data, or response actions.


reasoning: The paragraph discusses cybersecurity insurance coverage and costs (incident response, forensic investigations, business interruption, regulatory fines) and notes that updated guidance will follow, without describing any actual cybersecurity incident.


reasoning: The paragraph discusses reimbursement of incident-related costs through insurance recoveries, without describing the incident itself or any insurer-specific or cost-amount details.


reasoning: The paragraph describes a real cybersecurity incident timeline, including notification and confirmation dates, and states that customer information was exposed.


reasoning: The paragraph describes an ongoing disruption impacting accessibility of networks/transactional services and directs readers to an incident update site, but provides no concrete scope, timeline, affected data/systems details, or other hard specifics.


reasoning: The paragraph describes actions taken in response to an identified incident (closing off the point of unlawful access) and states customer notice to impacted customers, which are elements of incident response and affected-party scope.


reasoning: The paragraph only addresses expected financial/material impact and ongoing assessment, without describing the incident’s technical details, affected systems/data, or response actions.


reasoning: The paragraph does not describe the incident; it only discusses materiality/financial impact and operational impact in general terms, which fits strategy/financial impact integration rather than incident disclosure.


specificity_confidence: low

reasoning: The paragraph describes the status of an ongoing cybersecurity incident investigation and references assessment of the scope of personal information in exfiltrated data and planned required notifications, which are incident-related actions and scope elements.


reasoning: The paragraph discusses an ongoing cybersecurity investigation, including that the scope of potentially affected data is not yet determined and that remediation and potential claims are being supported, which aligns with incident disclosure even though specific incident details are not provided.


reasoning: The paragraph describes an ongoing investigation to determine whether PII was taken by threat actors and sets expectations for timing of the determination, which is substantive incident-related disclosure.


reasoning: This paragraph describes general operational disruptions (including online ordering) without any cybersecurity incident details, processes, roles, or third-party/vendor security oversight.


reasoning: This paragraph is solely a materiality/financial impact statement about an incident without describing what happened or any incident scope, dates, systems, or response actions.


reasoning: The paragraph includes a statement that the company maintains a cybersecurity risk management program to identify, assess, manage, mitigate, and respond to threats, which is an internal process. It also mentions leadership reporting lines, but the process description is the core disclosure.


reasoning: The paragraph does not describe what happened or any incident scope/response details; it only references ongoing monitoring of the incident’s timing and materiality, which is financial/materiality framing.


reasoning: The paragraph describes the status and outcome of a cyber incident (restoration of affected systems/data, authorities closing the investigation) rather than outlining internal risk processes or financial impacts.


reasoning: The paragraph discusses assessing potential financial/material impact of a cybersecurity incident, and states the impact cannot yet be determined, without describing what happened or any incident scope/actions.


reasoning: The paragraph describes an ongoing cybersecurity incident with concrete actions (unauthorized access, data exfiltration, and encryption of data on non-production systems), which is characteristic of incident narrative disclosure.


reasoning: The paragraph describes the status of an actual cybersecurity incident (contained it and restored the core IT environment) and ongoing restoration of business operations, which fits incident disclosure. However, it provides no firm-unique or verifiable details.


specificity_confidence: medium

reasoning: The paragraph describes an actual cybersecurity incident and its operational impact (system outage) and the response actions taken (activating an incident response team). It also includes a specific incident date, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company’s handling of an ongoing cybersecurity incident (contained it, restoring access, resuming normal operations), which is incident-response disclosure. It provides no verifiable dates, scope, systems, or other firm-specific details.


reasoning: This paragraph describes an actual cybersecurity incident’s operational impact (shipping/receiving, manufacturing processes, back office functions) and restoration efforts, which is incident disclosure even though it lacks incident-specific dates or named systems.


reasoning: This paragraph is a general notice to readers about website accessibility and where to find communications. It does not describe the incident details, impacts, or cybersecurity processes beyond a communications link.


reasoning: The paragraph primarily provides a materiality conclusion about whether the incident is reasonably likely to impact financial condition/results, with no incident scope/details. References to investigating/experts and law enforcement are generic and not firm-unique facts.


reasoning: The paragraph describes a real event (systems outage) tied to a cybersecurity attack and states the company’s response (activation of an incident response team), including the specific date of the incident.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized third party access) and provides a specific date of when the company became aware.


reasoning: The paragraph discusses the believed impacts of a cyber incident in terms of cost categories (website rebuilding, hosting, and security protocol enhancements) without providing a narrative of what happened, affected systems/data, or response actions.


reasoning: The paragraph provides only a materiality/financial impact conclusion about an incident, without describing what occurred, affected systems, or response actions.


reasoning: The paragraph describes a cybersecurity incident outcome (a fourth-party/vendor-of-a-vendor compromise) and that the Bank activated its response process, indicating actual incident narrative rather than a general risk framework or materiality discussion.


reasoning: The paragraph describes a real cybersecurity incident and its impact (threat actor access to an IT portion containing sensitive personal information) and states notification and regulatory agency actions. It does not provide any firm-specific identifiers, dates, tools, or named parties, so it is not more than generic incident disclosure boilerplate.


reasoning: The paragraph discusses ongoing assessment of material impact to financial condition/results of operations and states the impact cannot be determined, without describing any incident facts or response actions.


reasoning: The paragraph only discusses expected material impact on financial results (fourth quarter of 2023) and states no material impact on overall financial condition or ongoing operations. It provides no description of what occurred in the cybersecurity incident.


reasoning: The paragraph discusses materiality/financial impact of an incident but does not describe what happened, nor any incident scope or response details; it is therefore financial/materiality-focused integration language.


reasoning: The paragraph describes a concrete post-investigation response action (mailing notification letters) tied to personal information potentially involved, indicating incident-related remediation. It lacks firm-unique or verifiable specifics (dates, systems, amounts, names), so specificity remains generic.


reasoning: The paragraph is general, risk-factor style boilerplate describing potential cyber threats and impacts, with no named roles, programs, frameworks, dates, systems, tools, incidents, or other firm-specific cybersecurity facts.


reasoning: The paragraph describes temporary operational measures to continue business during system restoration, which is part of internal business continuity/response operations rather than a disclosed incident narrative with scope or impacts. It contains no incident-specific details, dates, tools, roles, or other firm-unique facts.


reasoning: The paragraph describes response actions related to an unauthorized access incident (notifying regulatory authorities and working with law enforcement), even though it provides no incident details or hard verifiable specifics.


reasoning: The paragraph describes the company’s own cybersecurity processes (threat assessment, layered security, training, standards/tooling, third-party penetration testing, and pre-hosting assessments) rather than an incident or board-identified oversight as the main subject.


reasoning: This paragraph is a cross-reference to an attached press release and amendment, without providing substantive cybersecurity incident details, processes, or outcomes.


reasoning: The paragraph describes a real cybersecurity event (unauthorized activity) with a specific notification date and states the company began investigation, containment, and remediation actions.


reasoning: The paragraph describes S&T BANCORP’s internal incident criticality assessment, escalation, and incident response/business continuity program processes. Although it references third-party vendor-managed systems, the central focus is S&T’s own risk/response processes rather than vendor oversight.


reasoning: The paragraph describes a specific real-world event, including a concrete detection date and the nature of the attempted fraud (attempting to obtain funds), which makes it incident disclosure rather than general risk management.


reasoning: The paragraph is primarily general risk-factor boilerplate about being targeted and potential impacts. It references vendors and unauthorized access scenarios but does not describe Oracle’s internal cybersecurity processes or any firm-specific framework/role/date, so no specific facts qualify.


content_category: Board Governance

reasoning: The paragraph is centered on the Board and specifically the Risk Committee’s oversight responsibilities for cybersecurity risk within the ERM program, including reporting to the Board. It includes named committee details rather than management role or incident/process specifics as the primary focus.


reasoning: The paragraph describes the effects of an actual cybersecurity incident, including operational impact and a specific duration (~six weeks), which is characteristic of incident disclosure.


reasoning: The paragraph describes BEL FUSE’s own cybersecurity processes (staffing, monitoring, penetration testing, and access controls) and how it evaluates risks tied to third-party providers as part of its internal risk management.


reasoning: The paragraph describes Wendy’s internal cybersecurity risk management strategy (assessments, infrastructure, dedicated teams, and training), which fits the Risk Management Process category. It also cites a specific board committee (Technology Committee), an internal audit team review, and a defined strategy basis (CIS Controls framework), making it company-specific rather than generic.


reasoning: The paragraph describes the Company’s own cybersecurity program components (governance support, technical safeguards, incident response and recovery planning, and third-party risk management as part of the program), which fits Risk Management Process rather than incident disclosure or third-party risk as a standalone topic.


reasoning: The paragraph describes the company’s own cybersecurity risk mitigation activities (controls, monitoring, resiliency, and continuous improvement) and how they are integrated into its risk management processes, even though third parties are mentioned as part of internal oversight.


reasoning: The paragraph discusses general cybersecurity risk management and references regulatory requirements, but it does not describe any firm-specific processes, roles, or incidents with verifiable details. The content is largely boilerplate about threats, compliance, and uncertainty.


reasoning: The paragraph describes general cybersecurity and technology risk factors and impacts to business operations, but it does not describe SMHI’s internal risk-management activities, specific roles/programs, or any disclosed incident or named frameworks/controls.


reasoning: The paragraph is general risk-factor language describing potential cyber threats and potential business impacts, without describing an actual incident, internal processes, specific roles, named programs, frameworks, dates, or verifiable firm-specific details.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (policies, responsibilities, risk assessment/mitigation, and escalation). It also identifies specific roles (CISO/CTO) in those processes and includes multiple firm-unique facts and verifiable details (e.g., OWASP Security Shepherd, IBM and Axway, and years of experience).


reasoning: The paragraph describes the company’s own cybersecurity risk framework adoption (NIST) and internal processes/measures (monitoring team, controls, testing, risk assessments) rather than an incident or a primarily vendor-focused oversight requirement.


reasoning: The paragraph describes the company’s internal cybersecurity risk management strategy and program components (identification/escalation, technical safeguards, incident response/recovery planning, and education), so it fits Risk Management Process. While it mentions third parties, the central topic is the company’s own program rather than vendor oversight requirements as the primary focus, and no hard firm-unique identifiers, dates, tools, or named standards are provided.


reasoning: The paragraph is primarily about the Chief Information Officer’s responsibilities, qualifications (including CISSP/CISA), and his review/oversight cadence for cybersecurity risk and incidents. While it references board/audit committee oversight, management’s role and processes centered on the CIO are the dominant subject.


reasoning: The paragraph is forward-looking and largely describes general cybersecurity risk without describing an actual incident or company-specific process details. It also includes a cross-reference to a risk factor, which is non-substantive beyond directing the reader to another section.


reasoning: The paragraph describes the Company’s internal cybersecurity processes (threat identification/mitigation, technical safeguards, incident response/recovery plans, and education) and includes third-party risk management as part of internal risk oversight. It contains no cybersecurity-specific named roles, committees, dates, programs with unique identifiers, or named tools/firms.


reasoning: The paragraph primarily describes the company’s internal Cybersecurity Program and how it is administered and used to assess and manage cyber risks (including its incident response plan), i.e., a risk management process. While it also names oversight roles and a steering committee, the focus is still on the organization and operation of the cybersecurity program itself.


reasoning: The paragraph describes the company’s internal incident response and cybersecurity processes (Agility Plan, incident escalation, CMT coordination, training, and assurance activities), not an actual incident or vendor-focused oversight. It is therefore best categorized as a risk management process.


reasoning: The paragraph describes the company’s own risk identification, mitigation, monitoring, and planning activities (risk assessment, protective measures, incident/disaster recovery planning). It specifically references the NIST Cybersecurity Framework, but contains no clear firm-unique cybersecurity roles, named programs, tools, or third-party firms.


reasoning: This paragraph details the company’s internal cybersecurity program within its ERM approach (governance, cross-functional process, technical safeguards, incident response/recovery, and third-party risk management). While it mentions board oversight, the grammatical subject and substance center on the company’s cybersecurity processes rather than a discrete incident or board-specific actions.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (monitoring, assessments, policies, training, and incident-related supplier processes). Vendor/supplier security is discussed as part of the company’s own processes rather than as a standalone third-party oversight program, and there are no named roles, frameworks, dates, or tools to make it firm-specific.


reasoning: The paragraph describes Bowman Consulting’s internal cybersecurity monitoring and processes (including its named Cybersecurity Incident Response Plan) and how responses are handled, rather than focusing centrally on incident disclosure or vendor/security-service governance.


reasoning: The paragraph primarily describes the company’s own cybersecurity program design, monitoring, incident/threat management processes, third-party risk process, and escalation/oversight mechanisms. Although it mentions Board/Audit Committee oversight, the dominant focus is internal cybersecurity risk management processes rather than incident disclosure or pure board governance.


reasoning: The paragraph primarily describes how cybersecurity is integrated into the company’s risk management framework, with board/Audit Committee oversight mentioned as part of that governance. However, most governance elements are generic and there are no firm-unique or verifiable details beyond the high-level integration statement.


reasoning: The paragraph is entirely forward-looking and describes general cybersecurity risk and mitigation concepts without any incident narrative, specific processes, named roles/frameworks, or company-specific details.


reasoning: The paragraph centers on who in management oversees and executes cybersecurity (named executives, the designated CISO, and the operational cybersecurity team and coverage), making it primarily a management-role disclosure rather than an incident or a process framework.


reasoning: The paragraph describes Riot’s own internal cybersecurity monitoring and response controls (EDR, SIEM, quarantine/removal, Zero Trust, encryption, backup/recovery, training) and related employee notification procedures. It is not centered on governance, board oversight, a disclosed incident, or third-party/vendor contractual oversight.


content_category: Third-Party Risk

reasoning: The paragraph is centered on the company’s outsourced third-party IT/cybersecurity firm taking primary responsibility for overseeing and managing cybersecurity processes and controls, with the vCISO and other team roles described. It is therefore best classified as third-party risk governance/oversight.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and risk management program (technology and processes) and how it evaluates material risks, rather than an incident or board/role-specific governance.


reasoning: The paragraph centers on the Chief Technology Officer’s role and qualifications (experience and specific security certification) and describes the internal Security and Privacy Governance Committee and the Cybersecurity Incident Response Plan, making management/role the primary subject.


reasoning: The paragraph describes ERII’s internal risk management activities for cybersecurity, including monitoring, recurring exercises/assessments, and recurring reporting/briefings tied to those processes. It is not primarily about a specific incident or third-party governance requirement; it focuses on how the company manages cybersecurity risk internally.


reasoning: Although the paragraph begins with board oversight, the main substance describes Schwab’s own cybersecurity and ERM-integrated information security practices (monitoring, controls/policies, training, and engaging external cybersecurity firms). The only firm-specific extractable detail is the named board Risk Committee.


reasoning: The paragraph describes the company’s internal cybersecurity policies and operating processes (monitoring, detection, encryption, access controls, vulnerability scanning, IR/DR practices). It does not describe a specific incident and includes no firm-unique named programs, roles, dates, tools, or third-party firm/product names.


reasoning: The paragraph describes USCF’s internal information security program and its cybersecurity risk evaluation and third-party due diligence as mitigation measures. However, it does not include any qualifying firm-unique cybersecurity program identifiers, roles, named tools/firms, dates, or quantified metrics from the ✓ IS list.


reasoning: The paragraph describes Cohen & Steers’ internal technical and organizational safeguards (monitoring, encryption, incident response plans, risk assessments, training, vulnerability management, and business continuity) to manage cybersecurity risk. It does not describe a specific incident or include verifiable, company-unique facts such as named tools/roles, dates, or third-party firms.


reasoning: The paragraph describes the company’s comprehensive approach and internal policies/processes for assessing and managing cybersecurity risks, plus ERM-style integration. It does not describe a specific incident, name a cybersecurity role, or provide firm-unique operational details beyond generic risk-management and forward-looking language.


reasoning: The paragraph centers on named cybersecurity and compliance leadership roles (CISO, Information Security Team, CCO) and describes their responsibilities and qualifications, making it primarily a management-role description rather than an incident or process disclosure.


reasoning: The paragraph describes LEE’s internal cybersecurity risk assessment and monitoring/response processes (roles, monitoring via a 24/7 SOC, and reporting into board materials), which centers on the company’s risk management approach rather than a standalone incident.


reasoning: The paragraph defines cybersecurity concepts and states that the company has implemented processes to identify, assess, and manage material cybersecurity risks impacting business and financial outcomes. It does not describe an actual incident or name specific roles, frameworks, or programs unique to the firm.


reasoning: The paragraph discusses the company’s use of its IRP (incident response plan) to respond to incidents and describes threats (directed attacks, misuse/unauthorized disclosure) in a general way without detailing a specific realized incident. It also frames impacts as “not had a material impact to date” in a forward-looking risk-disclaimer manner rather than providing an incident narrative with specific scope/timing.


reasoning: The paragraph is focused on Northern Trust’s internal cybersecurity/technology risk management program, including governance, policy/framework foundations, and how it operates within enterprise risk management, with only secondary mention of third-party control reviews as part of the internal program.


reasoning: The paragraph’s primary grammatical focus is board and committee oversight of cybersecurity risk management (board delegation to the Audit Committee and ongoing reporting to it). It also names the specific committee and a quarterly reporting mechanism, making it firm-specific rather than generic.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment/monitoring, incident management and remediation processes, and integration into overall risk management. References to third-party service providers are incidental steps within the internal process, not the central focus.


reasoning: The paragraph describes Embecta’s internal cybersecurity monitoring and risk management activities (SOC monitoring, defense-in-depth, control assessment, vendor risk management as part of its program) and a policy review process, rather than reporting a specific incident.


reasoning: The paragraph describes MEG’s own incident response plan (IRP) and how it is executed (including roles and processes) aligned to NIST RMF, making it an internal risk management process rather than a disclosed incident or purely third-party oversight.


reasoning: The paragraph describes the company’s own cybersecurity program activities (policies/procedures, controls, monitoring, and use of tools) and how it manages cybersecurity risk, with third-party risk management included as one component rather than the central focus.


reasoning: The paragraph is centered on the duties and qualifications of specific management individuals (President/CEO and General Counsel) for cybersecurity risk management and incident reporting, making it a Management Role disclosure.


reasoning: The paragraph describes the company’s own incident response plan, escalation/notification workflow, and testing activities (annual IR plan testing and tabletop exercises). It does not disclose an actual incident or name specific cybersecurity roles, committees, frameworks, products, or unique firm-specific identifiers.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (policies/standards/processes/resources and assessing managing risks). It does not disclose a specific incident or provide firm-unique cybersecurity governance details.


reasoning: This paragraph describes the company’s own cybersecurity program, controls, monitoring (SOC), employee reporting mechanisms, and ongoing program review by CIO/CISO—i.e., internal risk management processes rather than an incident or board oversight.


reasoning: The paragraph discusses absence of material incidents, lack of material financial impact, and forward-looking materiality/insurance implications without describing any incident or internal cyber processes. It is therefore focused on strategy/financial impact rather than incident disclosure or risk management procedures.


reasoning: The paragraph describes the company’s internal cyber security processes, including how subsidiaries run security programs, how incidents are classified and reported, and how the enterprise-wide IT team oversees incident response and escalation. Board oversight and an actual incident narrative are not the focus.


reasoning: The paragraph is a forward-looking statements safe-harbor disclaimer and cross-references other sections, with no substantive incident details (no dates, systems, scope, or response outcomes).


reasoning: The paragraph describes WTW’s internal cybersecurity strategy and processes (incident response planning, technical safeguards, education/training, threat intelligence, and internal third-party risk management). The named internal incident response plan (ICSIRP) makes it firm-specific, and the topic is internal risk management rather than a standalone incident or board-level oversight.


reasoning: The paragraph describes the company’s internal cybersecurity risk management measures (policies, vulnerability management, audits, access controls, monitoring, incident response, and business continuity) rather than an incident, board oversight, or a specific vendor requirement. Vendor risk management and a managed SOC are mentioned as components of the overall internal program, not as the central focus.


reasoning: The paragraph describes the company’s internal cybersecurity preparedness and response approach (disaster recovery plan, incident response policies, escalation/coordination via a Crisis Management Team) and related assurance/training activities, which is characteristic of its risk management processes rather than an incident report or board/management-only identification.


reasoning: The paragraph is explicitly about the Board/Audit Committee’s oversight responsibilities, their review activities (including with the CTO), and cyber insurance coverage—i.e., board governance of cybersecurity.


reasoning: The paragraph centers on how the company manages cybersecurity risks arising from its use of third-party service providers (including audits and contractual cybersecurity obligations). It does not include any firm-unique identifiers, dates, named tools, or other verifiable specifics beyond general vendor-management descriptions.


reasoning: The paragraph narrates a specific cybersecurity incident (unauthorized access and exfiltration, potentially sensitive personal information) and describes response actions and operational impact (system shutdowns, internet isolation, disruption, restoration).


reasoning: The paragraph centers on the CIO’s responsibilities and experience governing oversight of the cybersecurity team and related policies, even though it also describes related processes. The presence of a CIO role and quantified experience supports a Management Role classification.


reasoning: The paragraph describes a real cybersecurity incident (detection date, unauthorized access, encryption, investigation/containment/remediation, system shutdowns, law enforcement notice, and impact to business applications). It is therefore incident disclosure rather than general risk process or strategy.


reasoning: The paragraph contains forward-looking and non-substantive statements about lacking cybersecurity policies and intentions to develop a framework, with no board/management/process details, named roles, dates, standards, tools, or incident information.


reasoning: The paragraph narrates a specific cybersecurity incident (defaced website) with dated events, affected asset (wytecintl.com), remedial actions, operational impact (cancelled seminar), and law-enforcement reporting.


reasoning: The paragraph centers on the Board’s Audit Committee oversight responsibilities and the reporting/briefing structure for cybersecurity (CIO/CISO updates) to that committee and the full Board.


reasoning: This paragraph is a forward-looking/boilerplate statement about not identifying material incidents, with a generic reference to potential future threats and third-party vendors plus a cross-reference to Risk Factors. It does not describe any actual incident or any firm-specific process, roles, dates, or named parties.


reasoning: This paragraph is general risk and forward-looking boilerplate describing potential cybersecurity threats and possible impacts, without describing any specific AFG processes, roles, frameworks, incidents, or verifiable firm-specific facts.


reasoning: The paragraph describes oversight/approval by the Board of Directors in the context of cybersecurity risk appetite metrics. However, it does not name any cybersecurity-specific roles, committees, or concrete firm-specific details beyond generic governance language.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment/audit and how results and remediation are reviewed and addressed internally (including quarterly Audit Committee discussion). Although it mentions external firms and an MSSP, the central focus is the company’s risk management process and oversight workflow, not standalone third-party risk contracting requirements.


reasoning: The paragraph describes the company’s own cybersecurity program and enterprise risk management–based processes (assessments, training, threat intelligence monitoring, and incident-impact oversight), not an actual incident or board/management role. It contains no named roles, frameworks/standards, systems/tools, dates, or quantified facts that would make it firm-specific.


reasoning: The paragraph’s grammatical subject is the Board/Audit Committee oversight of the cybersecurity program, describing how cyber responsibility and escalation work between the CISO and the Board.


reasoning: The paragraph describes updates to a disclosed cybersecurity incident, including perpetrator status, access/saved data scope, deletion of affected data, and concrete response actions (customer compensation) tied to specific dates and quantified customer/account figures and voucher amounts.


reasoning: The paragraph describes the company’s internal cybersecurity safeguards, vulnerability assessment/threat intelligence practices, and an incident response plan that is tested annually. It does not discuss a specific incident, named roles, or firm-unique details.


reasoning: The paragraph describes an internal cybersecurity training practice, but it contains no firm-specific identifiers, roles, frameworks, standards, dates, or other verifiable details.


reasoning: The paragraph is centered on the named cybersecurity leadership roles (CISO and VP of Information Security) and describes their qualifications/experience, which fits Management Role rather than risk process or governance.


reasoning: The paragraph centers on who within management is operationally responsible for cybersecurity (IT-led management team and a Software Engineer coordinating with other management roles). Although it mentions activities like vulnerability assessments and monitoring, there are no named cybersecurity-specific roles, internal programs, dates, tools, or firm-unique facts to raise specificity.


reasoning: The paragraph describes the company’s internal procedures and processes to evaluate, manage, and mitigate cybersecurity risks (including prevention/detection/mitigation and integration into ERM). It does not describe an actual incident, name board/management roles, or impose central vendor security requirements.


reasoning: The paragraph describes the company’s cybersecurity strategy in terms of detection/analysis/response and cyber-risk management/resilience, which is an internal process description. It contains no named roles, programs, dates, frameworks, or tools that would make it firm-specific or more concrete than general boilerplate.


reasoning: The paragraph narrates a real cybersecurity event (a threat-actor email and a concluded single data-exfiltration campaign), including access method, response actions, and customer notification, which fits Incident Disclosure.


reasoning: The paragraph describes an internal incident response plan and the actions it mandates (mitigation, remediation, prevention), which is an internal risk management process. It does not disclose an actual incident or provide firm-unique details beyond generic response-plan language.


reasoning: This paragraph is a forward/backward-looking statement about the company’s lack of operations and that it has not adopted cybersecurity risk management processes. It does not describe an incident, identify cybersecurity roles/committees, or provide any firm-specific cybersecurity process details.


reasoning: The paragraph describes the company’s internal process for investigating a cybersecurity threat, determining whether an incident occurred, and taking steps like isolating affected systems. It also mentions engaging outside advisors, but the central focus is the company’s response/assessment process rather than vendor security oversight.


reasoning: The paragraph discusses the absence of processes for assessing and managing cybersecurity risk, which fits the internal risk management process category. However, it contains no firm-specific details, named roles, frameworks, standards, dates, or tools.


reasoning: The paragraph centers on overseeing cybersecurity risks from third-party service providers, including questionnaires and annual third-party risk assessments tied to contractual cybersecurity obligations.


reasoning: The paragraph discusses general security awareness/training practices and mentions cyber insurance, but it provides no incident narrative, no specific framework/roles, and no firm-specific details. The only potentially non-boilerplate element is cyber insurance, which fits strategy/incentive coverage rather than an incident disclosure.


reasoning: The paragraph describes the company’s internal information security/IT involvement in onboarding new products/projects and ensuring third-party vendors meet requirements via PMO and Vendor Management Office routines, which is an internal risk-management/onboarding process rather than an incident or board/management role.


reasoning: The paragraph describes general limitations of security controls and uses a risk-based approach to decide which controls to implement, which is internal risk management process language. It does not provide incident details, named roles/frameworks/tools, or firm-unique specifics.


reasoning: The paragraph centers on a board-level Risk Committee’s responsibilities and reporting regarding cybersecurity oversight, including references to its governance role and an incident response plan.


reasoning: The paragraph centers on the CISO’s oversight responsibilities and the involvement of specific management roles in cybersecurity risk management, making the grammatical focus management (CISO and other named cybersecurity-relevant leaders).


reasoning: The paragraph is centered on the oversight responsibilities of a board committee (Audit Committee) over cybersecurity risk, including receiving updates and ensuring incident communication and mitigation planning. It does not provide firm-unique or verifiable cybersecurity specifics beyond generic governance language.


reasoning: The paragraph describes Ardent Health’s own processes for managing and assessing third-party/vendor cyber risk (including internal cyber-team assessments and a cybersecurity incident response team), not primarily vendor requirements or an actual incident narrative.


reasoning: The paragraph focuses on using third-party service providers to identify, assess, and manage cybersecurity-related material risks, which is vendor oversight rather than internal risk management or an incident narrative.


reasoning: The paragraph describes the Board’s oversight responsibilities and their reviews/discussions with management regarding cybersecurity and breach response. It does not include any firm-specific identifiers (e.g., named committee/roles/programs), dates, frameworks, or other hard verifiable facts.


reasoning: This is a forward-looking/boilerplate disclosure stating the company is not aware of material cyber threats, without describing any incident, processes, or named parties/frameworks.


reasoning: The paragraph describes the company’s internal cybersecurity risk management objectives and improvement inputs, and it explains who reviews and supervises those processes (Technology Leadership Centre under the CTO).


reasoning: The paragraph describes the board of directors’ oversight and reviews of the company’s cybersecurity risk profile with management on a periodic/annual basis. It does not provide any firm-specific details such as named committees, roles (e.g., CISO), dates, or tools/frameworks.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and mitigation activities (risk assessment, monitoring, assessments, and maintaining an information security policy and cyber insurance). It centers on internal processes rather than an incident or third-party oversight, with only CIS/FERPA referenced as specific standards.


reasoning: The paragraph describes general limitations of implementing security controls and a risk-based approach to selecting/prioritizing controls, but it provides no incident narrative or firm-specific details.


reasoning: The paragraph describes internal escalation and coordination steps within cybersecurity incident response and vulnerability management processes, including reporting pathways. It does not include firm-specific details, named cybersecurity roles (per the allowed ✓ list), or verifiable dates/products.


reasoning: This is forward-looking boilerplate describing that cybersecurity risks could affect future operations and cross-referencing another risk factor in Item 1A, without describing any incident, framework, roles, or firm-specific cyber details.


reasoning: The paragraph describes the company’s own internal security measures (multi-layer defense, vulnerability remediation) and its incident response/disaster recovery planning. It does not reference a specific named role, tool, date, framework, or other firm-unique details.


reasoning: The paragraph is centered on named management cybersecurity roles (CIO/CTO/Information Security Officer) and describes their accountability for the bank’s information security program and related responsibilities.


reasoning: The paragraph states there are no known material cybersecurity incidents and discusses general risk of cyber threats impacting business strategy/operations/financial condition, without describing a specific incident. It also includes forward-looking reporting intentions to the board, but provides no firm-specific cyber governance details.


reasoning: The paragraph describes the Audit Committee’s (board committee) cybersecurity oversight responsibilities and its reporting relationship with the CISO, including incident oversight tied to a named incident response plan.


reasoning: The paragraph describes the company’s own cybersecurity program and internal processes (monitoring, access controls, segmentation, patch management, third-party audits) rather than a specific incident or board/management role. It contains no firm-specific named programs, tools, certifications, committees, or dates beyond generic practices.


reasoning: The paragraph describes BlackRock’s internal cybersecurity risk management program (governance structure, safeguards, incident response/recovery planning, and third-party risk management as part of ERM). While it mentions board support committees, the primary topic is the company’s own processes for identifying, preventing, mitigating, and responding to cyber risks.


reasoning: The grammatical subject is the company’s cybersecurity leadership role (“Head of Cybersecurity”) describing its responsibilities and reporting/notification duties. Board and the Audit Committee are mentioned, but the focus is on the management role’s function.


reasoning: The paragraph describes Western Digital’s own ERM risk management process, how cybersecurity incidents are treated as key material risks, and internal mitigation structures/procedures and response plans. It does not describe an actual incident and is focused on the company’s risk management processes rather than incident disclosure or third-party oversight.


reasoning: The paragraph describes the company’s internal cybersecurity program and the roles of specific cybersecurity teams/committees within its overall risk management process, including policy/procedure review and incident response monitoring.


reasoning: The paragraph describes the company’s own cybersecurity monitoring and testing activities (audits, regulatory exams, vulnerability/penetration testing, and patching) and how internal processes are supplemented, which fits a risk management/process description rather than incident disclosure or pure vendor oversight.


reasoning: The paragraph describes AAON’s general cybersecurity activities (testing, measurement against frameworks, and use of external support) but does not specify vendor security oversight as the central topic or include any firm-specific names, dates, tools, or named frameworks.


reasoning: The paragraph’s primary substance is requirements imposed on vendors that will store sensitive Company information (due diligence and contractual encryption/access controls). It also contains a general materiality statement about cyber risk, but the central focus remains third-party security oversight.


reasoning: The paragraph describes the company’s own technical safeguards (firewalls, anti-malware, monitoring agents) intended to protect information systems, which is part of its internal risk management approach. It contains no firm-specific details, dates, or named roles beyond generic security controls.


reasoning: The paragraph describes using third-party service providers to evaluate the effectiveness of the company’s cybersecurity program and mentions tabletop exercises. However, all details are generic (no named providers, dates, roles, or tools), so it has no firm-specific specificity.


reasoning: The paragraph centers on the named cybersecurity management roles (SVP/IT Manager and ISO) and describes their qualifications and experience, which is management-role disclosure rather than process or incident information.


reasoning: The paragraph provides a generic statement of no known material cyberattacks and includes forward-looking, non-specific disclaimer language with a cross-reference to Risk Factors, without describing any incident details, roles, committees, frameworks, or firm-specific facts.


reasoning: The paragraph describes the company’s internal security control activities (testing and evaluation) and how it reviews vendors’ SOC reports as part of its controls, rather than focusing primarily on vendor oversight as the central topic.


reasoning: The paragraph discusses due diligence and contract provisions during third-party procurement, which is central to third-party security oversight, but it contains no company-specific details, named benchmarks/frameworks, or verifiable facts.


reasoning: The paragraph describes roles participating in the company’s cybersecurity risk management program, which is primarily an internal risk management/process description. It also includes specific governance and management roles, but the core topic is the cybersecurity risk management program itself.


reasoning: The paragraph is centered on the role and reporting lines of the CIO and what the CIO establishes for the information security program, which is management-level governance of cybersecurity.


reasoning: The paragraph describes the company’s own processes and controls for assessing and managing cyber risk, including mitigation/prevention/detection activities and vulnerability/security incident handling, with only generic references to a third-party security program.


reasoning: This paragraph centers on named cybersecurity and oversight roles (CCO and CISO) and describes their responsibilities and qualifications/reporting support for managing cybersecurity material risks.


reasoning: The paragraph centers on oversight and reporting to the Audit Committee and senior leadership (board/committee involvement is the key subject). It also specifies a cybersecurity briefing cadence and a named senior IT role, making it firm-specific beyond generic language.


reasoning: The paragraph describes the company’s own cybersecurity risk management activities (policies, monitoring, risk assessments, training, and mitigation) rather than a specific incident or board/management role. It contains no firm-specific identifiers, dates, named tools/standards, or verifiable third-party entities beyond generic references.


reasoning: The paragraph focuses on dependence on third-party service providers and the cyber-attack risk posed by those providers, including monitoring of provider-related cyber risk. It does not describe an incident or internal governance/roles beyond generic statements.


reasoning: The paragraph describes Teladoc Health’s own cybersecurity program and how it uses policies/controls and external/internal assessments, including the frameworks it applies to manage cybersecurity risks.


reasoning: The paragraph centers on a named governance body (Cybersecurity Council) chaired by the CISO and describes its oversight/escalation role and reporting to senior management and the Board, with explicit meeting frequency and membership details.


reasoning: The paragraph focuses on identifying the CISO/COO roles, qualifications, reporting lines, and accountability for the cybersecurity program, rather than describing an incident or internal risk processes.


reasoning: The paragraph states that executive management is responsible for overseeing cybersecurity strategy and includes cybersecurity risk in its risk oversight, but it does not name any specific cybersecurity role, committee, program, framework, or time period.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and risk management program (including asset/threat identification, controls, monitoring, and effectiveness testing) rather than a standalone incident or board/management role. It also references NIST, making it sector-adapted rather than firm-specific.


reasoning: The paragraph discusses risk assessment and the need to integrate safeguards into management systems, which is an internal risk management process. However, it is purely hypothetical and contains no firm-specific details, dates, roles, frameworks, or tools.


reasoning: The paragraph focuses on the Audit Committee’s oversight of cybersecurity risk and its update/notification process to the Board. It does not include any firm-specific details beyond generic governance language (e.g., Audit Committee is treated as standard).


reasoning: The paragraph describes oversight and escalation by a named Cyber Security Subcommittee that performs an initial assessment and determines whether to notify members of the executive team. A named governance body (the Cyber Security Subcommittee) is the grammatical subject of the described cyber-related process.


reasoning: The paragraph describes the company’s internal cybersecurity activities (monitoring threats, using threat intelligence feeds/tools, mitigating highest risks) as part of its risk management approach, without any board/management role focus or an actual incident.


reasoning: This paragraph describes the company’s internal cyber incident response processes, including escalation, roles, and decision-making steps. Although it references board reporting, the main topic is how the incident response is managed internally (i.e., the process).


reasoning: The grammatical subject is a specific management role (“VP of IT and Facilities”), and the paragraph describes that role’s cybersecurity-related responsibilities and reviews.


reasoning: The paragraph describes the company’s internal security processes (flaw identification/correction, monitoring communications, backup/recoverability, physical protection, and review of third-party/cloud services) rather than an incident or board/management role.


reasoning: The paragraph describes the company’s internal cybersecurity activities (monitor/detect/analyze/mitigate/respond) and general preparedness efforts. Although it mentions third-party consultants and grid exercises, vendor oversight is not the central topic—internal security operations and readiness are.


reasoning: The paragraph is about the Board’s oversight function through a named board committee (“Technology Committee”) and describes its responsibilities for technology and cyber-related risk oversight and resiliency/contingency oversight.


reasoning: The paragraph describes the company’s planned internal cybersecurity security awareness and control-testing approach (policy updates, targeted training, evaluating control design/operational effectiveness) rather than governance, incident disclosure, or third-party oversight.


reasoning: The paragraph contains forward-looking, generic risk statements (and only a vague reference to not having experienced attacks) without describing a specific incident, internal process, roles, frameworks, or verifiable firm-specific details.


reasoning: The paragraph describes the company’s own incident-detection and response procedures (policy, triage, escalation) and how the incident response is managed, which is part of the internal risk management process rather than an actual incident disclosure.


reasoning: The paragraph centers on the CISO’s specific responsibilities and reporting/briefing role with the IOC, including how the CISO stays informed through an internal team.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity risks, including receiving presentations, incident updates, and annual discussions, making the Board the grammatical subject. No firm-specific facts or named standards are present, confirming generic boilerplate.

provider: x-ai


reasoning: Paragraph discusses general cybersecurity risks, lack of significant security investments, and concludes that threats have not materially affected the company, aligning with Strategy Integration for materiality assessments without incident narrative. No specific facts, roles, dates, frameworks, or quantifiable details present, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal processes for assessing, identifying, and managing cybersecurity risks, including integration into enterprise risk management and brief mention of third-party threats as a component, making Risk Management Process the best fit. No specific facts, named frameworks, roles, or unique details are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal multi-stakeholder team and processes for identifying, assessing, and managing cybersecurity risks, including monitoring and assessments, which fits Risk Management Process; vendors are components of the internal process, not the central topic.


reasoning: Paragraph states that cybersecurity risks have not materially affected the company to date, which is a standalone materiality conclusion fitting Strategy Integration; it includes a cross-reference to risk factors but no incident narrative or other substantive cyber process details.


reasoning: The paragraph describes the company's internal Enterprise Risk Management Program (ERM) and Enterprise Risk Assessment (ERA), including how cybersecurity risks are assessed, prioritized into 12 categories, monitored quarterly, and reported, making Risk Management Process the best fit. Board and executive reporting are mentioned but secondary to the process description.


reasoning: This paragraph is a cross-reference to the risk factors section (Item 1A) with quoted boilerplate language on potential cybersecurity risks and consequences, containing no substantive disclosure on governance, processes, incidents, or strategies.


reasoning: The paragraph focuses on the ISO's role, qualifications, reporting line to the CRO, and oversight responsibilities, making the management role the grammatical subject per guidelines. It names specific cybersecurity roles and includes a quantified experience detail, qualifying as Firm-Specific with one verifiable quantified fact but not reaching Quantified-Verifiable threshold.


reasoning: The paragraph centers on the Audit Committee's oversight responsibilities for cybersecurity risks, including receiving reports from the ERM Committee, CIO, and VP Infrastructure, with the board committee as the grammatical subject. It fits Board Governance as board/committee oversight is the main focus, not management roles or internal processes.


reasoning: The paragraph focuses on the company's own internal risk management processes, including ERM integration, framework adoption (FFIEC), periodic reviews, and cross-functional threat mitigation, with CISO mentioned as part of these processes rather than as the primary subject. Board oversight and management roles are mentioned briefly in support of the overall process description.


reasoning: The paragraph details the company's own internal Information Security programs aligned to ISO and NIST frameworks, focusing on risk assessment and management processes, which matches Risk Management Process. It names recognized frameworks (NIST, ISO) but lacks any firm-specific facts like roles, dates, or numbers, resulting in Sector-Adapted specificity.


reasoning: The paragraph details the company's internal risk assessment processes, including engaging third-party consultants to design/implement policies, monitor/test safeguards, and imposing certification/reporting requirements on those providers, making internal processes the central topic with vendors as a component (per tiebreakers). No incident narrative or other categories apply.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk management, including annual reviews, discussions with the CIO and CISO, and reporting to the Board, with the committee and Board as the grammatical subjects. Management roles are mentioned briefly in the context of board oversight.


reasoning: The paragraph details the company's internal cybersecurity processes, including incident response planning, testing, training, risk assessments, monitoring, mitigation measures, and activities like threat modeling, vulnerability scanning, and penetration testing, making 'Risk Management Process' the best fit. No specific roles, committees, dates, programs, tools, firms, or quantifiable details qualify as firm-specific facts; common practices and generic terms do not elevate specificity beyond boilerplate.


reasoning: The paragraph primarily describes the Board of Directors' oversight responsibilities for cybersecurity risks, assessments, reviews, and discussions, with the Board as the main grammatical subject. The HSE Director's role is mentioned in the context of Board oversight, aligning with Board Governance per tiebreakers.


reasoning: The paragraph assesses the materiality of past (none material) and potential future cybersecurity risks on business, operations, and financial condition, with no incident narrative, aligning with Strategy Integration per tiebreakers for materiality conclusions. It includes forward-looking disclaimers and a risk factor cross-reference but centers on business/financial impact without describing processes or events.


reasoning: The paragraph details the Trustee's own internal cyber risk management program, including identification, assessment, mitigation, protocols like passwords and training, and integration into overall risk management, fitting Risk Management Process. It lacks any named frameworks, specific roles, dates, vendors, or quantifiable details, resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program, including vulnerability management, monitoring via a service provider, and an incident response plan aligned with NIST, focusing on risk assessment, monitoring, and IR planning. Vendor mention is incidental to internal processes, and board escalation is brief, making Risk Management Process the best fit.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks, including monitoring through management reports and reporting to the Board quarterly, with the Board receiving periodic presentations, making the board/committee the grammatical subject. No firm-specific facts qualify under the ✓ IS list, as 'Audit Committee' is explicitly generic and cadences like 'quarterly' and 'periodic' do not count.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including adoption of the NIST framework, dedicated team assessments, monitoring, cross-departmental collaboration, and policy integration. This aligns with Risk Management Process as the company's own processes are the central topic, with third-party mentions as components.


reasoning: The paragraph details the company's own internal processes for risk identification, threat assessment, monitoring threat intelligence, evaluating controls, and mitigating risks including from third-party providers, making Risk Management Process the best fit as vendor risks are a component rather than central. 'Dedicated InfoSec team' qualifies as a firm-specific named team fact, with no named frameworks or additional verifiable facts for higher specificity.


reasoning: The paragraph focuses on the board and Audit Committee's oversight of cybersecurity risks, including report cadences from specific IT leaders, making board/committee the grammatical subjects. Specific IT leadership roles qualify as firm-specific cybersecurity-related facts, but no hard verifiable elements like dates or third-party names reach Quantified-Verifiable.


reasoning: This paragraph describes the company's own internal processes for threat identification, investigation, risk assessment, escalation, and reporting to committees, aligning with 'Risk Management Process'. Specific roles and committees are integral to the process but do not shift the focus to 'Management Role' or 'Board Governance' per tiebreakers.


reasoning: The paragraph details specific management roles such as VP for IT Data Security reporting to the CTO, the Cybersecurity Committee (management-level) providing guidance, and team compositions, aligning with Management Role despite an initial brief mention of Board oversight. Board is not the primary grammatical subject, and processes are not the focus.


reasoning: Paragraph details the company's internal processes such as incident response plans, tabletop exercises, training, business continuity plans, and risk-based security controls, which align with Risk Management Process. No qualifying specific facts from the ✓ IS list or named standards are present, resulting in Generic Boilerplate.


reasoning: The paragraph describes the Board's primary responsibility for cybersecurity risk oversight, the Audit Committee's review role, and the formation of a Cybersecurity Risk Subcommittee with specific requirements, making Board Governance the most applicable category as board/committee oversight is the grammatical subject and central topic.


reasoning: The paragraph focuses on the CDIO/CISO role, including identification, qualifications, reporting lines, experience, team oversight, and brief committee interactions, making 'Management Role' the clear fit as the role is the grammatical subject. Specificity reaches Quantified-Verifiable due to multiple hard facts: specific date (2021) and named third-party firms (Comerica Bank, HSBC, Citibank, General Electric).


reasoning: The paragraph details the company's own internal processes for developing, implementing, reviewing cybersecurity controls, conducting risk assessments, and using frameworks like CIS and PCI DSS, fitting 'Risk Management Process'; third-party involvement is a minor component of assessments, not central. It names recognized standards (CIS Critical Security Controls, PCI DSS) but lacks any firm-specific facts from the ✓ IS list.


reasoning: The paragraph describes the company's internal processes for protecting data/systems, monitoring via tools like SIEM, and conducting periodic tests including penetration testing, which aligns with Risk Management Process. No board/management as subjects, no central third-party focus, no incident narrative, and third-party experts are a minor component of internal processes.


reasoning: The paragraph focuses on the board of directors and audit committee's oversight of cybersecurity risks, incidents, and compliance, with the committee as the primary grammatical subject; management roles including CISO are mentioned secondarily in the context of programs supporting this oversight.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee overseeing cybersecurity risks, receiving quarterly reports, and the reporting escalation process, making the board the primary grammatical subject. No firm-specific facts qualify under the ✓ IS list; all elements like Audit Committee, CEO/CFO, and quarterly cadences are generic or excluded.


reasoning: The paragraph briefly mentions board oversight of risks via consultants but primarily addresses past immaterial cybersecurity incidents and concludes no material current or likely future impact on business or finances, aligning with Strategy Integration per tiebreakers for materiality assessments without incident narratives or descriptions.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including detection, training, assessments, penetration testing, vulnerability management, and third-party oversight as components, with NIST CSF as the framework. Third-party risk is mentioned only as part of internal processes, not centrally.


reasoning: The paragraph centers on the CIO and senior leaders as the grammatical subjects reviewing assessments, leading the response plan, and reporting to committees, aligning with Management Role criteria for role identification and reporting lines. Board and committees are recipients rather than subjects, distinguishing from Board Governance.


reasoning: The paragraph centrally focuses on assessing third-party providers' security standards, contractual requirements, insurance oversight, adherence to protocols like notification and encryption, incident dialog with partners, and use of consultants for penetration studies, making vendor/supplier oversight the primary topic rather than a component of internal processes.


reasoning: The paragraph focuses on the Board, Audit Committee, and Cybersecurity Subcommittee's oversight responsibilities, delegation, and reporting on cybersecurity risks, making board/committee oversight the central topic and grammatical subject.


reasoning: The paragraph emphasizes the Board's and Audit Committee's active involvement in oversight of the cybersecurity program, making the board/committee the grammatical subject, which aligns with Board Governance. It briefly describes internal processes and references NIST but does not shift the primary focus away from governance.


reasoning: The paragraph details the company's internal training programs, including security awareness, phishing simulations, tabletop exercises, and response tests, which are part of its risk management processes for handling cybersecurity threats.


reasoning: The paragraph describes the company's internal cybersecurity program based on the NIST CSF, including incident detection, response processes, operational plans, reviews, and exercises, which aligns with Risk Management Process for framework adoption and IR planning. No actual incidents, roles, board oversight, vendors, or financial impacts are mentioned.


reasoning: The paragraph provides a standalone materiality conclusion stating no material breaches or significant expenses to date, with potential impacts on business strategy, operations, and financial standing, fitting Strategy Integration; the brief mention of incident response practices is secondary and does not shift the primary focus.


reasoning: The paragraph focuses on specific management roles like the Director, IT Infrastructure & Security and VP of Information Technology, their qualifications, expertise, and reporting lines, making 'Management Role' the primary category. Processes like the CIRP are mentioned but subordinate to the roles as grammatical subjects.


reasoning: The paragraph states no material cybersecurity risks identified in fiscal 2025 affecting business strategy, operations, or financial condition, which is a standalone materiality conclusion without incident narrative, fitting Strategy Integration. Vague mentions of past intrusions do not describe specific events.


reasoning: The paragraph describes a specific past cybersecurity incident including the date (October 2023), unauthorized access and download of user information from 23andMe.com accounts, and detailed response actions such as system enhancements, password resets, and two-factor verification, fitting Incident Disclosure per tiebreakers. It contains two hard verifiable facts (specific date and named system), qualifying as Quantified-Verifiable.


reasoning: The paragraph details the company's own cybersecurity program features, including framework alignment, certification, controls, monitoring, incident response, and assessments, making Risk Management Process the best fit as internal processes are the central topic. Vendor mention is peripheral, not central.


reasoning: The paragraph focuses on the Board's delegation of risk oversight to committees, with the Audit Committee specifically overseeing cybersecurity risks, mitigation plans, breach response, and receiving management reports and incident updates, where the board/committees are the grammatical subjects.


reasoning: The paragraph details the company's internal processes for cybersecurity assessments, vulnerability management, patch management, disaster recovery, and threat monitoring by its technology team and operational risk group, fitting Risk Management Process as the company's own processes are the central topic. It contains no named frameworks, specific roles, dates, firms, or quantifiable facts, making it Generic Boilerplate.


reasoning: The paragraph centers on the Information Security team led by the CISO, detailing their certifications, the CISO's experience, education, certifications, and reporting lines to CITO and CEO, fitting 'Management Role' as management roles are the grammatical subjects and focus. Multiple quantified facts (17 years experience, numerous named certifications) exceed the threshold for Quantified-Verifiable, consistent with calibration examples.


reasoning: The paragraph centers on the CISO as the leader of the Information Security Council, detailing the CISO's qualifications, experience, and certifications, which aligns with Management Role where specific management roles are the grammatical subject. It mentions the ISC's activities but subordinates them to the CISO's role.


reasoning: Paragraph briefly mentions a past cybersecurity incident with a date but provides no description of the event, focusing instead on its immateriality to business/operations/financial condition and forward-looking risks, aligning with Strategy Integration per tiebreakers for brief incident mention + materiality conclusion.


reasoning: The paragraph details the company's own cybersecurity risk management program, including framework adoption (NIST Cybersecurity Framework and Sarbanes-Oxley), which aligns with 'Risk Management Process' as it focuses on internal processes for identifying, assessing, and managing risks. It names recognized frameworks but lacks any firm-specific facts from the ✓ IS list, resulting in Sector-Adapted specificity.


reasoning: This paragraph assesses the immaterial impact of past information security incidents and states no known cybersecurity risks reasonably likely to materially affect the business, with forward-looking notes on potential financial impacts, aligning with Strategy Integration for materiality conclusions without incident narratives. It contains no specific facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph focuses on the CISO as the primary subject, detailing their qualifications, experience, education, and specific responsibilities in cybersecurity, aligning with 'Management Role' per guidelines and tiebreakers emphasizing the role as grammatical subject.


reasoning: The paragraph centrally describes processes for overseeing third-party providers, including pre-engagement assessments, ongoing monitoring by the Information Security Department, and contractual expectations in the Sustainable Purchasing Charter, which aligns with Third-Party Risk rather than general internal processes. Employee training is mentioned briefly but is not the focus.


reasoning: This paragraph consists of forward-looking disclaimers about general cybersecurity risks and the limitations of controls, with a cross-reference to Risk Factors, fitting 'None/Other' as it provides no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph describes the company's own internal processes for assessing, identifying, and managing cybersecurity risks, including scope for internally managed IT, which fits Risk Management Process. It contains no named standards, roles, dates, or other specific facts from the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal risk management processes, including alignment with the NIST Cybersecurity Framework, integration into the ERM program, and risk assessment by security and ERM teams, making 'Risk Management Process' the best fit. Board and management are mentioned briefly at the start but are not the focus.


reasoning: The paragraph centers on the Chief Information Security Officer's identification, qualifications, experience, certifications, reporting line, and management's cybersecurity expertise, making management roles the primary subject. Board oversight is mentioned only briefly in passing.


reasoning: The paragraph details the company's internal processes for engaging external experts to test and evaluate security systems, conducting training, and refining policies based on results, which aligns with Risk Management Process as it focuses on the company's own risk assessment and monitoring practices. Vendor/external engagements are a component of internal processes, not the central topic. No specific facts from the ✓ IS list or named standards are present, confirming Generic Boilerplate.


reasoning: This paragraph describes a real cybersecurity incident with specifics on date, unauthorized access method, affected data (emails, usernames, phone numbers, hashed passwords, API keys, OAuth tokens, MFA), scope (all Dropbox Sign users, limited to Sign infrastructure), and response actions (activated incident response process to investigate, contain, remediate), directly matching 'Incident Disclosure'.


reasoning: The paragraph primarily describes the company's planned internal risk management processes for cybersecurity, including identification, assessment, vulnerability management, penetration testing, and integration into overall ERM, with board oversight and third-party consultant mentioned only briefly as components. No tiebreaker applies to shift to Board Governance or Third-Party Risk.


reasoning: This paragraph details a real cybersecurity incident, including the date of determination (March 10, 2024), unauthorized access by a third party, initiation of response protocols, containment measures, business disruption, and ongoing investigation, directly matching Incident Disclosure criteria.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight of cybersecurity risks, including annual and quarterly meetings with the CSO, fitting Board Governance as the board/committee is the grammatical subject. CSO is a cybersecurity-specific role, qualifying as a firm-specific fact, with no additional verifiable facts or named frameworks for higher specificity.


reasoning: Paragraph details a real cybersecurity incident with date of detection, unauthorized access description, response actions (incident procedure activation, external experts, law enforcement notification), and scope of disruptions to IT systems and business applications, directly matching Incident Disclosure. Includes one verifiable specific date, meeting Firm-Specific criteria but not reaching Quantified-Verifiable (only one hard fact).


reasoning: The paragraph details the company's internal Enterprise Risk Management process, including quarterly assessments, action plans for risk remediation, and incorporation of cybersecurity reports from the CISO and CDO into decision-making, making Risk Management Process the best fit. Specific roles like CISO are mentioned as contributors to the process rather than the primary subject.


reasoning: The paragraph focuses on the VP of IT (a cybersecurity-specific role), their qualifications, responsibilities, reporting lines to the CFO and Audit Committee, and details the IT Executive Steering Committee composition and security team, making management roles the grammatical subject per tiebreakers. Multiple quantified facts (durations, headcount) and named roles/committees exceed the threshold for Quantified-Verifiable.


reasoning: Paragraph details a specific cybersecurity incident including dates of detection and access, scope of affected accounts (employee emails of senior leadership and cybersecurity/legal functions), response actions (removed access, investigating, notifying authorities), and initial impact assessment, fitting Incident Disclosure. Multiple specific dates qualify it as Quantified-Verifiable.


reasoning: Paragraph details the timeline, scope (email accounts of senior leadership, cybersecurity, legal functions), actor actions (access, exfiltration, attempts on source code), and ongoing investigations of a specific incident, matching Incident Disclosure criteria. Contains one specific date and named department compositions, qualifying as Firm-Specific but not Quantified-Verifiable due to fewer than two hard verifiable facts.


reasoning: This paragraph details a specific cybersecurity incident, including the date it was determined (March 10, 2024), unauthorized access by a third party, response actions (incident response protocols, containment), scope (portions of information environment, business disruption), and remediation status, directly matching Incident Disclosure criteria.


reasoning: This paragraph describes a specific cybersecurity incident, including detection date (February 5, 2024), access start date (February 4, 2024), threat actor actions (unauthorized access, exfiltration), scope of data affected (client info, PII, admin/user data, small percentage of user accounts), and response actions (incident response process, external experts, law enforcement notification), directly matching Incident Disclosure criteria.


reasoning: Paragraph details a specific cybersecurity incident including detection date, unauthorized access to IT systems, response actions (incident response procedure activation, external experts, law enforcement notification), and operational disruptions to business applications and reporting systems, directly matching Incident Disclosure criteria.


reasoning: This paragraph consists entirely of forward-looking statement disclaimers, cross-references to Risk Factors, and boilerplate legal language with no substantive cybersecurity content.


reasoning: This paragraph details the incident response by a third-party provider, scope limited to their environment, unauthorized access to specific customer personal information types (name, DOB, SSN/TIN), notification plans, and no evidence of misuse, clearly describing an actual cybersecurity incident per category guidelines. No qualifying specific facts from the ✓ IS list (no dates, named roles/committees/firms/products, quantified metrics, or unique programs), confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the scope of a specific cybersecurity incident (impacted IT systems, billing and label making functions, data stolen/destroyed), response actions (removed third party, restored access, used contingency plans and backups), and operational continuity, matching Incident Disclosure criteria with narrative details of what happened.


reasoning: This paragraph provides a detailed narrative of a specific cybersecurity incident, including what happened (website defacement), dates, and response actions (restoration from backups, taking site down), directly matching Incident Disclosure criteria.


reasoning: Paragraph describes the specifics of a cybersecurity incident including exfiltration of client files containing personal information, engagement of experts for evaluation, ongoing analysis, client notifications, and confirmation of no public release, fitting Incident Disclosure as it narrates the event, scope, and response actions.


reasoning: Paragraph details the specifics of a cybersecurity incident involving a former employee accessing customer data from up to 33 million accounts, including data types accessed and not accessed, ongoing investigation, and regulatory involvement, matching Incident Disclosure criteria with a real event narrative and scope.


reasoning: Paragraph discusses materiality of financial impact and expected costs of an incident without describing the event itself, fitting Strategy Integration per tiebreakers. No specific facts, named standards, or verifiable details present.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including unauthorized access by a threat actor, system impacts, operational disruptions (halted production), data exfiltration, and ongoing review/notification actions, directly matching the Incident Disclosure criteria. No qualifying specific facts (e.g., dates, named entities, quantifiables) are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph details the incident narrative including unauthorized access to IT systems, exfiltration of specific data types (images of video meetings and screens), ransomware threat, response measures, and operational/financial impacts, directly matching Incident Disclosure criteria over Strategy Integration due to descriptive event details.


reasoning: Paragraph discusses financial costs, estimated expenses, and ongoing assessment of the Incident's impact without any narrative of the event itself or response actions, aligning with Strategy Integration per tiebreakers. Contains one specific dollar amount range, qualifying as Firm-Specific but not reaching Quantified-Verifiable threshold of two hard facts.


reasoning: This paragraph describes the scope and content of data affected in a cybersecurity incident, including types of records, customer interactions, and lack of certain PII, directly matching Incident Disclosure criteria for affected data/systems. No qualifying specific facts from the ✓ IS list (no dates, roles, named entities, quantifiables, etc.), resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes a specific cybersecurity incident including the date (February 3, 2025), unauthorized access, encryption of applications, data exfiltration, response actions (remediation, third-party vendors), and operational impacts, matching Incident Disclosure criteria.


reasoning: This paragraph describes a real cybersecurity incident with specifics on detection date, unauthorized occurrences, encryption of systems, data theft, response actions (investigation, incident response plan activation, system shutdowns), and operational impacts on retail and e-commerce, directly matching Incident Disclosure criteria.


reasoning: This paragraph describes a real cybersecurity incident with specific dates, affected systems (website, email, IT), cause (former executive action), and response steps, directly matching Incident Disclosure criteria including narrative, scope, and actions.


reasoning: This paragraph describes operational disruptions (e.g., interrupted inventory replenishment, delayed orders, cancellations, reduced e-commerce demand), response actions (system shutdown, resumption of operations), and recovery status from a specific cyber incident, directly matching Incident Disclosure criteria with narrative of event scope and impacts.


reasoning: The paragraph focuses on the financial and operational materiality of the Incident on Q2 2024 results, including slower vehicle sales since June 19, 2024, without describing the incident itself or response actions, aligning with Strategy Integration per tiebreakers for financial impact and materiality conclusions. It contains two specific dates (June 19, 2024 and June 30, 2024), qualifying as Quantified-Verifiable.


reasoning: The paragraph discusses the materiality assessment of a cybersecurity incident on business operations and financial condition, along with insurance coverage, without any incident narrative or description of the event, aligning with Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph describes a specific cybersecurity incident including detection date (December 13, 2023), response actions (investigation, incident response plan activation, system shutdown), and containment date (December 15, 2023), matching Incident Disclosure criteria with event narrative.


reasoning: Paragraph describes a specific cybersecurity incident including dates of notification and data access, unauthorized access method, threat actor identity, response actions, and scope of affected mailboxes. Meets Incident Disclosure criteria with narrative of what happened, when, scope, and response.


reasoning: The paragraph describes the incident involving unauthorized action by a former executive officer, its scope (website offline, delayed IT communications, no material impact on IP or customer data), and ongoing response (evaluation and investigation), fitting Incident Disclosure as it references a real event with narrative details. No qualifying specific facts from the ✓ IS list (no dates, roles, names, numbers, etc.), resulting in Generic Boilerplate specificity.


reasoning: This paragraph details a real cybersecurity incident with specifics on date, unauthorized access to Targus file systems, response actions (incident response protocols, containment), scope (Targus network), and operational impact (temporary interruption), directly matching Incident Disclosure criteria.


reasoning: This paragraph details the remediation, containment, operational impacts (communications, shipping, manufacturing), and response status of a specific cybersecurity incident, including scope and actions taken, which aligns with Incident Disclosure criteria. It goes beyond mere financial materiality by describing event impacts and resolution.


reasoning: The paragraph discusses expected insurance recoveries for incident-related costs and assesses the materiality of the cybersecurity incident on financial condition without describing the event itself, aligning with Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph focuses on financial costs, insurance, and materiality assessments of an incident without any narrative description of the event, aligning with Strategy Integration per tiebreakers. No verifiable facts, named standards, or firm-specific details present, resulting in Generic Boilerplate.


reasoning: Paragraph describes a specific ransomware incident including dates (August 16 and 21, 2025), origin via third-party vulnerability, scope on internal IT systems, response actions (engaged experts, system improvements), and conclusion, fitting Incident Disclosure criteria with event narrative.


reasoning: The paragraph assesses the materiality and financial impact of 'this incident' without any narrative description of the event, matching Strategy Integration per tiebreakers for financial/materiality discussions absent incident details. Multiple specific dates (February 11, 2025; March 31, 2025; June 30, 2025) provide two or more hard verifiable facts, qualifying as Quantified-Verifiable.


reasoning: This paragraph details a real cybersecurity incident, including the date of detection (July 10, 2024), unauthorized occurrences on IT systems, encryption of data files, immediate response actions (containment, investigation, incident response plan activation, system shutdowns), and specific operational impacts (manufacturing halted, retail/e-commerce open but fulfillment impaired), directly matching Incident Disclosure criteria.


reasoning: The paragraph describes a specific cybersecurity incident including the date it occurred at CDK, the scope of affected systems (DMS, CRM), restoration status, and operational disruptions, fitting Incident Disclosure. It contains multiple verifiable facts like a precise date and named firm/systems, exceeding the threshold for Quantified-Verifiable.


reasoning: This paragraph describes a specific cybersecurity incident including the detection date (June 30, 2024), unauthorized access to information systems, and initial response actions like containing, assessing, remediating, and engaging experts, directly matching Incident Disclosure criteria with a real event narrative.


reasoning: Paragraph describes a real cybersecurity incident including unauthorized access to IT systems, detection, response actions (activating incident response plan, taking systems offline, notifying law enforcement), and operational impacts (halting production at various locations), directly matching Incident Disclosure criteria. No qualifying specific facts from the ✓ IS list (no dates, named roles, firms, tools, or unique programs), resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes the detection of a cybersecurity incident on a specific date, initial response actions including network isolation and business continuity protocols, operational impacts, ongoing investigation, and notifications to regulators and law enforcement, directly matching Incident Disclosure criteria for narrating a real event with scope and response details.


reasoning: The paragraph details financial and business impacts of 'the incident' (delayed transactions, lost revenue, delayed title policy revenue recognition, one-time expenses) without any description of the event itself, matching Strategy Integration per tiebreakers for financial impacts absent incident narrative.


reasoning: This paragraph describes a specific cybersecurity incident including dates (June 19 and 21, 2024), scope of affected systems (DMS, CRM, others), current status (partial restoration), and ongoing response (investigation and testing), fitting Incident Disclosure per tiebreakers. It centers on the incident narrative and impacts rather than processes, governance, or vendor oversight.


reasoning: Paragraph details operational impacts, response actions (halting operations, remediation, engaging experts, restoration), and scope of a specific cybersecurity incident, fitting Incident Disclosure. Contains one firm-specific date ('mid-June'), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard verifiable fact.