reasoning: The paragraph describes the purpose of the company’s cybersecurity program (a process description), but it contains no named roles, frameworks, systems, dates, or other firm-specific details.


content_category: Management Role

category_confidence: high

specificity_confidence: medium

reasoning: The paragraph identifies a specific cybersecurity-related management function/person (“head of the ITS Department”) as the grammatical subject responsible for assessing and managing cybersecurity material risks.

provider: openai


content_category: Board Governance

specificity_confidence: low

reasoning: The paragraph is primarily about the Board of Directors’ oversight and reporting on cybersecurity matters, with the Board as the grammatical subject. While it mentions specific roles (CISO, CIO), the disclosure remains generic (no unique firm details, dates, tools, or quantified facts).


reasoning: The paragraph describes oversight responsibilities and explicitly references the Cybersecurity Committee evaluating its composition and performance, indicating board/committee governance rather than management-led processes.


content_category: Risk Management Process

specificity_confidence: high

reasoning: The paragraph describes the company’s incident response and recovery planning and how it is tested to improve preparedness, which is a core risk management/process description. No specific management role, board subject, named framework/standard, or incident narrative is provided.


category_confidence: medium

reasoning: The paragraph describes general cybersecurity threats and mentions safeguards, but it does not foreground a specific cybersecurity management role or board oversight, nor does it describe a named incident or firm-specific program/framework.


reasoning: The paragraph assigns cybersecurity-related oversight to the board (“monitors and assesses strategic risk exposure”) and assigns risk management to executive officers, with the board described as the subject of the governance action. It contains no specific cybersecurity roles, committees, processes, or incident details.


reasoning: The paragraph describes cybersecurity risk management being part of the company’s enterprise risk management program, focusing on the company’s process integration rather than a specific management role or board oversight. It contains no cybersecurity-specific named roles, committees, dates, standards, or tools, making it generic boilerplate.


reasoning: The paragraph describes the board’s oversight of cybersecurity risks and mentions that updates are provided through an audit committee and executive leadership, making the board/committee oversight the grammatical focus.


reasoning: The paragraph describes the company’s cybersecurity-related program requirements (PII policy, employee training/testing) but does not name any specific management role or board/committee oversight, nor does it disclose an incident or vendor-focused controls.


content_category: Strategy Integration

reasoning: The paragraph provides a materiality/impact conclusion about cybersecurity incidents on business strategy and financial position, without describing any incident details or management/cyber governance processes.


reasoning: The paragraph describes generic incident-response/eradication activities (remove malware, identify root cause, prevent recurrence) without naming any management role, board oversight, incident details, or firm-specific facts.


reasoning: The paragraph describes the company’s cybersecurity program as part of its risk management approach, focusing on program “key areas,” without naming any specific management role or an actual incident.


category_confidence: low

reasoning: The paragraph refers to the company’s IT team qualifications but does not name any specific cybersecurity role, leader, or committee, nor does it describe concrete governance or cybersecurity processes. It is generic boilerplate about qualifications without identifiable firm-specific facts.


content_category: None/Other

reasoning: This paragraph is general promotional/boilerplate language about e-mail and cloud services and mentions cybersecurity protections without describing a company-specific program, role, process, or any incident, vendor requirements, or framework.


reasoning: The paragraph centers on how cybersecurity updates flow from the Global Security Steering Committee to the Board of Directors (and Audit Committee), indicating board/committee oversight and reporting structure rather than describing a management leader’s qualifications or an internal risk process by itself.


reasoning: The paragraph identifies specific cybersecurity/technology security leadership roles (CIO and Director of IT Security, Risk and Compliance) and describes their experience as the focus of the disclosure.


reasoning: The paragraph is a financial/materiality statement about the absence of significant cybersecurity breach-related expenses, penalties, or settlements over a specified period, with no incident narrative or cybersecurity process details.


reasoning: The paragraph describes board/audit-committee oversight and briefings about the cybersecurity cyber risk management program, with the board/committee as the grammatical focus rather than a named cybersecurity leader or internal process details.


reasoning: The paragraph describes an internal process for continuously reviewing and updating an incident response plan (ongoing review/refinement, updating procedures), without naming specific management roles or any actual incident details.


reasoning: The paragraph centers on specific cybersecurity leadership (CISO) and identifies the management role responsible for implementing and maintaining the cybersecurity risk assessment and management processes.


reasoning: The paragraph centers on board-level reporting/updates and explicitly identifies the Audit Committee and the Cybersecurity team as sources of those updates, indicating board governance over cybersecurity risk. The facts are specific to the disclosure context but do not include hard verifiable quantities or dates.


reasoning: The paragraph addresses materiality and financial/expense impact of cybersecurity incidents (no material incidents; immaterial expenses; no penalties/settlements) without describing any incident events or cybersecurity processes.


reasoning: The paragraph describes how management is informed and how cybersecurity incident prevention/detection/mitigation/remediation is monitored, but it does not foreground a specific cybersecurity management role or provide incident details. The focus is on the company’s monitoring approach/process rather than an actual disclosed incident.


reasoning: The paragraph describes cybersecurity-related practices within programs (threat intelligence, external expert review, testing), but it does not foreground a specific management role or board committee and does not identify incident details. The facts are mostly generic and lack firm-unique program names, roles, dates, or tools.


content_category: Third-Party Risk

reasoning: The paragraph’s focus is the review and monitoring of third-party IT service providers’ cybersecurity measures, including use of Security Scorecard for provider oversight.


reasoning: The paragraph discusses cyber insurance coverage and mitigating financial losses, without describing any actual incident or specifying any management role or governance/process details.


reasoning: The paragraph describes the company’s cybersecurity measures in general (risk management for protecting information systems) without naming any specific management role, program, framework, incident, or other firm-unique details.


reasoning: The paragraph is centered on a specific cybersecurity management role (“internal cybersecurity coordinator”) and describes that person’s responsibilities and reporting line, making it Management Role rather than a process-only description.


reasoning: The paragraph describes general security training activities (phishing simulations and training) without any board/management roles, named frameworks, or firm-specific details, so it does not constitute substantive cyber governance/process specifics under the provided taxonomy.


reasoning: The paragraph describes the company’s cybersecurity risk assessment and management approach as internal processes (traffic monitoring tools and user training) without focusing on any specific cybersecurity leader or incident. No named roles, dates, standards, tools, or firm-specific identifiers are provided.


reasoning: The paragraph describes cybersecurity personnel responsibilities but does not name any specific cybersecurity leader (e.g., CISO) or company-specific role, so it reads as generic description rather than a firm-specific management assignment.


reasoning: The paragraph describes internal processes to identify, assess, and manage cybersecurity-related material risks across systems and data, without focusing on a specific management role or board oversight. It does not include incident details, named frameworks, or company-specific identifiers.


reasoning: The paragraph’s grammatical focus is on the Board and Audit Committee receiving reports and being updated by management, indicating governance oversight rather than describing management roles or internal processes.


reasoning: The paragraph centers on specific senior management roles (CFO/COO/CEO) and assigns responsibility for cybersecurity risk management and related approvals, making management roles the grammatical subject despite the content being largely generic.


reasoning: The paragraph is centered on specific cybersecurity management roles (CIO and VP of Information Security) and describes their primary responsibility and supervision of cybersecurity risk management.


reasoning: The Board of Directors is the grammatical subject and is described as providing oversight via updates and through enterprise risk management discussions. The paragraph contains only generic governance/cadence language (no named committees/roles, standards, or firm-specific details).


reasoning: The paragraph describes an internal cybersecurity-related team/program and its responsibilities, which is part of the company’s cybersecurity process rather than board oversight, management role, incident disclosure, or third-party risk.


reasoning: The paragraph describes an internal cybersecurity risk management system and its purpose (identify, assess, mitigate) as the main subject, without focusing on a specific cybersecurity leader, committee, incident, third party, or named framework.


reasoning: The paragraph describes an internal incident response process (IRP) and testing via tabletop exercises, with no named management roles, committees, frameworks, or firm-specific details.


reasoning: The paragraph focuses on a risk management process for critical third-party service providers, suppliers, and vendors, including due diligence and periodic monitoring. It does not describe a specific incident or name any particular firm-specific program, role, framework, or tool.


reasoning: The paragraph describes an internal cybersecurity training and communications practice as part of managing cybersecurity risk. It does not foreground any specific cybersecurity management role or board/committee oversight, nor does it reference an incident or named standards/tools.


reasoning: The paragraph provides a materiality conclusion about the absence of cybersecurity incidents, without describing any incident or cybersecurity program details. This fits Strategy Integration rather than Incident Disclosure or Risk Management Process.


reasoning: The paragraph focuses on who manages cybersecurity on a day-to-day basis (IT staff) and discusses considering changes to that management function; no named cybersecurity role, committee, program, dates, or tools are provided.


reasoning: The paragraph describes high-level objectives related to continuity and protecting data in a cyber incident, but it does not describe any concrete company process or identify a specific cyber leader, board committee, framework, date, system, or incident details.


reasoning: The paragraph describes the company’s cybersecurity/IT programs and their process components (policies, assessments, monitoring, response plans, testing) without foregrounding any specific cybersecurity leader or board/committee oversight.


reasoning: The paragraph states a materiality conclusion about cybersecurity threats impacting business strategy, results of operations, or financial condition and provides a cross-reference, without describing an incident or specific governance/process details.


reasoning: The paragraph describes the company’s cybersecurity program and how management is informed via processes such as an incident response plan, but it does not identify a specific cybersecurity leader/role or board committee as the sentence subject.


reasoning: The paragraph describes a planned cybersecurity risk management process integrated into the company’s broader risk management system, but contains no board/management role details or any concrete incident/quantified/framework-specific facts.


reasoning: The paragraph discusses reimbursement of costs via cybersecurity insurance and states timing/amount are unknown, without describing the incident itself or any cyber risk/management process.


reasoning: The paragraph provides only a materiality/financial-impact conclusion about an incident’s likelihood of material impact, without describing what the incident was or any operational or system scope.


reasoning: The paragraph is limited to a materiality conclusion about financial impact of the incident and does not describe any incident facts or cybersecurity risk processes or roles.


reasoning: The paragraph discusses potential financial/operational impact and related risks (e.g., revenue loss, remediation costs, regulatory penalties, litigation) from an incident, without describing what happened or naming management roles or specific processes.


reasoning: The paragraph focuses on potential material financial impact and ongoing analysis, without describing incident events, affected systems/data scope, or naming cybersecurity roles or processes beyond generic statements.


reasoning: The paragraph provides only a materiality assessment (no determination of financial/material operational impact) and does not describe any incident facts or governance/management processes.


reasoning: The paragraph discusses cybersecurity insurance coverage and related cost categories and guidance timing, without describing any actual incident or internal cybersecurity processes. No board/management roles or risk-management framework/process are the main subject, so it fits strategy/financial risk framing.


reasoning: The paragraph provides only a materiality/financial impact conclusion about an incident, without describing the incident details, response actions, affected systems, or governance/process specifics.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cyber incident outcome (threat actor accessed and exfiltrated limited data, including some personally identifiable information) and associated notification/response actions. It is not focused on governance/processes or financial strategy.


reasoning: The paragraph discusses financial/legal/materiality-style consequences (litigation risk, regulatory scrutiny, and insurance availability/cost) stemming from a cybersecurity incident, without describing the incident itself or foregrounding specific security processes or management roles.


reasoning: The paragraph discusses an ongoing cybersecurity incident investigation/forensic analysis, including efforts to determine its nature, scope, and impact. However, it provides no concrete, verifiable incident details (dates, affected systems/data, or named parties/tools), making it generic.


reasoning: The paragraph describes active disruption and incident response actions (restoring systems, retaining experts, coordinating with law enforcement, and notifying regulators). It does not provide incident details or verifiable specifics like dates, systems affected, or quantified impacts, so it remains boilerplate-level.


reasoning: The paragraph provides only a materiality/financial-condition assessment (no material impact; not reasonably likely to materially impact results) without describing what occurred in the incident.


reasoning: The paragraph describes an ongoing incident disruption causing certain networks and transactional services to be inaccessible and directs readers to an incident status page for updates, which aligns with incident disclosure rather than governance or risk processes.


reasoning: The paragraph centers on which named management role(s) implement and maintain the cybersecurity risk assessment and management processes (it identifies a cybersecurity-relevant individual: the Senior Director of IT). The CFO is mentioned but is excluded from specific-fact extraction as a generic C-suite role.


reasoning: The paragraph identifies specific cybersecurity- and technology-related management roles (chief technology officer and senior director of cybersecurity and compliance) and states their reporting line to a committee, making management-focused disclosure dominant.


reasoning: This paragraph is a generic regulatory/notification statement that does not describe an incident event, cyber program/process, management roles, board oversight, or any specific cybersecurity detail beyond boilerplate compliance language.


reasoning: The paragraph provides a materiality/financial impact conclusion about an (unspecified) incident without describing what happened, making it strategy/financial-materiality disclosure rather than incident or governance/process detail.


reasoning: The paragraph provides only a materiality conclusion regarding the incident’s impact on operations and financial conditions, without describing what happened or any cybersecurity process details.


reasoning: This paragraph is procedural and forward-looking about notifications to law enforcement and regulators, with no described cybersecurity incident details, governance, or management roles.


reasoning: The paragraph discusses how costs from a cybersecurity incident are expected to be reimbursed via insurance recoveries, focusing on financial/insurance treatment rather than incident mechanics or governance/process details.


reasoning: This paragraph is a generic contractual disclaimer about waiver scope under credit/lease agreements and contains no cybersecurity, incident, or governance/process content.


reasoning: The paragraph only addresses materiality/financial impact conclusions about an incident, without describing what happened or any systems/data scope. This fits strategy/financial-materiality integration rather than incident disclosure or governance/process details.


reasoning: The paragraph describes a disclosed cybersecurity incident timeline (notification and later confirmation) and states that customer information was exposed.


reasoning: The paragraph provides a materiality conclusion about whether the cybersecurity incident will impact financial condition/results, without describing the incident itself or cybersecurity governance/processes.


reasoning: The paragraph describes the status of an ongoing cybersecurity incident (contained it, restored core IT environment, restoring normal business operations), which is incident-response status disclosure rather than governance or risk processes. It contains no firm-specific details like dates, named systems/tools, scope, or affected data.


reasoning: The paragraph focuses on materiality/financial impact and ongoing assessment of that impact, without describing the incident’s technical facts or operational scope. It does not foreground a specific cybersecurity management role or process beyond the materiality conclusion.


reasoning: The paragraph describes an operational disruption affecting online ordering in parts of the U.S., which indicates an incident-like impact. However, it provides no cybersecurity-specific details (no dates, systems, or incident narrative specifics), so it does not qualify as firm-specific.


reasoning: The paragraph discusses an ongoing investigation and states that the scope of potentially affected data is not yet fully determined, along with remediation and engagement with a cyber insurance provider—incident-response context even though it lacks concrete incident facts (dates, systems, or amounts).


reasoning: The paragraph is centered on named management personnel and their interim executive role, including the resignation date and the specific interim CEO appointment for the Korean subsidiary.


reasoning: The paragraph provides a materiality/financial impact assessment of the cybersecurity incident without describing what happened or any operational or technical response details.


reasoning: The paragraph discusses an ongoing cybersecurity incident investigation, including assessment of the scope of personal information in exfiltrated data and intent to provide notifications to affected parties and regulators. Although it lacks concrete incident details (e.g., dates, systems, or amounts), it is still incident-focused rather than purely process/framework or financial impact.


reasoning: The paragraph describes an ongoing investigation into whether PII was accessed/exfiltrated by threat actors and provides timing for when a definitive answer is expected, which is incident-focused disclosure despite lacking incident details like dates or scope.


reasoning: The paragraph discusses material disruption, impact evaluation, and potential remediation/legal/financial/reputational considerations but does not describe what the incident was or any incident-specific operational or system scope. This is therefore presented as an effects/materiality discussion rather than an incident narrative.


reasoning: The paragraph describes the status of a specific cybersecurity incident (contained) and ongoing response actions (restoring access and resuming operations), even though it omits incident details. No named roles, dates, systems, tools, or other firm-verifiable specifics are provided.


reasoning: The paragraph describes actions taken in response to an actual cybersecurity incident (closing off unlawful access) and states notice will be provided to impacted customers, indicating incident response/scope implications.


reasoning: The paragraph discusses monitoring the timing and materiality of an ongoing incident but provides no incident specifics or response details; it is framed around materiality rather than describing what happened.


reasoning: The paragraph is a forward-looking/uncertain materiality conclusion about financial impact, without describing the underlying cybersecurity event or response actions.


reasoning: The paragraph primarily provides a materiality/financial-impact conclusion (“does not believe… reasonably likely to materially impact” financial condition or results), with only generic, non-specific incident status/actions mentioned (investigate, notify law enforcement).


reasoning: The paragraph discusses whether the incident may have a material impact on financial condition and results of operations, without describing what happened or any specific cybersecurity process details.


reasoning: The paragraph references investigation findings and notification of potentially involved personal information, indicating an incident-related action, but it provides no specific incident details (dates, scope, systems) and no named roles or measurable facts.


reasoning: The paragraph narrates an ongoing cybersecurity incident, stating that the perpetrator accessed Company systems, exfiltrated data, and encrypted data. It does not provide incident dates or named tools/roles, so it lacks firm-specific details.


reasoning: The paragraph describes a real event (systems outage due to a cybersecurity attack) and the company’s response actions (activation of an incident response team). It therefore falls under Incident Disclosure rather than processes or general governance.


reasoning: The paragraph focuses on the cause being a compromised fourth-party vendor and the activation of response in connection with that third-party compromise, making vendor-related security oversight central.


reasoning: The paragraph describes an actual cybersecurity event and immediate response actions (system outage, discovery, activation of an incident response team) with a specific date, indicating incident disclosure rather than process or governance.


reasoning: This paragraph provides operational/disclosure logistics about where to find incident communications, but does not describe the incident itself or any governance/process details. It is effectively procedural boilerplate (a URL notice) rather than substantive cybersecurity disclosure.


reasoning: The paragraph describes an actual cybersecurity event (unauthorized third-party access) with a specific awareness date, which fits incident disclosure rather than process or governance.


reasoning: The paragraph discusses expected financial/material impact of a previously referenced incident on quarterly results and overall financial condition, without describing what happened or any cybersecurity processes, roles, or systems.


reasoning: The paragraph is limited to a materiality/financial impact assessment of an incident (“not had a material impact… evaluating the impact… on financial condition or results”), with no incident narrative or operational scope details.


reasoning: The paragraph discusses ongoing materiality assessment of the incident’s potential financial impact and states the impact cannot yet be determined, without describing the incident itself or any cybersecurity governance/process details.


reasoning: The paragraph describes an actual cybersecurity incident (threat actor access) and indicates notification obligations to affected parties and regulators, which is characteristic of incident disclosure.


reasoning: The paragraph describes resolution steps following a cyber incident (restoration of impacted IT systems/data) and notes that authorities closed the investigation without identifying the source, which constitutes incident narrative and response/investigation status.


reasoning: The paragraph provides a materiality/financial impact assessment of a cybersecurity incident without describing what happened, so it fits Strategy Integration rather than Incident Disclosure or Risk Management Process.


reasoning: The paragraph describes an actual cybersecurity incident’s operational impact (shipping/receiving, manufacturing, back office) and restoration/temporary measures, which is incident disclosure even though it lacks dates or named systems.


reasoning: The paragraph describes the effects of a real cybersecurity incident, including loss of access to business applications and a stated duration.


reasoning: The paragraph references restoration of key systems for Change Healthcare and points to a press release with details, but it provides no incident specifics (no affected scope, no access details, no response actions) within the paragraph itself.


reasoning: The paragraph describes a real cybersecurity event (unauthorized activity) and the company’s immediate investigation, containment, and remediation actions, triggered by a specific notification date.


reasoning: The paragraph describes a real event (detection of fraudulent attempts) with a specific date and characterizes it as an incident.


reasoning: The paragraph does not describe what happened in the cyber incident or affected systems/data; it summarizes the Company’s belief about the incident impacts as costs (rebuilding website, new hosting platform, enhancing security protocols), which is strategy/financial-impact framing rather than process or governance.


reasoning: The paragraph describes general cyber risk and broad preventive/detective monitoring activities, but it does not identify any specific cybersecurity leader, board/committee oversight, named program, framework, tool, or incident. With no firm-specific details, it fits best under generic risk management process language.


reasoning: The paragraph is primarily about the company’s cybersecurity risk processes (threat assessment, layered controls, training, tool use, and assessments). Third parties are addressed as inputs to internal processes rather than as the central focus of vendor oversight, so it fits Risk Management Process more than Third-Party Risk.


reasoning: The paragraph references an actual cybersecurity event (“unauthorized access to information”) and describes response actions (notifying regulatory authorities and working with law enforcement), which aligns with incident disclosure even though details are limited.


reasoning: The paragraph describes response/mitigation actions (manual transaction processing and alternative distribution channels) taken while systems are being restored, indicating incident-related operational continuity measures, though it provides no incident-specific details (dates/scope).


reasoning: The paragraph’s primary focus is the identified cybersecurity personnel and their reporting line (Cybersecurity Expert reporting to the Global Head of IT and Cybersecurity Services), which is characteristic of a Management Role disclosure.


reasoning: The paragraph is primarily describing the company’s cybersecurity risk management strategy and its program components (strategy, risk assessments, infrastructure, dedicated personnel, and training). Although it references Internal Audit and the Technology Committee, the overall grammatical focus is on Wendy’s processes and strategy rather than on a specific management role or an incident.


reasoning: The paragraph primarily describes S&T’s incident response and business continuity programs/processes (evaluation criteria, escalation procedures, IR/BCP content). Although the CSO is specifically named as the evaluator, the company programs/controls are the dominant subject matter.


reasoning: The paragraph focuses on financial/business impact and materiality of cybersecurity threats for fiscal 2024, stating that no cybersecurity-related risks materially affected Oracle’s strategy, results, or financial condition, with forward-looking cost/brand impacts. This is best categorized as strategy integration rather than incident disclosure or a risk-management process.


reasoning: The paragraph is centered on named cybersecurity management roles (CISO and CTO) and their qualifications, reporting line, and responsibilities for risk assessment/mitigation.


reasoning: Most sentences are written from the Board/Risk Committee perspective describing oversight of cybersecurity risks within the ERM program, including reviews and reporting to the Board.


reasoning: This paragraph is general risk-factor style language describing reliance on IT systems and potential cyber threats, without describing an incident, a governance/management role, or a specific cybersecurity program/framework tied to the company.


reasoning: The paragraph describes generic cybersecurity risk management measures and regulatory compliance approach, but it is not incident-specific and contains no named management roles, programs, committees, or verifiable facts.


reasoning: The paragraph describes the company’s cybersecurity program and the processes/areas it includes (governance support, technical safeguards, incident response/recovery planning, third-party risk management, training). Although it mentions management roles and Board/Audit Committee interactions, the dominant grammatical subject is the cybersecurity program and its risk management activities.


reasoning: The paragraph describes the company’s multi-layered cybersecurity program (controls, awareness, third-party due diligence, continuous monitoring, and resiliency) as part of its overall risk management processes. While it mentions a managed security services provider, the central focus is the company’s risk management and security program rather than a vendor-oversight-only discussion.


reasoning: The paragraph is general forward-looking risk disclosure about potential cyber threats and impacts, with no board/management roles, no described incident, and no specific programs, dates, tools, frameworks, or quantified facts.


reasoning: The paragraph describes the company’s cybersecurity risk management program (controls, technical safeguards, incident response/recovery planning, third-party risk approach, and employee training) as the grammatical subject. No specific management cybersecurity role, named committee/team, concrete incident details, or unique firm-specific identifiers are provided.


reasoning: The paragraph is primarily centered on the named Chief Information Officer’s role, qualifications (CISSP/CISA), and reporting/oversight responsibilities tied to the Information Security Program and risk reporting.


reasoning: The paragraph identifies specific individuals/roles responsible for administering and overseeing the cybersecurity program (e.g., IT Manager, General Counsel, CEO/COO) and describes their qualifications and oversight functions, making Management Role the best fit.


reasoning: The paragraph is primarily about the company’s cybersecurity risk identification, mitigation, monitoring, and response/recovery processes (e.g., NIST Framework use, IRP/BCP, disaster recovery, enterprise risk assessment). While it mentions sharing results with the Board, governance is not the primary focus and no specific cybersecurity management role is foregrounded. The only recognized, cybersecurity-specific standard named is NIST, so the disclosure is best treated as Sector-Adapted rather than firm-specific or quantified.


reasoning: The paragraph describes the company’s cybersecurity capabilities and potential impacts, but it is framed as general risk/process language rather than an incident or specific management/board oversight. It also cross-references a risk factor section without adding substantive, firm-specific governance or incident details.


reasoning: The paragraph describes the company’s cybersecurity risk management approach and program elements (monitoring, assessments, policies, training) as the grammatical subject. While it includes supplier/provider engagement, it is presented as part of the overall internal risk management process rather than as a stand-alone vendor-oversight topic.


reasoning: Most of the paragraph describes the company’s cybersecurity program and processes (risk assessment/monitoring, incident handling, and third-party provider risk management). While it later mentions board oversight and reporting lines, the dominant subject is the cybersecurity program’s design and control activities rather than a single named cybersecurity leader acting as the main grammatical subject.


reasoning: The paragraph centers on specific cybersecurity roles (vCISO and named team roles) and describes their responsibilities, making management-role-focused disclosure primary.


reasoning: The paragraph is primarily focused on the company’s cybersecurity processes (how risks are assessed/identified/managed and what controls are used). Management roles are mentioned only as part of how those processes are managed, not as the main subject.


reasoning: The paragraph describes the company’s cybersecurity program elements within its ERM approach (governance, technical safeguards, incident response/recovery planning, education, and third-party risk management) rather than focusing primarily on board oversight or a single named cybersecurity leader’s role.


reasoning: The paragraph describes Riot’s cybersecurity tools and operational processes (monitoring, EDR/SIEM, alerting, ransomware defense, backups) and related procedures, with no specific cybersecurity leader or board committee identified as the grammatical subject.


reasoning: The paragraph foregrounds named management roles/team responsibilities (including the Sr. Director of IT and a specifically named Risk Management Team) that monitor and report on cybersecurity risks to the Audit Committee, even though board/committee oversight is also mentioned.


reasoning: The paragraph describes Bowman Consulting Group’s cybersecurity monitoring and incident response planning processes, including how monitoring actions are handled and that a Cybersecurity Incident Response Plan exists; it is process-focused rather than centered on a named management role or an incident disclosure.


reasoning: The paragraph primarily describes the company’s cybersecurity incident response and assurance processes (e.g., the Agility Plan, escalation, oversight activities and training). While it mentions the CIO and team memberships, the dominant subject is the company’s program/processes rather than a management-role description.


reasoning: The paragraph discusses potential financial and operational impact of a future cybersecurity incident and states that no material cybersecurity threats occurred during the year ended December 31, 2024, without describing any incident or specific cyber program details. It is therefore primarily materiality/financial impact strategy integration rather than an operational risk-management or governance description.


reasoning: The paragraph describes the company’s cybersecurity and risk controls and processes (monitoring, encryption, unauthorized-access prevention, disaster recovery, vulnerability scanning, third-party risk register, and insurance). No specific cybersecurity leader/role, board committee, or incident is foregrounded, and third-party risk is presented as one component of the internal program rather than as vendor oversight as the central topic.


reasoning: The paragraph foregrounds specific cybersecurity and technology leadership roles (chief digital officer, chief information officer, and a designated CISO) and describes their qualifications and responsibilities. This makes it primarily about management role identification and credentials rather than an internal risk process description.


reasoning: The paragraph describes the company’s cybersecurity processes (incident escalation, technical safeguards, incident response/recovery planning, education, and risk-based third-party oversight) rather than detailing a specific management role or an actual incident. Third-party risk is presented as part of the company’s overall risk management approach, not as a standalone vendor oversight requirement.


reasoning: The paragraph centers on board and board-committee oversight of cybersecurity risk (Board of Directors and Audit Committee) as the grammatical subject, describing reporting and assessment responsibilities. It also contains boilerplate materiality language about no material incident to date, but no firm-specific cyber roles, named programs, standards, dates, or tools.


reasoning: The paragraph centers on how Chewy responds to incidents (using its IRP) and describes general types of attacks, which maps best to risk management processes rather than board/management oversight or a specific disclosed incident.


reasoning: The paragraph describes an internal cybersecurity risk assessment and risk management program and how it manages material risks, but it does not foreground a specific cybersecurity management role or describe any specific incident.


reasoning: The paragraph’s main grammatical subject is the Chief Technology Officer and its experience/certifications, and it describes his leadership over IT risk and related governance. It also includes a committee and the incident response plan, but the management role is clearly foregrounded.


reasoning: The paragraph primarily focuses on specific cybersecurity management roles (CTO/ CIO/ CISO) and their responsibility for assessing and managing cyber risks, including their experience qualifications, making it Management Role over general processes or board governance.


reasoning: The paragraph describes the company’s cybersecurity controls and processes (detection/response, encryption, risk assessments, training, vendor risk management, and incident planning) rather than board oversight, a specific management role, or a disclosed incident. It does not include any uniquely identifiable company-specific details (e.g., named tools, third-party firms, certification/program names, or specific dates/figures), so it remains boilerplate at this level.


reasoning: The paragraph centers on specific cybersecurity and compliance leadership roles (CISO and CCO) and describes their qualifications, responsibilities, and reporting/oversight relationships, which fits Management Role. It also includes multiple verifiable details (10 years, >14 years, CISSP, Brown University, Carnegie Mellon).


reasoning: The paragraph primarily describes USCF’s cybersecurity risk evaluation and mitigation processes (risk profiling, due diligence, and program provisions) rather than detailing a specific cybersecurity executive or board oversight.


reasoning: The paragraph primarily describes the company’s cybersecurity/technology risk management program, policy, framework, and internal controls as processes used to identify, assess, and manage cyber risk. While third-party vendor controls are mentioned, they are one component of the broader internal risk management approach rather than the central topic.


reasoning: The paragraph describes the company’s processes for identifying, assessing, and managing material cybersecurity risks and ties those risks to business operations and financial condition. It is not focused on a specific management role, board oversight, a third-party vendor, or an actual incident narrative.


reasoning: The paragraph centers on the board’s and Audit Committee’s oversight responsibilities for cybersecurity risk management, with board/committee oversight as the grammatical focus.


reasoning: The paragraph describes high-level cybersecurity risk management approach (policies/standards/processes/practices for assessing and managing risks, plus investment intent) rather than an actual incident or a named cybersecurity leader/committee. It does mention board and management involvement, but the main thrust is the company’s generic risk-management process and strategy.


reasoning: The paragraph primarily describes the company’s cybersecurity program, risk-based approach, controls, monitoring, employee reporting, metrics, and review processes. While it mentions CIO/CISO, the dominant focus is on the organization’s risk management process and program design rather than the qualifications or reporting line of a specific cybersecurity leader.


reasoning: The paragraph describes general cybersecurity risk management activities and the existence of policies/processes for assessing and managing risks, but it does not identify a specific incident, named cybersecurity leader, or unique program/framework. The board and management are mentioned only in passing and the core content is generic risk-management posture.


reasoning: The paragraph primarily describes the company’s cybersecurity risk processes (incident management/response, monitoring for vulnerabilities, remediation) and how they integrate into overall risk management. Although a specific management cybersecurity role (Senior Director of Information Technology) is mentioned, the bulk of the disclosure is about the processes and programmatic controls.


reasoning: The paragraph primarily describes the company’s incident response program (IRP) and how it is aligned to NIST RMF, including coordinated investigation/containment/mitigation. While it also names the CISO (and CIO) as responsible for executing the plan, most of the disclosure is still framed as the company’s incident response process.


reasoning: The paragraph describes WTW’s cybersecurity risk management strategy and operational processes (incident response plan, technical safeguards, training, threat intelligence, and third-party risk management) rather than identifying a specific cybersecurity leader or board oversight.


reasoning: The paragraph is centered on named management individuals (CEO/President and General Counsel) and their responsibility/coordination for cybersecurity risk management and incident reporting. It also includes multiple independently verifiable date ranges, durations, and firm names, making it highly specific.


reasoning: Although the opening sentences describe Board/Risk Committee oversight, the majority of the paragraph focuses on Schwab’s cybersecurity risk management activities (monitoring, monitoring systems, security controls, and policies) as the grammatical subject.


reasoning: The paragraph describes GLP’s cybersecurity risk management program and incident response plan (including escalation, assessment of material impact, testing frequency, and tabletop exercises). It focuses on processes and controls rather than identifying a specific cybersecurity leader or a board/committee subject.


reasoning: The paragraph describes Embecta’s ongoing cybersecurity monitoring and control/risk management processes, including assessment and alignment activities. Although it mentions vendor assessments and the Information Security Risk Committee, the company’s processes (monitoring, frameworks, risk management, and assessments) are the grammatical focus rather than board governance.


reasoning: The paragraph discusses the lack of material incidents and concludes there are no cybersecurity risks reasonably likely to materially affect the business, plus mentions potential future material impact and insurance sufficiency. It does not describe any actual incident event or internal cybersecurity processes; it is primarily materiality/financial-risk framing.


reasoning: The paragraph primarily describes company processes for security program governance and incident reporting/escalation across subsidiaries, with the focus on how the enterprise manages cyber risk. Named roles (CISO, CIO) appear, but the grammatical emphasis is on the operating subsidiaries’ and enterprise-wide teams’ operating procedures rather than on qualifications or reporting lines of an individual leader.


reasoning: The paragraph describes Grindr’s cybersecurity risk assessment and mitigation measures (policies, vulnerability management, audits, access controls, training, and prioritization of threats) as company processes. No named cybersecurity leader, committee, or specific incident is presented, and vendor oversight is one component rather than the central topic.


reasoning: The paragraph is a standard forward-looking statements and safe-harbor disclaimer and does not describe any specific cybersecurity incident facts, systems, scope, personnel, or processes.


reasoning: The paragraph describes Tracon’s internal vendor management program and how it assesses providers and imposes cybersecurity-related contractual obligations, which is part of the company’s risk management process (not incident disclosure or board/management roles).


reasoning: The paragraph is centered on a specific cybersecurity leader (the CIO) describing that person’s responsibility for overseeing the cybersecurity team and policies. It also includes explicit, firm-relevant details about the CIO’s experience and SOC 2 reporting from vendors.


reasoning: The paragraph describes the company’s cybersecurity risk assessment and management activities (policies/program, controls, monitoring, and IR-related tool evaluation) as part of its security operations. It also mentions third-party risk, but as a component of its overall risk management approach rather than a standalone vendor-oversight topic.


reasoning: The paragraph centers on the Board delegating oversight of the cybersecurity program to the Audit Committee and describes the committee’s review and reporting role. A named management role (CTO) is mentioned, but the grammatical focus is the board committee’s oversight activities.


reasoning: The paragraph primarily describes how the company manages cyber risk arising from third parties (service providers/vendors), including dedicated vendor security risk assessment and contract security measures. Although it also mentions incident response planning, the dominant focus is third-party security risk management rather than an actual incident or board/management qualifications.


reasoning: The paragraph focuses on the company’s disaster recovery/incident response operating framework (processes, escalation, coordination, training, and assurance activities), which makes the company’s risk management program the primary subject. Although it names the CIO and CMT, they are primarily described as participants within that process rather than as the central governance/management role focus.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized third-party access, file exfiltration, potential sensitive personal information) and the company’s containment/response actions and operational impact, along with restoration and ongoing assessment.


reasoning: The paragraph describes a disclosed cybersecurity incident with dates, investigation findings (accounts accessed and data saved), data deletion, and compensation tied to the incident’s customer notification, including quantified scope and voucher amounts.


reasoning: The paragraph describes the company’s lack of cybersecurity policies/processes/training and absence of dedicated cybersecurity risk management personnel, which are statements about its cybersecurity risk management posture.


reasoning: The paragraph describes a specific cybersecurity incident, including what happened (defaced website), actions taken (restored from backups, took site down, temporary page), affected asset (wytecintl.com), and operational/business impact (cancelled seminar). It also references specific dates and response steps, which makes it incident disclosure rather than risk process or strategy.


reasoning: The paragraph narrates a specific cybersecurity incident, including date, unauthorized access, encryption deployment, system/application impact, exfiltration, and response actions.


reasoning: The paragraph is dominated by the Audit Committee’s oversight responsibilities and reporting/briefing structure for the Board on cybersecurity risks. While the CIO and CISO are named, they are primarily described in support of the Audit Committee/Board governance function.


reasoning: This paragraph is a forward-looking disclosure/boilerplate statement about having not identified material incidents and directs readers to another section, without describing any incident details or specific governance/process elements.


reasoning: The paragraph discusses generally assessing and managing material cybersecurity risks, but it does not describe any company-specific program or process details, named roles, frameworks, or incidents.


reasoning: The paragraph describes a real cybersecurity extortion threat and the company’s investigation/response, including detection, termination of involved personnel, fraud-monitoring protections, customer notifications, and a conclusion that the activity formed a single incident/campaign.


reasoning: The paragraph describes the company’s cybersecurity program and its risk-management activities (assessments, exercises, training, threat intelligence, and oversight of third parties) rather than focusing on a specific cyber leader or incident. No named roles/committees, tools, dates, or verifiable company-specific facts are provided.


reasoning: The paragraph focuses on managing cybersecurity risks specifically arising from third-party service providers, including annual third-party risk assessments tied to contractual cybersecurity and regulatory requirements.


reasoning: The paragraph is centered on senior management responsibilities for defining and recommending cybersecurity risk appetite metrics to the Board. No specific cybersecurity leader titles, committees, metrics, or other firm-specific details are provided.


reasoning: The paragraph describes the company’s cybersecurity safeguards and an incident response plan, including how it is evaluated and tested. No specific management role, board oversight, incident narrative, or named standards/tools unique to Phreesia are provided.


reasoning: The paragraph describes company processes and procedures for evaluating and managing cybersecurity risks and preventing/detecting/mitigating data breaches, as part of enterprise risk management. No specific cybersecurity leadership roles, board/committee subjects, named programs/standards, or identifiable incident details are provided.


reasoning: The paragraph’s grammatical subject is specific cybersecurity management roles (CISO and VP of Information Security) and describes their experience and responsibilities, indicating a management/leadership qualification disclosure.


reasoning: The paragraph describes cybersecurity strategy elements (detection, analysis, response, risk management, resilience) but does not foreground any specific management role or governance body and contains no named standards, dates, roles, tools, or other firm-unique facts.


reasoning: The paragraph emphasizes that audit results and risk work are discussed with the board’s Audit Committee on a quarterly basis for cybersecurity risk oversight. Although it mentions management review roles, no qualifying cybersecurity-specific or non-generic named governance elements are provided beyond generic references that don’t meet the specific-fact extraction criteria.


reasoning: Although the paragraph begins with board/audit committee oversight, most sentences center on the CISO/CIO/CTO (their responsibilities and reporting lines), making this primarily a management-role description rather than a board-oversight narrative.


reasoning: The paragraph’s grammatical subject is the board-level Risk Committee and it describes the committee’s oversight and reporting duties for cybersecurity risk and related governance processes.


reasoning: The paragraph is a general statement about not having operations and not adopting cybersecurity programs; it does not describe processes, roles, governance, third-party risk, or any incident.


reasoning: The paragraph describes a company incident response plan and actions for mitigation, remediation, and prevention, which are internal risk management processes rather than a described real incident. Although it mentions referring matters to the CEO, the governance is generic and no named cybersecurity leadership, committee, dates, systems, or incident details are provided.


reasoning: The paragraph describes investigation and assessment steps after a cybersecurity threat notice, including isolating systems and using advisors as part of incident evaluation and response. It does not foreground a specific cybersecurity management role or describe an actual incident narrative with scope/impact.


reasoning: The paragraph describes an internal information security training practice as a component of the company’s cybersecurity processes. No specific management role, board oversight, named framework, or unique firm detail is provided.


reasoning: The paragraph addresses the absence of cybersecurity and third-party risk processes, which fits risk management process. However, it contains no specific roles, frameworks, dates, or firm-unique details.


reasoning: The paragraph’s main subject is the use of third-party service providers to identify, assess, and manage cybersecurity-related material risks, which makes it third-party risk oversight.


reasoning: The paragraph centers on the board of directors’ periodic review of the company’s cybersecurity risk profile and reporting cadence from management. It does not name any specific cyber leadership roles, committees, programs, tools, dates, or other firm-unique facts.


reasoning: The paragraph focuses on general security awareness/training activities plus a statement that the company carries cybersecurity insurance for potential incident losses, without describing any actual incident or naming specific frameworks, roles, dates, or tools.


reasoning: The paragraph assigns operational responsibility to management (led by the IT department) and describes that management executes cybersecurity strategy, with a named internal role (“Software Engineer”) coordinating cybersecurity. It does not provide firm-specific, verifiable details beyond generic responsibility and activities.


reasoning: The paragraph describes internal processes (Project Management Office routines and Vendor Management Office requirements) used by the Information Security/IT teams to onboard products/projects/third-party vendors with oversight, rather than focusing centrally on a single vendor security program or describing an actual incident or management qualification.


reasoning: The paragraph describes limits of its security controls and a general risk-based approach for selecting controls, focusing on the company’s security process rather than any specific manager, committee, standard, incident, or third-party oversight requirement.


reasoning: The paragraph is centered on oversight by a board committee (Oblong’s Audit Committee) receiving updates and ensuring incident communication/mitigation planning. No cybersecurity-specific leader, named committee other than the generic Audit Committee, dates, or firm-unique technical details are provided.


reasoning: The paragraph describes the Board of Directors’ oversight and briefing/review activities regarding cybersecurity and data privacy, making the board the grammatical subject. It contains no cybersecurity-specific roles, named committees, programs, dates, or other firm-unique details beyond generic governance language.


reasoning: The paragraph is centered on named cybersecurity and IT management roles (CISO and VP of Information Technology) and describes their responsibilities in cybersecurity risk management and strategy processes.


reasoning: The paragraph makes a materiality/impact statement about cybersecurity incidents (none known that are materially affecting or likely to) and discusses potential business/financial impacts in general, without describing any actual incident or naming specific cyber roles/processes.


reasoning: The paragraph primarily describes the company’s cybersecurity risk management objectives and improvement initiatives as well as how processes are reviewed. Although the Chief Technology Officer is mentioned as supervising, the grammatical subject is the experts/centre reviewing processes, so this aligns most closely with risk management processes rather than management role.


reasoning: The paragraph is a materiality/impact statement about cybersecurity threats but does not describe any incident or management roles; it is generic disclosure language.


reasoning: The paragraph describes escalation pathways within the company’s incident response and vulnerability management processes (process design and reporting), rather than a specific incident or a foregrounded cybersecurity leader’s qualifications. No qualifying firm-specific facts, named cybersecurity roles from the IS list, committees from the IS list, standards, dates, or systems/tools are provided.


reasoning: The paragraph describes the company’s cybersecurity risk assessment and mitigation activities (tools, monitoring, assessments, and an insurance policy) as an ongoing process, without focusing on a specific cybersecurity leader or board oversight.


reasoning: The paragraph is primarily about BlackRock’s cybersecurity program elements (controls, safeguards, incident response/recovery planning, and third-party risk management) rather than primarily identifying a specific cybersecurity leader’s role or board oversight as the main focus.


reasoning: The paragraph describes general limitations of security controls and a risk-based approach to prioritizing controls, but it does not foreground any specific cybersecurity management role or an incident. No named roles, tools, dates, or company-unique identifiers are provided.


reasoning: The paragraph is centered on specific cybersecurity-related executive roles (CIO, CTO, Information Security Officer) and states they are accountable for the information security program and related activities, making management role the grammatical focus.


reasoning: This paragraph is forward-looking risk boilerplate stating that cybersecurity threats could occur and references another risk factor in Item 1A, without describing any incident, cybersecurity process, governance, or named roles/frameworks.


reasoning: The paragraph describes company cybersecurity processes (defense approach, vulnerability updates, incident response and disaster recovery planning) as the grammatical focus, with no named cybersecurity leader or board/committee subject.


reasoning: The paragraph’s primary subject is vendor security requirements imposed before storing sensitive Company information, including due diligence and contractual encryption/access-control terms. It also includes a materiality statement, but that serves as secondary context rather than the main focus.


reasoning: The paragraph primarily describes the company’s risk management process via a cybersecurity program and dedicated teams/committees for managing cybersecurity risks and incidents. Although it mentions Board discussion and includes management roles in a council, the grammatical focus is on the program/process and associated structures.


reasoning: The paragraph describes internal use of third-party service providers as part of evaluating and improving the effectiveness of the company’s cybersecurity program, but it does not center vendor security oversight or describe a specific incident or management role.


reasoning: The paragraph describes the company’s recurring cybersecurity monitoring and testing processes (audits/exams, vulnerability/patching supplementation, and monitoring via SOC-as-a-Service), rather than incident details or a specific named cyber leader or board oversight. Third parties appear as a component of the internal program, so it fits Risk Management Process rather than Third-Party Risk.


reasoning: The paragraph describes the company’s internal control practices for vulnerability/penetration testing and evaluation, including reviewing service organizational controls reports for vendors as part of its process. No specific cybersecurity management role or board committee is foregrounded, and the vendor oversight is a component rather than the central topic.


reasoning: The paragraph describes the Audit Committee’s oversight responsibilities for cybersecurity risk, controls, and investigations, with the committee as the grammatical subject of the sentences. It also references the CISO reporting into that governance process and a specific incident response plan.


reasoning: The paragraph describes the company’s cybersecurity program and risk management activities (identifying critical systems, network segmentation, access controls, continuous monitoring, patch management) as part of internal processes. No specific cybersecurity leader, board/committee, named tools/products, or firm-specific details are provided.


reasoning: The paragraph describes generalized processes and controls for assessing and managing cybersecurity/material risks and mentions a third-party security program, but it does not focus on incident details or on a specific cybersecurity leader/board committee. No firm-specific roles, dates, tools, or programs with unique identifiers are provided.


reasoning: The paragraph is a general materiality and risk disclaimer with a cross-reference to Item 1A, and it does not describe any specific cybersecurity incident, program, framework, or named management/board oversight.


reasoning: The paragraph explicitly links cybersecurity risk management responsibilities to the Board of Directors alongside management, with the Board mentioned as the first and prominent governance subject. It does not describe cyber risk processes themselves, so it fits governance/oversight rather than risk process mechanics.


reasoning: The paragraph describes the company’s cybersecurity program and how it assesses and manages cybersecurity risks through controls and framework use, without centering a specific named cybersecurity leader. It also states Teladoc’s active HITRUST certification and SOC 2 Type II compliance, making the disclosure firm-specific.


reasoning: The paragraph describes the company’s technical safeguards as part of its cybersecurity approach; no board/committee or specific cybersecurity leader is the grammatical subject, nor is an incident being disclosed.


reasoning: The paragraph is centered on a named cybersecurity leader (“Head of Cybersecurity”) and describes their responsibilities as the grammatical subject of the main sentences.


reasoning: The paragraph identifies specific cybersecurity-related management roles (SVP/IT Manager and ISO) as the subjects responsible for duties, and describes the ISO’s qualifications and experience.


reasoning: The paragraph foregrounds specific cybersecurity leadership roles (CCO and CISO) as the grammatical subjects and details their qualifications and tenure, rather than describing a company-wide risk process.


reasoning: The paragraph’s central focus is third-party service provider dependency and monitoring of those providers’ cyber risk, which fits the Third-Party Risk category.


reasoning: The paragraph describes cybersecurity testing/measurement activities and ongoing support/consulting as part of the company’s cybersecurity program, but does not identify incident details or a named management role as the grammatical subject.


reasoning: The paragraph’s grammatical subject is a named cybersecurity management role (CIO) and it describes that role’s reporting line and responsibilities for the information security program.


reasoning: The paragraph describes Western Digital’s ERM process and the risk-management/mitigation approach to cybersecurity risk (identification, assessment, management, reporting, monitoring, and response plans). It does not foreground a specific cybersecurity management role or disclose an actual incident narrative.


reasoning: The paragraph centers on a named board subcommittee (“Cyber Security Subcommittee”) making an initial assessment regarding a potential cybersecurity incident and triggering executive team notice.


reasoning: The paragraph is centered on the CISO’s qualifications and responsibilities (and the COO’s board committee service), with the CISO as the grammatical subject for the core cyber-related duties. It also identifies a specific board committee (“Risk Committee”).


reasoning: The paragraph describes the company’s cybersecurity policies/programs/controls and ongoing process activities (prevention, monitoring, risk profiling, training) rather than focusing on a named management role, board oversight, a specific incident, or third-party security oversight as the central topic.


reasoning: The paragraph centers on a named governance body (Cybersecurity Council) and describes how it provides oversight/escalation information to senior management and ultimately the Board. It foregrounds the council’s structure, cadence, and reporting/escalation process rather than describing a cybersecurity leader’s personal role/qualifications as the primary subject.


reasoning: The paragraph describes the company’s cybersecurity risk assessment cadence and details of its cybersecurity risk management program (asset/threat identification, prevention/detection, third-party risk management, DLP, and effectiveness testing). No specific cybersecurity management role or board committee is the grammatical subject, so it fits Risk Management Process.


reasoning: The paragraph centers on named cybersecurity management roles (VP Security, CIO, Cybersecurity Incident Manager) assigning, evaluating, and managing incident response, with board/Audit Committee involvement described primarily as an output of those roles rather than as the primary subject.


reasoning: The paragraph focuses on due diligence and contract provisions during third-party procurement and contracting, which is vendor security oversight. No specific company details, named standards, roles, dates, or tools are provided.


reasoning: The paragraph is centered on the Technology Committee’s role and purpose in providing board oversight of technology and security/cyber risks and related recovery/resiliency plans, making board governance the grammatical focus.


reasoning: The paragraph is centered on a specific management role (Senior Director of Information Technology) delivering cyber-threat updates, with routing to executives and an Audit Committee. The rest describes generic internal-audit review over controls without cyber-specific or firm-unique details.


reasoning: The paragraph centers on a specific management role (“VP of IT and Facilities”) and describes that person’s responsibilities for cybersecurity oversight activities.


reasoning: The paragraph is largely forward-looking and generic risk language about potential cybersecurity attacks, with no described incident, no named roles/frameworks, and no firm-specific details to analyze.


reasoning: The paragraph centers on the CISO’s actions (providing updates and meeting with the IOC) and describes the CISO’s cybersecurity team’s responsibilities. This makes the CISO the grammatical subject and primary focus.


reasoning: The paragraph states that executive management considers and is ultimately responsible for overseeing cybersecurity strategy, but it provides no named cyber leader or any firm-unique governance/process details.


reasoning: The paragraph describes the company’s internal cybersecurity processes (monitoring, backup/recoverability, physical protection mechanisms, and review of third-party/cloud services) rather than an incident or a named cybersecurity leader/board body.


reasoning: The paragraph describes intended security/privacy awareness activities and control testing (design/operational effectiveness) but does not foreground any specific cybersecurity management role or board oversight, and it contains no firm-specific details.


reasoning: The paragraph describes how a risk assessment and safeguards would be structured (identifying foreseeable risks, evaluating likelihood/damage, and determining sufficiency of existing safeguards). It does not foreground any named management role, incident, or board oversight, and it contains no firm-specific identifiers or verifiable details.


reasoning: The paragraph describes the company’s cybersecurity protection activities (monitoring threats, using threat intelligence feeds/tools to mitigate risks) as an internal process, without foregrounding a specific management role or naming board oversight, incidents, or third parties.


reasoning: The paragraph describes the company’s incident detection/triage and response process as governed by an internal IT Security Incident Response Policy, but it does not foreground any cybersecurity management role as the main subject. It also mentions potential use of third-party advisors and cybersecurity insurance as components of the broader process/risk mitigation, without describing a real incident event.


reasoning: The paragraph is centered on the Audit Committee’s oversight/briefing role for cybersecurity risk and how it notifies/updates the board. It does not include any firm-specific details beyond generic governance language (and “Audit Committee” is treated as a standard, non-qualifying entity for extracted facts).


reasoning: The paragraph describes the company’s cybersecurity processes and capabilities (monitoring, detection, analysis, mitigation, response) rather than incident details or board/individual management roles. Mentions of third-party consultants are in support of overall preparedness and grid exercises, not as a stand-alone vendor oversight program.


reasoning: The paragraph describes the company's processes for assessing, identifying, and managing cybersecurity risks, including integration into ERM, with processes as the grammatical subject and no specific management roles foregrounded. Third-party risks are mentioned only as a component, not centrally.

provider: x-ai


reasoning: The paragraph provides a standalone materiality conclusion that cybersecurity threats have not materially affected the company to date, with no incident narrative, and cross-references risk factors, aligning with Strategy Integration per the tiebreakers.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity risks, including receiving presentations, incident updates, and annual discussions, with the Board as the primary grammatical subject. No specific management roles, processes, or incidents are foregrounded, fitting Board Governance clearly.


reasoning: The paragraph discusses general cybersecurity risks, potential adverse consequences, and concludes with a standalone materiality assessment that threats have not materially affected the company's business or financial condition, aligning with Strategy Integration. It contains no specific facts, named frameworks, roles, dates, or quantifiable details from the ✓ IS list, resulting in Generic Boilerplate.


reasoning: The paragraph focuses on the company's processes for identifying, assessing, and managing cybersecurity risks through a multi-stakeholder team and monitoring methods, with processes/programs as the primary grammatical subject. No specific management roles are foregrounded, and third-party involvement is a component of internal processes rather than the central topic.


reasoning: The paragraph describes the company's risk management processes, including the ERM program, ERA, risk assessment, monitoring, and reporting, with processes as the grammatical subjects. No specific management roles or board oversight are foregrounded, and it fits Risk Management Process as internal processes are central.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risks, including receiving reports from the ERM Committee, CIO, and VP Infrastructure, making the board committee the primary grammatical subject. Management roles are mentioned secondarily as report sources, aligning with Board Governance per tiebreakers.


reasoning: This paragraph is a cross-reference to the risk factors section in Item 1A, quoting generic boilerplate language about potential cybersecurity risks and consequences, with no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph centers on oversight of third-party service providers, including requirements for them to certify security measures and report breaches, making vendor security oversight the primary topic rather than general internal processes. No specific management roles, board, or incidents are foregrounded, and vendor requirements distinguish it from Risk Management Process.


reasoning: The paragraph describes the company's Information Security programs aligned to ISO and NIST frameworks, focusing on risk assessment, identification, and management processes, with the programs as the grammatical subject. No specific management roles, board oversight, incidents, or third-party focus is foregrounded.


reasoning: The paragraph provides a standalone materiality conclusion stating no prior material cybersecurity incidents have affected the company and future threats could be material, without describing any specific incident or processes. It includes forward-looking disclaimers and a cross-reference to risk factors, aligning with Strategy Integration per the tiebreakers.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risk management, including reviews and discussions with management (CIO and CISO), reporting to the Board, and handling of risks and incidents, making the board/committee the primary grammatical subject. Management roles are mentioned briefly as part of these oversight activities, not as the central focus.


reasoning: The paragraph focuses on specific management roles including the VP for IT Data Security and CTO, their reporting lines, responsibilities, and the composition of the Cybersecurity Committee, with board oversight only briefly mentioned at the start. This aligns with Management Role per the guidelines and tiebreakers.


reasoning: The paragraph details the company's cybersecurity program components, including incident response planning, risk assessments, monitoring, mitigation measures, training, and testing practices like vulnerability scanning and penetration testing, with processes/programs as the grammatical subjects. No specific management roles, board oversight, or vendor focus is foregrounded, and common practices do not qualify as firm-specific.


reasoning: The paragraph centers on the Information Security Officer (ISO) as the grammatical subject, detailing their reporting line to the CRO, qualifications, experience, and oversight responsibilities, fitting Management Role criteria where specific cybersecurity leaders are foregrounded.


reasoning: The paragraph centers on the board and Audit Committee's oversight of cybersecurity risks, including report cadences and content, with the committee as the primary grammatical subject. Specific cybersecurity-related IT leadership roles are named as reporters, providing firm-specific details without reaching Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's risk identification, assessment, threat intelligence review, control evaluation, and third-party risk mitigation processes, with processes/programs as the grammatical subjects and no specific management roles foregrounded. Vendor risks are mentioned as a component of internal processes, not the central topic.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risks, including monitoring through reports from management and reporting to the Board quarterly, with the Audit Committee and Board as the primary grammatical subjects, fitting Board Governance. No specific facts from the ✓ IS list are present (Audit Committee is standard/generic, quarterly is a generic cadence), resulting in Generic Boilerplate.


reasoning: The paragraph focuses on the Trustee's cyber risk management program, protocols, integration with overall risk management, employee training, and annual third-party assessment, with processes as the grammatical subject. No specific management roles, board oversight, or vendor risk as central topic; internal processes dominate.


reasoning: The paragraph focuses on the company's cybersecurity processes, including assessments, monitoring, team collaborations, policy integration, and layered defenses, with processes/programs as the primary grammatical subjects and no specific management roles foregrounded. It includes a specific departmental composition as a firm-unique fact, qualifying as Firm-Specific without two or more hard verifiable facts.


reasoning: The paragraph primarily describes the Board's oversight role in assessing and reviewing cybersecurity risks and processes, with the Board as the grammatical subject in most sentences; the HSE Director is mentioned as the program overseer with reporting to the Board, but board focus predominates per tiebreakers.


reasoning: The paragraph focuses on the company's risk management program, ERM integration, framework adoption (FFIEC), and overall processes for addressing cybersecurity risks, with the grammatical subjects being programs and processes; specific management roles like CISO are mentioned but not foregrounded as the primary subject.


reasoning: The paragraph focuses on the board of directors and audit committee's oversight of cybersecurity risks, including meetings with management and reporting to the full board, making board/committee the primary grammatical subjects. Management roles are mentioned briefly at the end but do not shift the main focus.


reasoning: The paragraph centers on the CDIO/CISO's role, reporting lines, experience, qualifications, and oversight responsibilities, with the named role as the primary grammatical subject, fitting Management Role. It includes multiple hard verifiable facts (specific year 2021 and four named prior firms), exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's processes for identifying, investigating, escalating, and reporting cybersecurity threats and incidents, with processes/programs as the grammatical subjects, fitting Risk Management Process. It contains firm-specific roles and named committees, qualifying as Firm-Specific, but lacks two or more hard verifiable facts (e.g., dates, dollars, headcounts) for Quantified-Verifiable.


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


reasoning: The paragraph focuses on the company's internal processes and programs such as incident response plans, tabletop exercises, training, and risk-based approaches, with 'The Company' or processes as the grammatical subject, fitting Risk Management Process; no specific management roles are foregrounded. No qualifying specific facts from the ✓ IS list (e.g., no named roles, committees, dates, firms, or unique programs), only generic practices and unnamed entities, confirming Generic Boilerplate.


reasoning: The paragraph describes the company's processes and procedures for cybersecurity incident identification, response, monitoring tools, and testing, with processes as the grammatical subject and no specific management roles foregrounded. It contains no named frameworks, roles, dates, firms, or other firm-specific facts, making it generic boilerplate.


reasoning: The paragraph briefly mentions past cybersecurity incidents without any description of events, dates, or scope, focusing instead on their immateriality and forward-looking materiality assessments of potential impacts on business and financial condition. This aligns with Strategy Integration per tiebreakers for materiality conclusions without incident narratives.


reasoning: The paragraph centers on the Board, Audit Committee, and especially the Cybersecurity Subcommittee's oversight of cybersecurity risks, with these entities as the primary grammatical subjects, clearly fitting Board Governance. It contains firm-specific facts like the named non-generic committee and its 2023 establishment date, but only one hard verifiable fact (date), qualifying as Firm-Specific.


reasoning: The paragraph centers on the Board of Directors and Audit Committee overseeing cybersecurity risks, receiving quarterly reports from management, and ad-hoc reporting via CEO/CFO, fitting Board Governance as the board/committee is the primary subject. No qualifying specific facts from the ✓ IS list (e.g., cybersecurity-specific roles, named non-generic committees, dates, or named entities); Audit Committee, CEO, CFO, and generic cadences are excluded per ✗ NOT list, yielding Generic Boilerplate.


reasoning: The paragraph details the IT Department's cybersecurity risk management policies, processes like vulnerability management, penetration testing, and third-party oversight as components of internal processes, with processes as the grammatical subject, fitting Risk Management Process; third-party is not central. It names the NIST Cybersecurity Framework but has no firm-specific facts beyond that.


reasoning: The paragraph foregrounds the CIO as the grammatical subject in reviewing risks, leading the response plan, and escalating incidents, with reporting to committees; per tiebreakers, management roles are the main focus despite brief committee mentions.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight of the cybersecurity program, with the board/committee as the primary grammatical subjects. It mentions the NIST framework but lacks firm-specific details beyond that.


reasoning: The paragraph focuses on the company's cybersecurity program, vulnerability/risk management processes, monitoring via a managed service provider, and an incident response plan aligned with NIST, with processes/programs as the primary grammatical subject, fitting Risk Management Process. The vendor is a minor component, not central, and board/Audit Committee are mentioned only briefly in escalation context.


reasoning: The paragraph centers on assessing and imposing security requirements on third-party providers, vendors, and consultants, including contractual terms, incident notification, encryption, and penetration studies, making vendor/supplier oversight the primary focus. No specific management roles or internal processes are foregrounded.


reasoning: The paragraph focuses on the company's processes for developing, implementing, reviewing cybersecurity controls, conducting risk assessments, and managing risks, with 'The Company' and processes as grammatical subjects; no management roles or board foregrounded. It names recognized security frameworks (CIS Controls, PCI DSS) but lacks firm-specific facts like dates, roles, or named programs.


reasoning: The paragraph describes the company's training programs and mechanisms for cybersecurity awareness and preparedness, with processes like the training program as the grammatical subject, fitting Risk Management Process. No specific management roles, board oversight, incidents, or third-parties are foregrounded. No qualifying specific facts (e.g., named roles, dates, numbers, frameworks) are present, confirming Generic Boilerplate.


reasoning: The paragraph details the company's information security program structured around NIST CSF functions, incident detection/response processes, operational plans, reviews, and exercises, making processes the grammatical subject with no management roles or board foregrounded. It names the NIST CSF framework but lacks firm-specific facts like roles, dates, or unique programs.


reasoning: The paragraph primarily discusses the absence of material cybersecurity incidents or costs to date and potential adverse business/financial impacts, qualifying as a standalone materiality assessment under Strategy Integration; the brief mention of generic incident response practices involving CEO and CFO does not shift it to Risk Management Process.


reasoning: The paragraph centers on the CISO as the grammatical subject, detailing their qualifications, experience, responsibilities, and team oversight, fitting 'Management Role' per the test for named management roles being foregrounded.


reasoning: The paragraph centers on the CISO, CITO, and Information Security team's roles, qualifications, experience, education, and reporting lines, making named management roles the grammatical subjects. It contains multiple hard verifiable facts including quantified experience years and named certifications, exceeding the threshold for Quantified-Verifiable.


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 post-incident response actions, fitting Incident Disclosure per tiebreakers. It meets Quantified-Verifiable with two hard facts: a specific date and a named system.


reasoning: The paragraph centers on the Director, IT Infrastructure & Security as the grammatical subject, detailing their leadership, qualifications, training, and reporting lines to specific executives, fitting Management Role; processes like CIRP are secondary and guided by named individuals.


reasoning: The paragraph details the company's cybersecurity program, its features, tools, processes, and alignment with standards, with the program and processes as the primary grammatical subjects, clearly fitting Risk Management Process. No specific management roles, board, or incidents are foregrounded, and third-party mention is peripheral.


reasoning: The paragraph focuses on the Board's delegation of cybersecurity risk oversight to the Audit Committee, management's reporting cadence to the Board and committees, and incident update processes, with the Board/committees as the primary grammatical subjects. No qualifying specific facts from the ✓ IS list are present (Audit Committee is standard/generic per ✗ NOT list), and no named frameworks, confirming Generic Boilerplate.


reasoning: The paragraph concludes that no cybersecurity threats in fiscal 2025 materially affected or are anticipated to affect business strategy, operations, or financial condition, which is a standalone materiality assessment fitting Strategy Integration. Vague references to past intrusions lack incident details, narrative, or scope, so not Incident Disclosure; cross-references are secondary.


reasoning: The paragraph focuses on the company's cybersecurity risk management program, its design using specific frameworks like NIST Cybersecurity Framework, and processes for identifying, assessing, and managing risks, with the program and 'we' as the grammatical subjects. No management roles, board, incidents, or third-party focus is foregrounded.


reasoning: This paragraph assesses the material impact of cybersecurity risks, stating no material past incidents, immaterial expenses, and no known future risks likely to materially affect the business, which aligns with Strategy Integration for materiality conclusions without incident narratives. It includes forward-looking disclaimers and a cross-reference to risk factors but focuses on business/financial impact assessments.


reasoning: The paragraph briefly mentions a past cybersecurity incident in August 2020 but focuses primarily on its immaterial impact on business and financial condition, forward-looking risks, and a cross-reference to risk factors, aligning with Strategy Integration per tiebreakers for brief incident mention + materiality conclusion.


reasoning: The paragraph focuses on the company's processes for assessing, identifying, and managing cybersecurity risks, with 'we' and 'processes' as the grammatical subjects, fitting Risk Management Process; no board, management roles, incidents, or third-party focus. No specific facts, named standards, roles, dates, or quantifiable details qualify it beyond generic boilerplate.


reasoning: The paragraph describes the company's internal processes for cybersecurity assessments, vulnerability management, patch management, disaster recovery, access controls, and threat monitoring performed by its technology team and operational risk group, with no specific management roles foregrounded. No firm-specific facts, named standards, roles, dates, or quantifiable details are present, making it generic boilerplate.


reasoning: This paragraph consists of forward-looking disclaimers and a cross-reference to Risk Factors, containing no substantive cybersecurity disclosure on governance, processes, roles, or incidents.


reasoning: The paragraph centers on the CISO as the leader of the ISC, detailing the CISO's experience, certifications, and role in cybersecurity risk management, with the named role as the primary grammatical subject. It includes firm-specific elements like the named non-generic committee (ISC), cybersecurity-specific role (CISO), quantified experience, and personal certifications, but lacks two or more hard verifiable facts (e.g., no dates, dollars, headcounts, named firms/tools) for Quantified-Verifiable.


reasoning: The paragraph focuses on the company's internal processes for engaging external experts for audits and assessments, employee training, and refining policies based on results, with processes as the grammatical subject and no specific management roles foregrounded. No qualifying specific facts or named standards are present, making it generic boilerplate.


reasoning: The paragraph describes company processes for employee training, third-party risk oversight (as a component including assessments and monitoring), and insurance maintenance, with processes as the grammatical subject. Third-party details are integrated into overall risk management rather than being the sole central topic.


reasoning: The paragraph focuses on the company's processes for assessing and managing cybersecurity risks, including alignment with NIST framework and integration into the ERM program, with processes/programs as the grammatical subjects. No specific management roles or board oversight are foregrounded, and teams are mentioned generically in support of processes.


reasoning: The paragraph describes the company's intended risk management program, processes for identification, assessment, and treatment of cybersecurity risks, integration into overall risk management, use of technologies, third-party consultants, and specific activities like vulnerability management and penetration testing, with processes as the primary grammatical subjects. No specific management roles are foregrounded, and board oversight is mentioned only briefly at the start.


reasoning: This paragraph provides a narrative of an actual cybersecurity incident, including the detection date, unauthorized access details, response actions (incident response protocols, containment, investigation, engaging expertise, notifying law enforcement), and operational disruption, directly matching Incident Disclosure criteria. It includes one verifiable specific date, making it Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: The paragraph describes the Board of Directors and Audit Committee's oversight of cybersecurity risks, including meeting cadences with the CSO, making the board/committee the primary grammatical subjects (Board Governance test). It includes the CSO as a cybersecurity-specific role (one firm-specific fact), but no named standards or two+ verifiable facts.


reasoning: This paragraph provides a detailed narrative of a specific cybersecurity incident, including the date of detection, unauthorized access, response actions (investigation, containment, external experts, law enforcement notification), and operational disruptions to IT systems and business applications, directly matching Incident Disclosure criteria.


reasoning: The paragraph focuses on the Enterprise Risk Management Committee's processes for identifying, measuring, monitoring, and controlling risks, including integration of cybersecurity reports and assessments, with the company's risk management program as the grammatical subject. Specific management roles like CISO and CDO are mentioned only briefly as contributors, not foregrounded.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the date, access method, data accessed (emails, usernames, phone numbers, hashed passwords, API keys, OAuth tokens, MFA), response actions (incident response process activation, investigation, containment, remediation), and scope limitations (no access to account contents, payments, or other products). This matches Incident Disclosure as it describes what happened in a real event with specifics.


reasoning: The paragraph details the timeline, scope (email accounts of senior leadership, cybersecurity, legal functions), actor (nation-state threat actor), and ongoing activities (access to source code repositories) of a specific cybersecurity incident, matching Incident Disclosure criteria. It contains one specific date and named team compositions, qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard verifiable fact.


reasoning: The paragraph describes a real cybersecurity incident with specifics on date, unauthorized access by a third party, response protocols, containment measures, business disruption, and remediation status, directly matching Incident Disclosure criteria over Strategy Integration as it includes event narrative and actions rather than just financial/materiality impacts.


reasoning: This paragraph details a specific cybersecurity incident including the detection date, unauthorized access description, response actions (activating incident response procedure, engaging external experts, notifying law enforcement), and operational disruptions to business applications and reporting systems, directly matching Incident Disclosure criteria.


reasoning: The paragraph centers on the VP of IT (a named cybersecurity-specific role) as the primary subject, detailing their responsibilities, experience, reporting lines, hiring, and the composition of the IT Executive Steering Committee and security team. Board and Audit Committee mentions are brief and secondary.


reasoning: The paragraph describes the scope of a specific cybersecurity incident (impacted IT systems, billing and label making functions, data stolen/destroyed), response actions (removal of third party, restoration via contingency plans and backups), and operational impact (operations continued), fitting Incident Disclosure. No specific verifiable facts like dates, names, or quantities are present, making it Generic Boilerplate.


reasoning: This paragraph describes a real cybersecurity incident, including what data was obtained (name, phone, address, email, order histories), scope (up to 33 million accounts), response (ongoing investigation, external experts), and regulatory actions, making it Incident Disclosure rather than Strategy Integration which lacks incident narrative.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including detection date, access start date, threat actor actions (access and exfiltration of data), scope of affected data/systems, and response actions like activating incident response and notifying authorities. This matches Incident Disclosure as it describes what happened in the event with dates and specifics, not just financial impacts.


reasoning: The paragraph focuses on the Chief Information Security Officer as the primary subject, detailing qualifications, experience, certifications, education, and reporting lines, with brief mentions of management and board. This fits Management Role per the test for named management roles as grammatical subjects.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including timelines, access method, scope (employee emails including senior leadership and functions like cybersecurity/legal), response actions (removal of access, investigations, notifications), and initial impact assessment, matching Incident Disclosure criteria. Multiple specific dates (late November 2023, January 12/13, 2024) qualify as two or more hard verifiable facts for Quantified-Verifiable specificity.