fact: Chief Information Security Officer (CISO)

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor oversight processes, which aligns with the Third-Party Risk category. Specificity is elevated to Firm-Specific due to the mention of the CISO role, a cybersecurity leadership position that distinguishes this company's disclosure.


content_category: Incident Disclosure

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily describes a specific cybersecurity incident (MOVEit Transfer), including investigation, notification, and impact, which answers 'What happened in a cybersecurity incident?' for Incident Disclosure. Specificity is Generic Boilerplate because the paragraph lacks any specific, verifiable facts or domain expertise beyond generic incident description; no facts elevate it above Level 1.

provider: xiaomi

stage: benchmark


content_category: Risk Management Process

fact: network and perimeter defense

fact: infrastructure security

fact: cloud security

fact: endpoint protection

fact: data protection

fact: identity management

fact: network segmentation

fact: cybersecurity assessments

fact: cybersecurity threat intelligence

reasoning: The paragraph primarily answers what the cybersecurity program does by describing tools, safeguards, and assessment processes, fitting Risk Management Process. It contains multiple domain-specific cybersecurity terms (e.g., network segmentation, endpoint protection) that demonstrate expertise beyond generic risk management, supporting Domain-Adapted specificity.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing its components and efforts to evaluate and improve security aspects, aligning with Risk Management Process. It contains no specific facts (e.g., firm-specific roles, verifiable claims, or domain terms that pass the ERM test), so specificity is Generic Boilerplate.


content_category: Management Role

reasoning: The paragraph primarily answers how the management team is informed and monitors cybersecurity risks, which is about management's role in handling cybersecurity, fitting Management Role. It contains no specific facts such as named roles, tools, or verifiable claims, so it is Generic Boilerplate.


fact: ransomware

fact: multi-factor authentication

reasoning: The paragraph primarily answers what happened in a specific cybersecurity incident (ransomware attack in May 2022, response steps, and impact), making Incident Disclosure the appropriate category. Specificity is driven by the verifiable date 'May 2022' (Level 4) and domain terms like ransomware and multi-factor authentication (Level 2), with the date being externally confirmable.


fact: phishing attempt

fact: phishing security test

fact: information security training

reasoning: The paragraph primarily describes cybersecurity program activities (employee training and phishing tests), fitting Risk Management Process; specificity is Level 2 due to domain-specific terms like 'phishing security test' that demonstrate cybersecurity expertise beyond generic ERM language.


reasoning: The paragraph primarily describes the company's cybersecurity program and its role in enterprise risk management, answering 'what does the cybersecurity program do?' for Risk Management Process; it contains no specific facts, making it generic boilerplate.


content_category: Board Governance

fact: Chief Technology Officer

reasoning: The paragraph primarily addresses board oversight of cybersecurity through reporting and education, fitting Board Governance. Specificity is elevated to Firm-Specific due to the mention of the company's Chief Technology Officer in a cybersecurity context, which is a verifiable leadership role unique to the firm.


reasoning: The paragraph primarily addresses board oversight of cybersecurity through delegation to the Audit Committee and reporting lines, fitting Board Governance; specificity is driven by the firm-specific title 'Senior Director of Governance & Information Security,' which distinguishes this company's cybersecurity leadership structure.


fact: Cybersecurity incident in August 2021

fact: Cybersecurity incident in January 2023

fact: Reference to Note 18 – Commitments and Contingencies for additional details

reasoning: The paragraph primarily answers what happened in specific cybersecurity incidents (August 2021 and January 2023), making it Incident Disclosure; specificity is driven by verifiable dates and a specific financial note reference, which are externally confirmable facts.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, focusing on the IT Lead's role and experience, which fits Management Role. No specific facts (e.g., verifiable claims, firm-specific roles, or domain expertise terms) are present, so specificity is Generic Boilerplate.


fact: over 15 years of experience in software development and security architecture

reasoning: The paragraph primarily describes the CTO's role and responsibilities in cybersecurity, answering how management is organized, so it falls under Management Role. Specificity is driven to Quantified-Verifiable by the externally verifiable claim of 'over 15 years of experience,' which can be checked against the CTO's background.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through committee structures, fitting Board Governance. It contains no specific facts, dates, numbers, or unique details, so specificity is Generic Boilerplate.


specificity_confidence: medium

reasoning: The paragraph primarily answers how the board oversees cybersecurity through reports and incident notification flows, fitting Board Governance. No specific facts (e.g., names, dates, verifiable claims, or firm-specific details) are present, and the domain terms used are generic boilerplate that do not demonstrate cybersecurity expertise beyond common governance language.


reasoning: The paragraph primarily answers what the cybersecurity program does regarding incident response planning and testing, aligning with Risk Management Process. It contains no specific facts that elevate specificity above generic boilerplate, as all terms (e.g., 'incident response plan,' 'crisis simulation exercises') are commonly confused and lack firm-specific or verifiable details.


fact: On February 21, 2024, Change Healthcare notified the company of a cybersecurity incident

reasoning: The paragraph primarily answers what happened in a specific cybersecurity incident (Change Healthcare notification on February 21, 2024, with response actions), fitting Incident Disclosure; it contains a verifiable fact (specific date and named entity) that elevates specificity to Level 4.


fact: security incident and event manager (SIEM) interface with behavioral analytics

fact: third-party experts for penetration testing and system security assessments

reasoning: The paragraph primarily describes cybersecurity processes and tools for incident identification and response, answering what the program does, so it fits Risk Management Process. Specificity is Level 2 due to domain-specific terms like SIEM and penetration testing, which demonstrate cybersecurity expertise beyond generic risk management language.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident response steps and processes, fitting Risk Management Process; it contains no domain-specific, firm-specific, or verifiable facts, using only generic terminology, so specificity is Level 1.


fact: Senior Manager of our Enterprise IT Security Risk and Compliance team

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing leadership roles, experience, and reporting lines, which aligns with Management Role; specificity is driven by the verifiable claim of 'over 20 years specializing in cybersecurity,' which is a hard lower-bound fact externally checkable.


fact: Vice President of IT & Digitization

reasoning: The paragraph primarily answers how management is organized for cybersecurity by describing the VP oversight and IT team responsibilities, fitting Management Role; specificity is driven by the firm-specific VP title, which distinguishes this company's cybersecurity leadership.


fact: continuous system monitoring

fact: threat detection

fact: cybersecurity assessments

reasoning: The paragraph primarily describes the company's cybersecurity program activities, such as evaluations and monitoring with third parties, which answers the Risk Management Process question; it contains domain-specific terms like 'threat detection' and 'cybersecurity assessments' that demonstrate cybersecurity expertise, driving Domain-Adapted specificity.


fact: NIST framework

fact: ISO framework

reasoning: The paragraph primarily answers how the board oversees cybersecurity and integrates it into ERM, fitting Board Governance; it contains domain-specific terms like NIST and ISO frameworks, which demonstrate cybersecurity expertise and elevate specificity to Domain-Adapted.


fact: access controls

fact: firewalls

fact: intrusion detection and prevention systems

fact: vulnerability and patch management processes

fact: phishing tests

reasoning: The paragraph primarily answers what the cybersecurity program does, describing risk assessments, controls, and tools, so it fits Risk Management Process. Specificity is Domain-Adapted because it contains cybersecurity-specific terms like intrusion detection and phishing tests that demonstrate expertise beyond generic risk management language.


fact: Chief Information Security Officer role

fact: 25 years of prior experience

fact: Certifications: CICA, PCIP, CISSP, CISA, CRISC

reasoning: The paragraph focuses on the CISO's responsibilities, experience, and credentials, directly answering how management is organized for cybersecurity, which is Management Role. Specificity is Level 4 due to verifiable claims like '25 years of prior experience' and named certifications that can be externally checked.


reasoning: The paragraph primarily addresses board oversight of cybersecurity, describing the Audit Committee and Board's purview and annual discussions with management, which fits Board Governance. It contains no specific facts—such as firm-specific roles, verifiable claims, or domain expertise beyond generic terms—so specificity is Generic Boilerplate.


fact: Energy Transfer's Chief Information Officer has more than 35 years of experience leading business technology functions

fact: Energy Transfer IT team has over 50 years of combined IT experience, including 20 years dedicated to cybersecurity

fact: Energy Transfer IT team holds certifications including GICSP, CISSP, and CEH

fact: USAC's IT leadership team has an average of over 25 years of experience in IT operations and over 10 years in IT security

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on roles and qualifications, which aligns with Management Role; specificity is driven by multiple verifiable facts such as specific years of experience and named certifications, elevating it to Level 4.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing the qualifications and experience of specific executive roles, fitting Management Role; for specificity, it contains no verifiable facts or domain-specific terms—the experience is soft-numbered ('approximately 20 years or more') and the roles are generic executive titles, so it is Generic Boilerplate.


fact: CISO role at VF

fact: CSBDO role at VF

fact: CISO has over thirty years of experience as a cybersecurity professional

reasoning: The paragraph primarily answers what the cybersecurity program does by describing systems, processes, training, and incident response, aligning with Risk Management Process; specificity is driven by the verifiable claim of the CISO's over thirty years of experience, which is externally checkable.


content_category: Strategy Integration

reasoning: The paragraph primarily answers how cybersecurity affects business outcomes, with assessments of past incident impacts and forward-looking risks about financial and operational effects, aligning with Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—making it generic boilerplate for specificity.


fact: February 13, 2023 disclosure of security breach

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by describing a specific real event on February 13, 2023, making it Incident Disclosure; specificity is Level 4 because the date is an externally verifiable fact.


fact: Served as CSO for Zebra since 2018

fact: Over 14 years of global executive cybersecurity experience

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CSO's role, responsibilities, and experience, which falls under Management Role. Specificity is Level 4 due to verifiable facts like the specific start date (2018) and quantified experience (over 14 years), which an external party could check.