fact: endpoint protection

fact: network segmentation

fact: identity management

fact: cloud security

fact: cybersecurity threat intelligence

reasoning: The paragraph describes cybersecurity program activities—tools, safeguards, and security domains—answering 'what does the program do?' (RMP). Multiple domain terms like endpoint protection, network segmentation, identity management, and threat intelligence pass the ERM test, elevating specificity to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does - tools, safeguards, security domains. RMP.

Specificity: Let me check for domain terms. "network and perimeter defense, infrastructure security, cloud security, endpoint protection, data protection, identity management and network segmentation" - several of these pass the ERM test: endpoint protection, network segmentation, identity management, cloud security, threat intelligence. These are cybersecurity-specific terms.

Any firm-specific facts? No named roles, no specific committees. No verifiable claims.

Level 2.


content_category: Board Governance

fact: RCSC (Regulatory Compliance/Risk Committee) as named board-level committee

fact: CISO provides updates to the board committee

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes how a board-level committee (RCSC) oversees cybersecurity through CISO briefings, squarely answering 'how does the board oversee cybersecurity?' → Board Governance. The RCSC is a named non-generic committee and CISO is a firm-specific leadership role, elevating to Level 3, but no verifiable claims (quarterly is generic cadence, no specific dates or certifications).

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

This is about the RCSC (a board-level committee) receiving reports from the CISO about cybersecurity. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- RCSC (Regulatory Compliance & Sustainability Committee or Risk Committee) - named committee, but need to check if this is a board-level committee. Given context it's a board committee receiving CISO reports → BG
- CISO - named role (firm-specific)
- "quarterly updates" - generic cadence, not firm-specific

- The report contents (threat landscape, key initiatives, legal/regulatory landscape, incident overviews) describe what information flows to the board, and both the CISO and RCSC are firm-specific named entities, making this Level 3.


content_category: Strategy Integration

reasoning: This paragraph states a backward-looking materiality conclusion ('have materially affected... business strategy, results of operations, or financial condition'), triggering the SI materiality rule. No specific facts elevate specificity — the negative self-assertion about no material impact is not externally verifiable.

thinking: SI materiality rule applies here.


content_category: Third-Party Risk

fact: data security addendum required for vendors

fact: cybersecurity insurance requirement for vendors

fact: mandatory incident reporting protocols for vendors

fact: administrative, physical, and technical safeguards

specificity_confidence: medium

reasoning: The paragraph centrally addresses requirements imposed ON vendors (security protections, data security addendum, insurance, incident reporting), making it Third-Party Risk. The mention of specific safeguard categories (administrative, physical, technical), cybersecurity insurance requirements, and mandatory incident reporting protocols demonstrate domain knowledge beyond generic ERM language, reaching Level 2. The 'data security addendum' is a firm-specific-sounding term but is fairly generic in practice; no named roles, verifiable claims, or firm-unique identifiers push it higher.

thinking: Third-party vendor management is the central topic.


fact: CISO provides a cybersecurity dashboard reviewed at every regularly scheduled Board meeting

fact: CIO role referenced in cybersecurity oversight context

fact: Dashboard includes KPIs for cybersecurity process maturity, operational performance, and enterprise performance toward TSA compliance

fact: Transportation Security Administration (TSA) compliance

type: framework

fact: CIO and/or CISO presents to the Board bi-annually

fact: CIO presents to the Audit Committee bi-annually

reasoning: The paragraph is squarely about how the Board and Audit Committee oversee cybersecurity through briefings, dashboards, and escalation protocols — classic Board Governance. Specificity reaches Level 3 via firm-specific roles (CISO, CIO) and distinguishing program details like the cybersecurity dashboard with KPIs tied to TSA compliance, which narrows this to a pipeline/transportation company. No externally verifiable quantified claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, CISO dashboard, Board meetings, KPIs, TSA compliance, CIO/CISO presentations, Audit Committee role, incident escalation to Board.

Category: Board Governance - clearly about how the board oversees cybersecurity.

Specific facts:
- CISO (named role, firm-specific)
- CIO (named role, firm-specific)
- Cybersecurity dashboard with KPIs (firm-specific program detail)

- TSA compliance (domain term / framework, specific to pipeline/transportation companies)
- Audit Committee (generic governance structure)
- Bi-annual presentations to both Board and Audit Committee
- Dashboard reviewed at every regularly scheduled Board meeting
- KPIs tracking cybersecurity process maturity, operational performance, and progress toward TSA compliance (firm-specific metrics)

The CISO and CIO are VP-level firm-specific roles, while TSA is a named regulatory framework that applies to this industry.


content_category: Management Role

fact: Chief Information Officer (CIO) role responsible for cybersecurity

fact: CIO is a member of the Company's Executive Committee

fact: Chief Information Security Officer (CISO) role responsible for cybersecurity

reasoning: The paragraph is headed 'management's responsibility' and primarily identifies WHO is responsible (CIO, CISO) and their organizational positioning (Executive Committee membership); applying the person-removal test, only generic risk-management language remains, confirming MR. Specificity reaches Level 3 via firm-specific named roles (CIO, CISO) and the CIO's Executive Committee membership, but no verifiable claims push it to Level 4.

thinking:
Classify this paragraph.

The paragraph describes management roles (CIO, CISO) and their responsibilities for cybersecurity. It also mentions a risk-based approach and cybersecurity controls.

Person-removal test: Remove CIO, CISO, Executive Committee membership. What remains? "The Company takes a risk-based approach to cybersecurity and has implemented cybersecurity controls designed to address cybersecurity threats and risks... responsible for assessing and managing cybersecurity risks, including the prevention, mitigation, detection, and remediation of cybersecurity incidents." Some program description remains but it's generic.

The core of this is really about the organizational structure and who holds responsibility—the CIO and CISO roles, their positioning on the Executive Committee. That's what makes it firm-specific. The actual cybersecurity processes and controls are just standard industry language, so this is clearly MR material. The named roles and committee membership are the distinguishing factors here.


reasoning: The first sentence is a cross-reference to Item 1A, which alone would be N/O, but the second sentence makes a backward-looking negative materiality assertion ('have not experienced any material cybersecurity incidents') which triggers SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—'last three fiscal years' is a soft timeframe and the negative assertion is not externally verifiable.

thinking:
Cross-reference to Item 1A plus negative assertion about no material incidents.

The first sentence is a cross-reference pointing to Item 1A. The second sentence is "have not experienced any material cybersecurity incidents" - this is a backward-looking negative assertion about materiality → SI per Rule 5.

Specificity: "In the last three fiscal years" + "have not experienced any material cybersecurity incidents" - negative self-assertion, not externally verifiable. "last three fiscal years" is a soft timeframe. No domain terms, no firm-specific facts, no verifiable claims. This is essentially a cross-reference + materiality assertion. The cross-reference part would be N/O, but the materiality assertion makes it SI.

The cross-reference itself is N/O, but the negative assertion about material incidents is SI per Rule 5. Since the disclosure contains both elements, the SI classification wins out. There are no specific domain terms or firm-specific facts here—just a soft timeframe and a self-reported negative claim that lacks external verification.


content_category: Risk Management Process

fact: Enterprise Cybersecurity team

fact: CISSP certification held by team members

fact: GICSP certification held by team members

fact: Cybersecurity and Infrastructure Security Agency (CISA)

fact: threat intelligence

fact: network monitoring

fact: vulnerability scanning

reasoning: Person-removal test: removing team references leaves substantial program description (threat intelligence sources, monitoring, scanning) → RMP. Specificity reaches Level 4 because CISSP and GICSP are specifically named certifications verifiable via (ISC)² and GIAC registries, and E-ISAC and CISA are named external organizations.

thinking:
Let me analyze this paragraph.

Content: Describes TEP's Enterprise Cybersecurity team, their certifications, threat intelligence sources, and activities.

Category: The paragraph starts by mentioning the team but the bulk describes what the program does (threat intelligence, monitoring, scanning). Person-removal test: remove team composition → substantial program description remains (threat intelligence sources, tools, activities). → RMP

Specific facts:
- "Enterprise Cybersecurity team" → named_team (firm-specific)
- CISSP certification → verifiable

- GICSP certification → verifiable
- Electricity Information Sharing and Analysis Center (E-ISAC) → named external org
- CISA → named external org
- Network monitoring, vulnerability scanning → domain terms
- Threat intelligence → domain term

The certifications are independently verifiable through their respective bodies, though the claim here is about unnamed team members holding them rather than specific individuals. The verifiability remains intact even without naming the particular people who hold these credentials.

Level 4.


fact: SOC 1 audit

fact: IT security and business process controls review of SOC 1 reports

reasoning: The paragraph is entirely about requirements imposed on third-party service providers (SOC 1 audit mandate, waiver process, report review), making Third-Party Risk the clear category per Rule 3. SOC 1 is a specific audit framework that passes the ERM test, elevating to Level 2, but there are no firm-specific facts (no named roles, committees, or verifiable claims) to reach Level 3.

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

Specific facts: SOC 1 audit (domain term/framework), annual SOC 1 audit requirement for key third-party providers.

SOC 1 is a specific audit framework - domain term. The paragraph describes requirements imposed ON vendors (annual SOC 1 audit mandate), so this is TP per Rule 3.

"annual SOC 1 audit" - SOC 1 is a specific framework/standard. This passes the ERM test as it's a specific type of audit report.

No firm-specific facts beyond generic practices. No named roles, no verifiable claims.

The mandate requiring key third-party service providers to undergo annual SOC 1 audits is a Level 2 reference to the framework itself, and while there's mention of a waiver process, it's too generic to distinguish the firm's approach.


fact: Eversource's Cyber Security Group performs vendor screening

fact: Vendors are risk ranked based on the type of work being performed

fact: Company bars sourcing from countries on the Department of Homeland Security's list of Prohibited Nations

fact: Cyber insurance covers breaches of networks and operational technology

fact: Eversource identified as parent entity performing screening

category_confidence: medium

reasoning: The majority of the paragraph describes vendor screening processes—risk ranking, rescreening of critical vendors, attestation requirements, and DHS prohibited nation sourcing restrictions—making Third-Party Risk the central topic, though cyber insurance is also mentioned. Specificity reaches Level 3 due to firm-specific facts like the named 'Cyber Security Group' and the specific DHS Prohibited Nations sourcing policy, but no externally verifiable quantified claims push it to Level 4.

thinking:
Classify this paragraph.

Content: Third-party vendor screening, risk ranking, rescreening, attestation requirements, DHS prohibited nations, cyber insurance.

Category: The central topic is third-party vendor management processes. But it also covers cyber insurance at the end. The majority of text is about vendor screening → Third-Party Risk.

Wait, let me re-read. About half is vendor screening, then it shifts to cyber insurance and coverage adequacy. The vendor content is dominant (first ~60% of paragraph). TP wins.

Specific facts:
- "Cyber Security Group" → named team (firm-specific)

- "risk ranked based on type of work" → process description
- "Department of Homeland Security's list of Prohibited Nations" → named external reference (verifiable)
- "cyber insurance which covers breaches of networks and operational technology" → domain term (operational technology)
- Vendor attestation to business continuity, insurance, indemnification → process
- "Eversource" → named firm (parent company)

The paragraph pulls in multiple verifiable references like the DHS prohibited nations list and specific operational details around insurance coverage and attestation requirements, which grounds this in concrete vendor management practices rather than general principles.


fact: CISO chairs the Security and Technology Risk Leadership Committee

fact: Privacy and Data Governance Committee

fact: Chief Privacy Officer chairs the Privacy and Data Governance Committee

fact: Data Security and Privacy Governance Committee (reporting target)

reasoning: The paragraph describes management-level committee structures, their chairs, composition, and reporting lines — organizational structure per Rule 1 (management-level committees → MR). Multiple named committees and named roles (CISO, CPO) make this firmly Firm-Specific; 'approximately 20 departments' is a soft number that fails the verifiability test.

thinking:
Let me analyze this paragraph.

Content: Describes two management-level committees - Security and Technology Risk Leadership Committee and Privacy and Data Governance Committee - their chairs, composition, meeting frequency, and reporting to a higher committee.

Category: These are management-level committees describing structure/membership → MR per Rule 1.

Specific facts:
- "Security and Technology Risk Leadership Committee" - named committee (firm-specific)
- "CISO" - named role (firm-specific)
- "Privacy and Data Governance Committee" - named committee (firm-specific)
- "Chief Privacy Officer" - named role (firm-specific)

- "Data Security and Privacy Governance Committee" - another named committee (firm-specific)
- "approximately 20 departments" - soft number, not verifiable
- "monthly or every other month" - generic cadence

The specificity here is Level 3 since we have multiple named committees and roles, though the soft number and generic meeting frequency keep it from reaching Level 4.


reasoning: The paragraph opens with a backward-looking materiality assessment ('cybersecurity risks have not materially affected our business or our results of operations'), which is the hallmark of Strategy Integration under Rule 5. The remainder is generic forward-looking risk language and a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present—the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Strategy Integration - backward-looking materiality assessment plus forward-looking risk language and cross-reference.

The key sentence: "cybersecurity risks have not materially affected our business or our results of operations" → SI (backward-looking materiality assessment per Rule 5).

Specificity: The materiality statement is a negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts. This is Generic Boilerplate level... but wait, the cross-reference names a specific risk factor title. That's not really a domain term or firm-specific cybersecurity fact.

Actually, the negative materiality assertion "have not materially affected" is SI content but for specificity it's a negative self-assertion (not verifiable per rules).

The cross-reference to Item 1A pulls in N/O-type content with no domain terms that satisfy the ERM test, so that lands at Level 1.


reasoning: The paragraph is centrally about managing third-party cybersecurity risk — vendor assessments, reassessments, and contractual security requirements — making Third-Party Risk the clear category. The vocabulary ('risk-based approach,' 'formal risk assessments,' 'contractual language,' 'data security controls and policies') is standard enterprise risk management language that a non-security ERM professional would naturally use about any vendor risk domain; no cybersecurity-specific domain terms pass the ERM test, keeping this at Level 1.

thinking:
Let me analyze this paragraph.

Category: This is centrally about how third-party cyber risks are managed - vendor assessments, reassessments, contractual requirements. → Third-Party Risk

Specificity: Let me scan for facts.
- "Cybersecurity team" - named team with security qualifier → firm-specific
- "risk-based approach" - generic
- "formal risk assessments" - generic process
- "data security controls" - domain term? Borderline, but fairly generic
- "risk assessment and rating process" - generic
- Contractual language about data collection, use, sharing, retention, security terms - this is about vendor oversight

- "Cybersecurity team" is pretty generic - most companies have one, so that's not really firm-specific. "Data security controls" is borderline - it's domain-specific language an ERM professional would recognize, but it's not particularly distinctive to this organization. The paragraph is mostly describing standard vendor risk management processes without revealing anything unique about how this firm operates. The phrase "data security controls" does suggest some domain awareness, but it's still fairly surface-level—the overall tone and vocabulary remain solidly in generic ERM territory, so I'm settling on Level 1.


reasoning: The paragraph contains a backward-looking materiality assessment ('prior cybersecurity threats have not materially affected our business strategy, results of operations or financial condition'), which is the hallmark of Strategy Integration per Rule 5. The remaining content is generic speculation ('could be negatively impacted') and a cross-reference to Item 1A. No domain terms pass the ERM test—threat types like 'cyber-attack, cyber intrusion, insider threats, supply chain incidents' are standard risk language any ERM professional would use—and the negative materiality assertion is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

The paragraph contains:
1. "prior cybersecurity threats have not materially affected our business strategy, results of operations or financial condition" — this is a backward-looking materiality assessment → SI
2. "we could be negatively impacted by a cybersecurity breach" — speculation, not SI
3. Cross-reference to Item 1A

The materiality assessment is the key substantive claim here → Strategy Integration per Rule 5.

Specificity: The materiality statement "have not materially affected our business strategy, results of operations or financial condition" is a negative self-assertion — not externally verifiable.

The threat categories mentioned—cyber-attacks, intrusions, insider threats, supply chain incidents—are fairly standard risk terminology that an ERM professional would use, so they don't rise to specialized domain language. The backward-looking claim about materiality is what matters here, keeping this at Level 1.


reasoning: The first sentence states a backward-looking materiality conclusion ('has not experienced any material impacts to our business, operations, or reputation due to cyberattacks'), which is an SI assessment under Rule 5. However, 'have not experienced material impacts' is a negative self-assertion that is not externally verifiable, and the remainder is generic forward-looking commitment language with no domain terms, firm-specific facts, or verifiable claims.

thinking: Materiality assessment paragraph.


fact: John Bresney, EVP & CIO

fact: Christopher Cunniff, SVP and CRO

fact: Bresney employed approximately 30 years

type: quantified

fact: McKenna employed approximately 21 years

fact: McKenna has over 27 years of technology and information security experience

fact: Cunniff employed approximately six years

fact: Cunniff has over 32 years of insurance industry experience

fact: Columbia University CIO Program Certificate (Bresney)

fact: Certified Insurance Counselor (McKenna)

fact: Fellow of the Casualty Actuarial Society (Cunniff)

fact: Member of the American Academy of Actuaries (Cunniff)

fact: Security Incident Response Plan ("IRP")

fact: Quarterly updates to the Board's Risk Committee

fact: Emerging Risk Committee

fact: ERC (Enterprise Risk Committee)

reasoning: The paragraph is overwhelmingly about management roles — named individuals, their titles, reporting lines, qualifications, and career histories — making it clearly MR. Specificity is Level 4 due to numerous externally verifiable facts: named professional certifications (Certified Insurance Counselor, Fellow of the Casualty Actuarial Society, American Academy of Actuaries membership, Columbia University CIO Program Certificate) and specific quantified experience claims (30 years, 21 years, 27 years, 32 years).

thinking:
This is a detailed paragraph about management roles and qualifications.

Category: Management Role - describes leadership roles, qualifications, credentials, career history, reporting lines.

Specificity: Contains many verifiable facts - named individuals, specific years of experience, named certifications, specific titles.

Let me list the specific facts:
- John Bresney, EVP & CIO (named individual + named role)
- Reports to CEO
- ~30 years employment
- Bachelor's in information systems and business

- Master's Certificate in Project Management
- Columbia University CIO Program Certificate (verifiable)
- Robert McKenna, SVP of Enterprise Strategy and Execution (named individual + role)
- Reports to CIO
- ~21 years employment
- Over 27 years of technology and information security experience
- Master's degree in business administration
- Certificate in Project Management
- Certified Insurance Counselor (verifiable certification)
- Christopher Cunniff, SVP and CRO
- Reports to CFO
- ~6 years employment
- Over 32 years insurance industry experience
- Bachelor's in mathematics
- Fellow of the Casualty Actuarial Society (verifiable)
- Member of the American Academy of Actuaries (verifiable)
- Security Incident Response Plan ("IRP") (named program)

I'm seeing a strong credibility profile here with multiple verifiable certifications, specific named individuals in executive roles, and documented experience spanning decades. This looks like a Level 4 assessment based on the density of concrete, checkable facts.


content_category: Incident Disclosure

fact: MOVEit Transfer (named product involved in incident)

fact: Progress Software Corporation (named vendor)

fact: Incident occurred/discovered during 2023

fact: Online and mobile banking customers potentially had personal information copied

fact: Vendor implemented recommended patches released by Progress Software Corporation

fact: Cyber insurance expected to cover many costs

fact: Only cybersecurity incident that materially affected the Corporation during 2023 fiscal year

reasoning: The paragraph describes a real cybersecurity incident — the MOVEit Transfer breach — including timeline, scope, remediation, and impact, making it Incident Disclosure. It names Progress Software Corporation and the MOVEit Transfer product, both externally verifiable entities tied to a well-documented global incident, pushing specificity to Quantified-Verifiable.

thinking: Incident disclosure about MOVEit Transfer breach, with named entities and specific details.


reasoning: The paragraph frames cybersecurity governance as important for alignment with business objectives and regulatory compliance, loosely answering the 'how does the board oversee cybersecurity' question, though it is purely introductory with no substantive detail. No domain terms pass the ERM test, no firm-specific facts, and no verifiable claims, placing it at Level 1.

thinking:
Classify this paragraph.

This is a general statement about cybersecurity governance importance. No specific facts, no domain terms beyond generic "cybersecurity program." It's introductory/framing language.

Category: This talks about governance importance and alignment with business objectives. It's really just an introductory statement - could be BG or N/O. It mentions governance oversight conceptually but doesn't describe HOW the board oversees. It's more of a preamble. But it does reference "Utilities' cybersecurity program" aligning with objectives and regulations - this is a framing statement about governance importance. I'll call it Board Governance since it's about cybersecurity governance structure/importance, though it's quite generic.

I'm reconsidering whether this is truly Board Governance or just a generic preamble that doesn't substantively address governance. The paragraph frames cybersecurity governance as important and mentions the Utilities' program aligning with regulations, which leans toward BG, but it's borderline with N/O since it lacks specificity and doesn't explain how governance actually functions. I'll stick with Board Governance as the classification since it's setting up the governance discussion, though it's thin on detail. On specificity, there are no domain terms that would pass an ERM test and no firm-specific facts beyond a generic reference to the company's subsidiaries.


fact: defense-in-depth approach

fact: National Institute of Standards and Technology Cyber Security Framework (NIST CSF) alignment

fact: vulnerability scanning

fact: penetration testing

fact: endpoint technology including encryption, threat management, monitoring, investigation support, and backups

fact: identity and access management controls

fact: multi-factor authentication

fact: elevated privileges safeguards

fact: cyber risk scoring for third parties

fact: Named internal program: "Written Information Security Program"

reasoning: The paragraph primarily answers what the cybersecurity program does, describing six key focus areas of security operations, making it RMP. While it mentions third-party risk management and a materiality-adjacent statement, these are subordinate to the overall program description. Specificity reaches Firm-Specific due to the named 'Written Information Security Program' as a distinguishing internal program identifier, atop extensive domain terminology (defense-in-depth, NIST CSF, vulnerability scanning, penetration testing, MFA, endpoint technology, IAM, cyber risk scoring).

thinking:
Let me analyze this paragraph.

Content category: This describes what the cybersecurity program does - defense-in-depth approach, security measures, six key areas of focus. It also mentions third-party risk management but as one of six areas. The primary question answered is "What does the cybersecurity program do?" → RMP.

There's a materiality statement: "is reasonably likely to defend against risks of cybersecurity threats that would have a material impact on our business strategy, results of operations, or financial condition" - this is not quite the standard SI materiality assessment. It's describing the program's capability, not stating a conclusion about whether cybersecurity has affected business outcomes.

Looking at this more carefully, the language about defending against risks is really about program effectiveness rather than a materiality conclusion, so this falls under RMP. Now I'm examining the specificity of what's mentioned - there are concrete technical controls and frameworks referenced like NIST CSF, the Written Information Security Program, vulnerability scanning, penetration testing, encryption, multi-factor authentication, and identity and access management controls, plus incident response and disaster recovery exercises.

The Written Information Security Program is the key here - it's a named internal program with a specific identifier, which pushes this to Level 3. There aren't any verifiable claims like specific numbers or certifications, and the alignment with NIST CSF reads more as an aspiration than something concrete. So this is Level 3 - Firm-Specific.


fact: confidentiality, integrity and availability (CIA triad)

reasoning: The paragraph describes having policies, procedures, and systems to identify and address cybersecurity risks, which answers what the program does (RMP). The CIA triad reference ('confidentiality, integrity and availability') is a foundational information security concept that passes the ERM test, elevating to Level 2, though the rest is generic boilerplate.

thinking:
Classify this paragraph.

Content: Generic statement about recognizing importance of information security and having policies/procedures to address cyber risks.

Category: This is about what the cybersecurity program does (RMP), but it's extremely generic. It describes having "policies, procedures, and systems" to "identify and address material risks." This is RMP.

Specificity: "confidentiality, integrity and availability" - this is the CIA triad, a fundamental infosec concept. Does it pass the ERM test? CIA triad is a core information security concept that a non-security ERM professional wouldn't naturally use. Actually, "confidentiality, integrity and availability" is pretty widely known...

The CIA triad is still domain-specific terminology from information security, even if somewhat familiar. Most of the language here is generic—"intellectual property," "policies, procedures, and systems," and "identify and address material risks" are all standard ERM phrasing. The CIA triad reference is the only element that signals domain expertise, so I'm rating this Level 2.


fact: Reference to 'Previously Disclosed Cyber Incident' — a specific real incident

reasoning: The paragraph makes both a backward-looking materiality conclusion ('have materially affected us, including our results of operations and financial condition') and a forward-looking one ('reasonably likely to materially affect us'), which are classic SI materiality assessments under Rule 5. While it references a real incident, the frame is financial impact, not incident details, so SI wins per Rule 4. The reference to a specific 'Previously Disclosed Cyber Incident' is a firm-specific fact distinguishing this company, elevating to Level 3, but the negative-assertion/self-reported nature and lack of verifiable hard numbers keeps it below Level 4.

thinking: This paragraph makes explicit materiality assessments both backward-looking and forward-looking, plus references a real incident.


fact: S&T Information Security Program

fact: defense in depth strategy

fact: data loss prevention technology

fact: transport layer security encryption

fact: phishing, malware and social engineering testing

reasoning: The paragraph describes specific cybersecurity program activities — encryption, DLP, training — making it RMP. The named 'S&T Information Security Program' is a firm-specific identifier, and multiple domain terms (defense in depth, DLP, TLS, phishing/malware/social engineering) elevate beyond boilerplate, with the named program pushing to Level 3.

thinking:
RMP - describes what the program does (defense in depth, encryption, DLP, training)

Specific facts: defense in depth, data loss prevention, transport layer security encryption, phishing, malware, social engineering, "S&T Information Security Program" (named program)


content_category: None/Other

reasoning: The paragraph describes the general cyber threat landscape (ransomware, phishing, nation-state threats) without answering any of the six substantive questions—it discloses no program activity, governance structure, management role, incident, or materiality assessment. While domain terms like ransomware and phishing are present, None/Other paragraphs receive Generic Boilerplate per the rules.

thinking:
Classify this paragraph.

Content: Discusses cyber risk landscape - threat actors, ransomware, phishing, nation state threats. This is general risk discussion, not describing what the company's program does, not governance, not an incident. It's generic risk landscape commentary.

Does it answer any of the six questions? Not really. It's contextual/environmental risk discussion. Could be Strategy Integration if it assesses materiality impact, but it doesn't make a materiality assessment. It's more of a general risk landscape description.

This feels like None/Other or possibly RMP context. But it doesn't describe any process, governance, management role, or incident.

The paragraph is fundamentally general threat environment commentary without substantive answers to the classification questions. It mentions specific threat types like ransomware and phishing, which gives it some domain specificity, but the rules dictate that None/Other paragraphs default to Generic Boilerplate regardless. So this is None/Other, Generic Boilerplate.


fact: cyber incident response plan

fact: cybersecurity risk insurance policy

fact: CISO

fact: CSBDO (Chief Strategy and Digital Business Officer)

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

fact: CISO has experience as the CISO of two large retailers

fact: CSBDO has nearly twenty years of experience enabling digital transformation

fact: VF associates with access to confidential information receive training at least annually

reasoning: The paragraph primarily describes what VF Corp's cybersecurity program does—detection, training, incident response, insurance—making it RMP despite touching on roles and third parties. 'Over thirty years of experience' for the CISO is a verifiable lower-bound claim, driving specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This is a dense paragraph covering multiple topics. Let me break it down:
- Securing information, systems to detect/respond to incidents → RMP
- Third-party risk management → TP (but brief)
- Training program → RMP
- CISO and CSBDO roles, experience → MR
- Cyber incident response plan → RMP
- Engaging service providers → RMP
- Cybersecurity insurance → SI

The bulk is about what the program does (RMP activities). The person-removal test: removing CISO/CSBDO details, there's still substantial program description. → RMP

Now I'm looking at the specificity markers in the text. The named roles like CISO and CSBDO are firm-specific, and the experience claims—"over thirty years" and "nearly twenty years"—are quantified and verifiable, though the latter is hedged. I also see domain-specific terms like "cyber incident response plan" and "cybersecurity risk insurance policy," plus references to risk assessments and training cadence.

The key distinction is that "over thirty" establishes a clear lower bound that's verifiable, while "nearly twenty" is softer and directional without a hard floor. This pushes the classification to Level 4 based on the thirty-year claim.


fact: CIO leads the DTI organization

fact: CISO leads the CDT function

fact: DTI organization (named internal organization)

fact: CDT team (named cybersecurity team responsible for monitoring, detection, mitigation, remediation)

fact: Incident Response team includes CISO and senior CDT members

reasoning: Applying the person-removal test, substantive program activities remain: monitoring/detecting threats, mitigation/remediation, severity evaluation, and incident escalation processes — pointing to RMP over MR. The named internal organizations (DTI, CDT) and leadership roles (CIO, CISO) are firm-specific identifiers that elevate to Level 3, but no externally verifiable claims are present.

thinking:
Let me analyze this paragraph.

Category: This describes how management is organized - CIO, CISO, CDT team, incident response team, reporting lines. But it also describes what the program does (monitoring, detecting, mitigating, remediating). Let me apply the person-removal test.

Remove person-specific content (CIO, CISO, CDT team roles, Incident Response team membership): "monitoring and detecting cybersecurity threats and incidents... mitigation and remediation of cybersecurity incidents... when a cybersecurity threat or incident is detected or encountered by a third-party service provider, the discovery is communicated... evaluates the severity..."

The core issue is whether this is really about organizational structure or the actual program activities. Reading it again, the paragraph is fundamentally answering "how is management organized to handle cybersecurity?" - it's structured around roles, responsibilities, and how information flows between them. Even though monitoring and detection activities are mentioned, they're really just illustrating what those roles do. When I strip away the people and positions, I'm left with fragments of activities, but the paragraph's main purpose is explaining the organizational hierarchy and escalation process. So this leans toward organizational structure rather than substantive program description.

But actually, the activities themselves—monitoring threats, detecting incidents, mitigation, remediation, severity evaluation—those are substantive regardless of who's doing them. The escalation process and incident response procedures are real program elements. So I think this does qualify as RMP after all, with the organizational details just providing context for how the program operates.

Looking at specificity: the CIO and CISO are clearly firm-specific named roles. The CDT and DTI teams are firm-specific internal teams. The Incident Response team is named but somewhat generic. The actual activities—monitoring, detecting, mitigating—are generic. There are no verifiable facts like numbers, certifications, or product names. This puts it at Level 3, Firm-Specific.


reasoning: This is a section header followed by generic risk language ('could disrupt,' 'could damage,' 'could cause losses') without describing any actual cybersecurity processes, governance, or measures. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: It's a section header followed by generic statements about operational dependency on secure transactions and risks of breaches. No specific processes, no specific people, no specific incidents. It's mostly introductory/risk language.

Category: This reads like a section header + generic risk language. It doesn't describe any actual processes, governance, or incidents. The "could disrupt... damage... increase... cause" language is speculative risk framing. This is borderline N/O or RMP intro. But it doesn't actually describe any cybersecurity measures. It's a section header with generic risk language. → None/Other.

The paragraph mentions operational dependence on secure financial transactions but offers only speculative risk language without describing actual cybersecurity measures or firm-specific details. It's generic boilerplate with no verifiable claims or domain-specific terminology.


reasoning: The paragraph contains both a backward-looking materiality assessment ('do not believe...materially adversely affected') and a forward-looking SEC 106(b)(2) assessment ('reasonably likely to materially affect'), making SI the clear primary category. Specificity is Level 1 because there are no domain terms, firm-specific facts, or verifiable claims—just standard materiality language and a cross-reference to Item 1A.

thinking:
This paragraph contains multiple elements. Let me analyze:

1. "We do not believe that our business strategy, results of operations or financial condition have been materially adversely affected by any cybersecurity incidents" — backward-looking materiality assessment → SI
2. "cybersecurity threats are pervasive" — general statement
3. "face risks from certain cybersecurity threats that, if realized, are reasonably likely to materially affect" — SEC Item 106(b)(2) forward-looking assessment → SI
4. Cross-reference to Item 1A → N/O element

The paragraph has TWO materiality assessments (backward-looking negative and forward-looking positive), making it clearly SI.

The materiality assertions here are self-referential with no domain-specific terminology, firm-specific details, or verifiable evidence backing them up. The negative claim about not being materially affected isn't something I can independently verify, and the cross-reference doesn't add specificity. This is boilerplate language, so despite triggering the SI rule through its materiality assessments, it scores at Level 1 for specificity.


fact: Specific date of disclosure: February 22, 2024

fact: Cybercrime threat actors identified as believed perpetrators

reasoning: The paragraph describes a real cybersecurity incident—its disclosure date, ongoing investigation, and believed perpetrators—making Incident Disclosure the primary category. The trailing materiality sentence is subordinate to the incident narrative frame. The specific date 'February 22, 2024' is an externally verifiable fact (the 8-K filing is public record), driving specificity to Level 4.

thinking: Incident disclosure with specific date, named threat actor type, and materiality assessment.


reasoning: The paragraph centrally addresses contractual security requirements imposed ON suppliers, vendors, and third parties — squarely Third-Party Risk per Rule 3. The language is entirely generic ('appropriate security controls,' 'contractually restricts') with no domain-specific terms, firm-specific details, or verifiable claims, keeping specificity at Level 1.

thinking:
Classify this paragraph.

Content: About contractual requirements imposed ON vendors/suppliers/third-parties regarding security controls and data use restrictions.

Category: This is centrally about requirements imposed on third parties → Third-Party Risk (Rule 3).

Specificity: Let me scan for facts.
- "contractually requires suppliers, vendors and other third-parties" — generic process description
- "implement and maintain appropriate security controls" — generic
- "contractually restricts their ability to use the Company's data" — generic

No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims. This is generic boilerplate about vendor contractual requirements.

Level 1.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not materially affected') and a forward-looking SEC 106(b)(2) assessment ('reasonably likely to materially affect'), making it Strategy Integration under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the rest is generic speculation and a cross-reference to Item 1A.

thinking: SI materiality assessment paragraph.


reasoning: The first sentence is a backward-looking materiality assessment ('have not materially affected') combined with an SEC Item 106(b)(2) forward-looking assessment ('reasonably likely to materially affect'), both triggering the SI materiality rule. The second sentence is a cross-reference to Item 1A. Specificity is Level 1 because the negative assertion about no material breaches is a self-reported claim about absence (not externally verifiable), '2023' is a reporting period rather than a cybersecurity fact, and the cross-reference adds no substantive detail.

thinking:
This paragraph has two parts: (1) a negative materiality assertion about 2023, and (2) a cross-reference to Item 1A.

Category: The first sentence is a backward-looking materiality assessment ("have not materially affected") and forward-looking ("reasonably likely to materially affect") → SI per Rule 5. The second sentence is a cross-reference → N/O. The dominant content is the SI assertion.

Specificity: "In 2023" is a reporting period, not a cybersecurity fact.

The core claim here is that cybersecurity incidents haven't materially affected operations or financial condition — a negative self-assertion that can't be externally verified. There are no specific facts, domain terms, or verifiable details to anchor this claim, which puts it at Level 1.


fact: Vice President (VP) of Platforms, Infrastructure and Cybersecurity

fact: Both CDIO and VP have over 20 years of related experience

reasoning: The paragraph describes two management-level roles (CDIO and VP), their shared responsibility for cybersecurity, and their qualifications — person-removal collapses it, confirming MR. 'Over 20 years of related experience' is a lower-bound claim verifiable against resumes, elevating to Level 4.

thinking:
Classify this paragraph.

Category: This is about management roles - EVP CDIO and VP of Platforms, Infrastructure and Cybersecurity, their responsibilities, qualifications, experience. Person-removal test: remove names/titles/qualifications → "Our information security program is administered under the supervision of... who share responsibility for assessing and managing the Company's cybersecurity risks." Very little remains. → MR.

Specific facts:
- EVP, Chief Digital and Innovation Officer (CDIO) → named_role (firm-specific, VP+ level)

- VP of Platforms, Infrastructure and Cybersecurity → named_role (firm-specific, VP level with security qualifier)
- "over 20 years of related experience" → quantified (lower bound, verifiable)
- "notable multinational organizations" → not specific enough

Specificity: Level 4 (Quantified-Verifiable) due to "over 20 years"


fact: Board designated its Risk Committee for cybersecurity oversight

fact: Chief Information Security Officer (CISO) presents to the Risk Committee

fact: Vulnerability assessments referenced as a reporting topic

fact: Board receives reports at least annually on cybersecurity risk metrics

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the Risk Committee's delegation, its receipt of CISO reports, and the Board's annual reporting cadence — all governance-chain content with the board as the focal point. Specificity reaches Firm-Specific due to the named Risk Committee designation and CISO role, with domain terms like vulnerability assessments also present.

thinking:
Let me analyze this paragraph.

Category: This describes how the Board's Risk Committee oversees cybersecurity risk management. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- Risk Committee (board-level committee, but this is a named committee beyond generic "Audit Committee") - actually "Risk Committee" is fairly specific
- CISO role mentioned
- ERM program integration mentioned
- "key risk indicators" - domain-ish but ERM would use this
- "vulnerability assessments" - domain term

- "risk assessment outcomes" - generic
- "at least annually" for Board reports - generic cadence
- "emerging threats" - generic

Now I'm refining my assessment. The domain-specific language includes vulnerability assessments and information security, while the firm-specific elements are the Risk Committee as a designated board body and the CISO role. The cadence and threat references are too generic to add specificity. This lands at Level 3 due to the named committee structure and CISO designation.


fact: Vendor Management Committee oversees the process

fact: Vendor Management team conducts due diligence

fact: Review includes cybersecurity, data and privacy protection, and business continuity practices

reasoning: The paragraph is centrally about how the company manages third-party vendor cybersecurity risk—due diligence for new vendors, ongoing reviews, and committee oversight—making it Third-Party Risk. The named Vendor Management Committee and Vendor Management team are firm-specific organizational details that elevate this to Level 3.

thinking:
Classify this paragraph.

Category: This is centrally about how third-party vendor cyber risks are managed - vendor management process, due diligence, oversight. Central topic is third-party risk management → Third-Party Risk.

Specific facts:
- "Vendor Management Committee" - named committee (firm-specific)
- "Vendor Management team" - named team (firm-specific)
- "cybersecurity, data and privacy protection, and business continuity practices" - domain terms but these are pretty generic
- "Annual due diligence follow-up reviews" - specific cadence but generic

Level 3 due to named committee and team.


reasoning: The paragraph's central claim is a backward-looking materiality assessment ('have not been subject to cyber attacks that, individually or in the aggregate, have been material to Verizon's operations or financial condition'), which triggers SI under Rule 5. The remainder is speculative forward-looking language and a cross-reference to Item 1A. No domain terms passing the ERM test, no firm-specific facts beyond the company name, and the negative materiality assertion is not externally verifiable, so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

Content: States they haven't had material cyber attacks, notes increasing threats, and cross-references Risk Factors.

Category: The key statement is "we have not been subject to cyber attacks that, individually or in the aggregate, have been material to Verizon's operations or financial condition" — this is a backward-looking materiality assessment → SI per Rule 5.

But there's also a cross-reference and speculative language. The materiality assessment is the substantive claim here.

Specificity: "have not been subject to cyber attacks that...have been material" — this is a negative self-assertion, NOT externally verifiable.

Looking at the domain terms and firm-specific facts, there's nothing that really stands out beyond the company name itself. The cross-reference to Item 1A is just standard boilerplate language. This is essentially generic materiality assessment language without any distinguishing details, so I'm classifying it as Level 1 - Generic Boilerplate.


fact: Ransomware attack in May 2022

fact: ransomware

fact: multi-factor authentication

fact: Company did not pay any ransomware

fact: engaged a team of third-party forensic experts

reasoning: The paragraph's primary frame is a real cybersecurity incident — ransomware in May 2022, detection, response, and resolution — making it Incident Disclosure per Rule 4 (incident frame dominant over the trailing materiality assessment). Specificity reaches Quantified-Verifiable because 'May 2022' is a specific date tied to a real, externally confirmable event (ransomware attack on a public company).

thinking:
Let me analyze this paragraph carefully.

This paragraph covers multiple topics:
1. A real cybersecurity incident (ransomware in May 2022) - Incident Disclosure
2. Response actions (forensic experts, law enforcement) - ID
3. Statement that it didn't materially affect business - Strategy Integration
4. Improvements made (MFA, training) - RMP
5. Materiality assessment - Strategy Integration
6. Cross-reference to Item 1A - N/O

The dominant frame is the incident itself - what happened, when, how they responded. But there's also a significant materiality assessment.

The incident narrative is the primary frame, with the materiality conclusion integrated. The paragraph starts with the incident, describes response, then pivots to materiality and improvements. The incident description takes up roughly the first half, and the materiality and improvements the second half. So Incident Disclosure is the primary category.

Looking at the specific facts: May 2022 is a verifiable date, ransomware and multi-factor authentication are domain terms, third-party forensic experts are mentioned but unnamed, and notably they didn't pay any ransom. I'll categorize this as Incident Disclosure.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks of third-party vendors—conducting assessments, imposing contractual requirements, and requiring incident notification—making Third-Party Risk the clear category. The language is entirely process-descriptive ('conducts cyber assessments,' 'contractually required to manage their cybersecurity risks') without domain-specific terminology that passes the ERM test; a non-security risk professional could write this same paragraph about any vendor oversight program.

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

Specific facts:
- "cyber assessments on potential vendors" - this is a process description, borderline L1/L2. "Cyber assessments" is fairly generic.
- "contractually required to manage their cybersecurity risks" - generic
- "provide notification in the event of a cybersecurity incident" - contractual requirement on vendors

This is clearly Third-Party Risk - it's about requirements imposed ON vendors.

For specificity: The paragraph describes vendor assessments and contractual requirements. "Cyber assessments on potential vendors" - is this domain-adapted? The ERM test: would a non-security ERM professional say "cyber assessments"? Possibly not naturally - they might say "risk assessments." But it's borderline.

Looking at the vendor oversight language more closely, the assessment trigger is fairly specific—it applies to vendors with access to IT systems, data, or facilities housing them. But this still reads as process description rather than domain expertise. An ERM professional could easily write about assessing vendors and imposing contractual requirements. "Cyber assessments" is just a generic term with "cyber" added on. I'm settling on Level 1 for this—the language is procedural and doesn't demonstrate specialized security knowledge.


reasoning: The paragraph makes explicit materiality assessments: 'results of operations and financial condition have not been materially affected' (backward-looking) and 'cybersecurity threats...have materially affected our business strategy and processes' (affirmative SI conclusion). These are direct answers to how cybersecurity affects the business/finances → SI. Despite multiple materiality statements, the paragraph contains no domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims — it is entirely generic language about investment, risk, and impact.

thinking: Strategy Integration - materiality assessments about business impact.


reasoning: The paragraph's central topic is how the company evaluates and manages cybersecurity risks of third-party service providers — vendor selection criteria, oversight, and contractual obligations — making Third-Party Risk the best fit. The language is entirely generic ERM vocabulary (vendor management process, contractually imposed obligations, industry standards) with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: This is primarily about how third-party cyber risks are managed - vendor selection, oversight, contractual obligations. Central topic is third-party risk management. → Third-Party Risk

Specificity: Let me scan for facts.
- "cybersecurity programs based on industry standards" - generic
- "vendor management process" - generic ERM language
- "contractually imposed obligations" - generic
- No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims.

This is all generic language any ERM professional could write.

So this lands at Level 1 - it's boilerplate third-party risk management language without any specificity or concrete details.


reasoning: The paragraph's primary purpose is a cross-reference directing the reader to Item 7 for further detail; the ERM integration mention is a thin introductory framing sentence rather than a substantive process description. None/Other paragraphs always receive Generic Boilerplate.

thinking:
Classify this paragraph.

This is a brief paragraph that says cybersecurity is part of ERM and cross-references Item 7. No substantive cybersecurity disclosure - it's a cross-reference/introductory statement.

Category: This mentions ERM integration briefly but the main purpose is a cross-reference. The ERM integration mention is very thin. This is essentially a cross-reference paragraph → None/Other.

Wait - "We manage our cybersecurity risk as an integral part of our enterprise risk management programs" - this could be RMP (ERM integration). But the second sentence is purely a cross-reference. The substantive content is minimal - just saying "cybersecurity is part of ERM" which is a single generic statement, plus a cross-reference.

Looking at Rule 5 on cross-references, the second sentence is clearly pointing elsewhere, which would suggest None/Other. The first sentence does state ERM integration, but it's so generic that it's borderline. Given that the paragraph's primary function appears to be directing readers to Item 1A rather than disclosing actual risk management practices, I'm leaning toward None/Other despite the thin ERM mention.


reasoning: The paragraph introduces the company's cybersecurity risk management program, its purpose (safeguarding data, transactions, systems), and its integration with ERM, making RMP the best fit; the 'could have a material adverse effect' language is speculation per Rule 5, not SI. All language is generic—FRB, FDIC, and DFR are standard banking regulators (not cybersecurity domain terms), and the rest ('robust program,' 'safeguards sensitive customer data') is boilerplate any ERM professional could write, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses cybersecurity risks, mentions regulatory compliance (FRB, FDIC, DFR), and states the company established a cybersecurity risk management program as part of ERM. It's introductory/overview language.

Category: This is mostly introductory framing. It mentions risks, regulatory context, and that a program exists. The "could have a material adverse effect" is speculation (not SI per Rule 5). The paragraph introduces the program but doesn't describe what it does in detail. It's borderline RMP/N/O but does mention establishing a program and its purpose.

The core focus here is really about the existence and purpose of the risk management program itself, so that points to RMP. Now I'm checking the specificity level—FRB and FDIC are standard regulatory references for any bank, but DFR as the Vermont Department of Financial Regulation adds some state-level context that's more particular to this company's jurisdiction.

The language around "robust cybersecurity risk management program" and "safeguards sensitive customer data" reads as generic Level 1 material. These regulatory bodies are banking-specific rather than cybersecurity domain terms, so they don't really elevate the specificity beyond what any financial institution would mention. Even with DFR narrowing things down geographically, this still feels like foundational banking compliance language rather than firm-specific detail.


fact: cybersecurity insurance coverage

reasoning: The paragraph makes multiple materiality assessments: results have not been materially affected by incidents, yet cybersecurity threats have materially affected business strategy and processes, and it discusses insurance and investment — all answering how cybersecurity affects the business/finances. Specificity reaches Level 2 via 'cybersecurity insurance coverage' as a domain-specific risk transfer mechanism, but the rest is generic risk language and speculation ('could have a material adverse effect') that any ERM professional could write.

thinking: Strategy Integration - materiality assessments about business/financial impact.


fact: CIA triad referenced: confidentiality, integrity, or availability

fact: CSO (Chief Security Officer) identified as part of program structure

reasoning: The paragraph primarily answers what the cybersecurity program does — protecting information, assessing/identifying/managing risks, responding to incidents — making it RMP. The person-removal test confirms: removing the CSO reference leaves a full program description. Specificity reaches Level 3 because CSO (Chief Security Officer) is a VP-level-or-above security role that is firm-specific, while the CIA triad language provides domain-adapted terminology.

thinking:
Classify this paragraph.

Content: Describes AT&T's network and information security program - what it does (protect information, assess/identify/manage risks, respond to incidents). Mentions CSO but as part of program description. Third-party risk mentioned but as one component.

Category: RMP - describes what the cybersecurity program does.

Specific facts:
- "CSO" - Chief Security Officer, a named role (firm-specific, VP-level equivalent)
- "network and information security program" - generic
- "confidentiality, integrity, or availability" - CIA triad, domain term

- Third-party risk from vendors and suppliers - mentioned but generic

The CSO is a firm-specific role at VP level, while the CIA triad is standard security domain language that passes the ERM test. Most of the rest—assessing, identifying, and managing risks, plus incident response—reads as boilerplate language rather than distinctive content.


reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party service providers (pre-engagement assessments, periodic reviews, security standards), making it Third-Party Risk. The language is entirely generic — 'risk assessments,' 'standards for security,' 'strategic risk management committees' — all pass the ERM test as terms any non-security risk professional would use, yielding Level 1.

thinking:
Classify this paragraph.

Content: About managing third-party cybersecurity risks through assessments. Central topic is third-party risk management.

Category: Third-Party Risk — requirements imposed on vendors, vendor oversight as central topic.

Specific facts:
- "strategic risk management committees" — this is a named committee? It's somewhat generic but "strategic risk management committees" could be firm-specific. Actually, it's fairly generic - not a unique named committee like "Cybersecurity Steering Committee." It's more of a generic description.
- "pre-engagement and periodic risk assessments" — process description, not really domain-specific.

The language here is pretty generic—the kind of thing any ERM professional would write about vendor risk. "Pre-engagement and periodic risk assessments" and "strategic risk management committees" don't demonstrate specific cybersecurity expertise, just standard vendor oversight terminology. I'd classify this as Level 1 boilerplate.


fact: Named internal program: Third Party Risk Management (TPRM) program

fact: TPRM program is integrated into procurement process

reasoning: The paragraph's central topic is how Unisys manages cybersecurity risks from third-party service providers — vendor due diligence, ongoing monitoring, and the TPRM program — making Third-Party Risk the clear category. The trailing sentence is a section header/transition for a materiality discussion, not an actual assessment. The named 'Third Party Risk Management (TPRM) program' with its specific integration into procurement is a firm-specific distinguishing detail, elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes third-party risk management program (TPRM), integrated into procurement, cybersecurity due diligence on vendors, monitoring suppliers. The last sentence is a materiality assessment statement.

Category: The central topic is third-party risk management - how they manage vendor cyber risks. The last sentence is a materiality transition/header. But the bulk is about TP. The last sentence looks like a section header for the materiality assessment (it's phrased as a question/topic header, not an actual assessment). So TP is the primary category.

The key detail here is that they've named this their "Third Party Risk Management (TPRM) program" - that's a firm-specific identifier, not generic language. They've also integrated it into their procurement process, which is a concrete operational detail. The cybersecurity due diligence piece is more standard practice, but combined with the named program and procurement integration, this is clearly firm-specific. The last sentence is just a transition point, not an actual materiality assessment yet.


fact: Director of Cybersecurity

fact: Chief Information Officer (CIO)

fact: CIO reports directly to CEO

fact: CIO and Director of Cybersecurity both have over 20 years of cybersecurity oversight experience

fact: CIO previously served as CIO for a NYSE-listed manufacturing company

reasoning: The paragraph focuses on management roles (CIO, Director of Cybersecurity), their responsibilities, reporting lines, and career qualifications — person-removal collapses it, confirming MR. 'Over 20 years' is a verifiable lower bound checkable against resumes, elevating to Level 4.

thinking:
Classify this paragraph.

Category: This is about management roles, responsibilities, qualifications, and experience. Person-removal test: remove names, titles, qualifications → almost nothing remains. → MR

Specific facts:
- Director of Cybersecurity (named role with security qualifier)
- CIO (named role, VP-level equivalent)
- CEO (generic, not firm-specific)
- Reports directly to CEO (reporting line - firm-specific organizational fact)
- "over 20 years of cybersecurity oversight experience" for both CIO and Director of Cybersecurity → quantified, lower bound, verifiable

- CIO's prior role as CIO at a NYSE-listed manufacturing company is a firm-specific career detail that's verifiable and specific.


fact: CDO (Chief Data Officer) leads cybersecurity risk management

fact: CISO leads cybersecurity risk management

fact: Collectively over 25 years of prior work experience

fact: ISACA Certified Information Security Manager (CISM) certification required

fact: ISC2 Certified Information Systems Security Professional (CISSP) certification required

fact: ISACA named as certifying body

fact: ISC2 named as certifying body

reasoning: The paragraph primarily answers who leads cybersecurity and what qualifies them — CDO and CISO roles, their collective experience, and required certifications — making it Management Role. Person-removal leaves only thin references to incident response and risk processes. Specificity reaches Level 4 via the verifiable lower bound of 'over 25 years' of experience and named certifications (CISM, CISSP) checkable against ISACA and ISC2 registries.

thinking:
Classify this paragraph.

Category: This is about the CDO and CISO - their experience, qualifications, certifications, and how they monitor cybersecurity. Person-removal test: remove names, titles, qualifications, experience → what remains? "cybersecurity risk management and strategy processes... prevention, mitigation, detection, and remediation of cybersecurity incidents... incident response plan." Some program description remains but it's thin. The primary focus is on WHO leads (CDO, CISO), their experience, their required certifications. This is MR.

Specific facts:
- CDO (named role, firm-specific)

- CISO (named role, firm-specific)
- Combined experience of over 25 years with a quantifiable lower bound
- ISACA CISM and ISC2 CISSP certifications, both verifiable credentials from named organizations

Specificity: Level 4 (Quantified-Verifiable)


reasoning: The paragraph contains the SEC Item 106(b)(2) forward-looking materiality assessment ('reasonably likely to materially affect our business strategy, results of operations, or financial condition'), which triggers the SI materiality rule. No domain terms, firm-specific facts, or verifiable claims are present—the self-description as 'large financial technology provider' is generic and the cross-reference to Item 1A is boilerplate.

thinking:
Let me analyze this paragraph.

Content: States cybersecurity threats are "reasonably likely to materially affect" business strategy/results/financial condition. Also mentions inability to guarantee no future incidents. Cross-references Item 1A.

Category: The "reasonably likely to materially affect" language is the SEC Item 106(b)(2) forward-looking assessment → SI per Rule 5. The cross-reference alone would be N/O, but the materiality assessment is substantive.

Specificity: No domain terms, no firm-specific facts beyond "large financial technology provider" (generic self-description). No verifiable claims. The negative assertion about not guaranteeing no incidents is not verifiable.

This is Level 1, Generic Boilerplate. The self-description as a "large financial technology provider" doesn't really distinguish the company—plenty of firms could use that language. The materiality language triggers the SI classification under SEC Item 106(b)(2), but without any concrete details about actual threats or the company's specific vulnerabilities, it's just standard risk disclosure language.


fact: Vice President of Cybersecurity

fact: Audit Committee receives cybersecurity updates on a quarterly basis

fact: IT security/cybersecurity briefing from management on at least a semi-annual basis

fact: Full Board receives updates on the Cybersecurity Program at least annually

reasoning: The paragraph describes how the Board and Audit Committee oversee cybersecurity, including briefing cadences and escalation paths, squarely answering the Board Governance question. The VP of Cybersecurity is a VP-level title with a security qualifier, making it firm-specific (Level 3); the specific cadences (quarterly, semi-annual, annual) are notable but generic scheduling, not verifiable claims.

thinking:
Classify this paragraph.

Category: Board Governance - describes board/committee oversight, briefing frequency, how information flows to the board.

Specific facts:
- Audit Committee (generic, every company has one - not firm-specific)
- Vice President of Cybersecurity (VP-level with security qualifier → firm-specific)
- Quarterly cybersecurity updates (cadence)
- Semi-annual IT security/cybersecurity briefing
- Annual full Board updates

Specificity: "Vice President of Cybersecurity" is a VP-level role with security qualifier → Firm-Specific (Level 3).


reasoning: The paragraph describes the Audit Committee's oversight role for cybersecurity risks, squarely answering 'how does the board oversee cybersecurity?' → Board Governance. The language is entirely generic governance boilerplate — 'Audit Committee' is not firm-specific (every company has one), and terms like 'policies, strategies, and initiatives' and 'risk oversight responsibility' are standard ERM language with no domain-specific or verifiable content.

thinking:
Classify this paragraph.

Category: Board Governance - describes Audit Committee oversight of cybersecurity, which is board-level governance.

Specific facts: "Audit Committee" is generic (every company has one), not firm-specific. The language is generic oversight language - no domain terms, no firm-specific facts, no verifiable claims.

Specificity: Generic Boilerplate (Level 1).


fact: Change Healthcare named as involved third party

fact: UnitedHealth Group named as parent company of Change Healthcare

fact: February 21, 2024 - date Change Healthcare notified of cybersecurity incident

fact: February 28, 2024 - date by which no compromise identified

fact: Forensics conducted on systems

reasoning: The paragraph primarily describes a real cybersecurity incident involving Change Healthcare with specific timeline, response actions, and scope — making it Incident Disclosure under Rule 4 (incident frame dominant, with a materiality assessment in the closing sentence). Specificity is Level 4 due to multiple externally verifiable facts: named third-party firms (Change Healthcare, UnitedHealth Group) and specific dates (February 21 and 28, 2024) tied to a publicly known real event.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph describes a real cybersecurity incident (Change Healthcare) with timeline, scope, response, and impact assessment. It's primarily about what happened - an incident disclosure. But it also contains a materiality assessment at the end.

Rule 4: Mixed incident and financial assessment. The incident frame is dominant - most of the paragraph describes the timeline, response, and scope. The last sentence is a materiality/SI statement, but the dominant frame is incident disclosure.

Actually, let me re-read. The paragraph starts with a general statement about no material compromises, then describes the Change Healthcare incident in detail (timeline, response, forensics, impact).

The last sentence wraps up with a materiality assessment, but the core of this is really incident disclosure. I'm seeing multiple verifiable facts here - specific dates like February 21 and February 28, 2024, named entities like Change Healthcare and UnitedHealth Group, plus forensic investigation details. That puts this at Level 4 specificity with concrete, tied-to-real-events information.


fact: zero-day vulnerability

fact: compromised credentials

fact: MOVEit Transfer file sharing software named as the affected product

fact: 2023 third-party vendor incident involving MOVEit Transfer zero-day

fact: credit card information, social security numbers referenced as compromised data types

reasoning: The paragraph primarily describes actual cybersecurity incidents (unauthorized access, fraud via compromised credentials, third-party breaches) with the incident frame dominating over the closing materiality sentence, making it Incident Disclosure. Specificity reaches Level 4 because MOVEit Transfer is a named product tied to a well-known, publicly documented 2023 zero-day exploit (CVE-2023-34362), which is independently verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes actual incidents (unauthorized access, fraud attempts, compromised credentials, third-party vendor incidents including the MOVEit Transfer zero-day in 2023). It also concludes with a materiality assessment.

Category: This is primarily about actual incidents that occurred - describing their nature (unauthorized access, fraud, compromised credentials, third-party breaches). The final sentence is a materiality assessment (SI). But the dominant frame is incident disclosure - what happened. By Rule 4, mixed with incident frame dominant → ID.

Wait, let me reconsider. The paragraph describes multiple incidents broadly, then gives the MOVEit example, then concludes with materiality.

The incident descriptions dominate the text, so ID is the right categorization. For specificity, I'm seeing domain terms like "zero-day vulnerability" and "compromised credentials" at Level 2, the named product "MOVEit Transfer" at Level 4, and the 2023 timing as a specific verifiable date tied to that well-known breach. The materiality statement at the end is a self-assessment rather than a verifiable fact.


reasoning: The paragraph describes how board-level committees (Audit Committee, Risk Committee) oversee cybersecurity governance and coordinate on information security matters — squarely answering the board oversight question. No domain-specific terminology passes the ERM test ('cybersecurity governance, risks, and related controls' is standard governance language), and both Audit Committee and Risk Committee are generic board committees common at financial institutions, not firm-specific identifiers.

thinking:
Classify this paragraph.

Content: Audit Committee monitors internal audit's cybersecurity coverage, Risk Committee coordinates with Audit Committee on information security matters.

Category: Board Governance - this is about board-level committee oversight of cybersecurity.

Specific facts:
- Audit Committee - generic, every company has one
- Risk Committee - this could be firm-specific if it's a named non-generic committee... but "Risk Committee" is fairly common at banks. Let me think - the instructions say "Audit Committee" is NOT firm-specific since every company has one. "Risk Committee" - is this generic? Many financial companies have a Risk Committee of the Board.

Risk Committee is common enough at financial institutions that I wouldn't call it firm-specific, even though it's not universal across all public companies. The language here—cybersecurity coverage, information security matters—is standard governance terminology without the specialized vocabulary an ERM professional would use. This reads like generic boilerplate about board committee responsibilities, so I'd classify it as Level 1.


fact: Named internal program: Third Party Risk Management (TPRM) program

fact: TPRM integrated into procurement process

fact: Outside-in, hacker perspective monitoring of suppliers via external service provider (attack surface monitoring)

reasoning: The paragraph's central topic is how Unisys manages cybersecurity risks from third-party vendors — the TPRM program, vendor due diligence, and ongoing supplier monitoring — making TP the primary category. The final sentence reads as a copy-pasted SEC regulatory prompt (Item 106(b)(2) language) rather than an actual materiality conclusion. The named TPRM program with its distinguishing integration into procurement elevates to Firm-Specific; the 'outside-in, hacker perspective' language demonstrates domain knowledge of attack surface monitoring.

thinking:
Let me analyze this paragraph carefully.

Content: This paragraph discusses third-party risk management (TPRM) program, its integration into procurement, vendor due diligence, monitoring of suppliers. The last sentence is a materiality assessment statement.

Category: The central topic is third-party risk management - how vendors are overseen. The last sentence is an SI materiality statement, but the bulk is about TPRM. The last sentence looks like it might be a copy-paste error or template language - "Whether any risks..." reads like a question/header rather than a conclusion. Let me re-read it.

Actually, that final sentence is just regulatory boilerplate from the SEC - it's phrased as a question rather than an actual assessment, so it's not really providing substantive information about cybersecurity impact. The real substance here is the third-party risk management framework, so I'll categorize this as TP.

Looking at the specificity of the language used, the "Third Party Risk Management program" is a named internal program specific to Unisys, which signals firm-specific detail. The phrase "outside-in, hacker perspective" demonstrates domain expertise in attack surface monitoring. The "cybersecurity due diligence reviews" language is somewhat technical but fairly standard. The "risk profile" reference is more generic. The named TPRM program is the strongest indicator of specificity here, so this lands at Level 3.


fact: ransomware attack

fact: 2021 - specific year of the incident

fact: incident did not have a material impact on business, operations, or financial condition

reasoning: The paragraph describes an actual cybersecurity incident (ransomware attack) with timeline, nature, and impact — squarely Incident Disclosure. The specific date '2021' for the ransomware attack is a verifiable claim tied to a real event (a publicly disclosed ransomware incident can be cross-referenced), elevating to Level 4. The materiality conclusion is a secondary element but the incident frame dominates per Rule 4.

thinking: Classifying this paragraph about a ransomware attack.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for materiality discussion, with no substantive cybersecurity disclosure of its own. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' → N/O. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A risk factors about materiality.


fact: vulnerability assessments

fact: Vice President of Information Security

fact: CIO

reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing Board and Audit Committee receipt of reports, briefing cadences, and incident notification thresholds — making it Board Governance. The mention of VP of Information Security (VP-level security role) and named teams like Information Technology Senior Leadership Team elevate specificity to Firm-Specific.

thinking:
Classify this paragraph.

Category: This describes board/committee oversight of cybersecurity. The primary question answered is "How does the board oversee cybersecurity?" — BG.

Specific facts:
- CIO (named role)
- Vice President of Information Security (named role, VP-level with security qualifier)
- Information Technology Senior Leadership Team (named team)
- Information Security and Compliance teams (named team)
- Audit Committee (generic, not firm-specific)
- vulnerability assessments (domain term)
- "At least once each quarter" - cadence, generic

- "at least annually" - cadence, generic

The VP of Information Security stands out as firm-specific given the VP-level designation paired with the security focus, while the CIO is more of a standard role. The named teams like the Information Technology Senior Leadership Team add some firm-specificity as well. Overall, this lands at Level 3 (Firm-Specific) primarily because of the VP-level security role and the specific team structures mentioned.


fact: Vice President of Information Technology, Security and Business Intelligence

fact: over 18 years of experience in IT and information security

fact: Prior roles at Biogen, AstraZeneca, Iron Mountain, Charles River Labs, Sunovion Pharmaceuticals, Agero, DentaQuest

fact: Master's degree in business administration from Boston University

fact: Master's degree in electrical and computer engineering from Utah State University

fact: Bachelor's degree in electronics engineering from Mumbai University

fact: IT team has over 10 years of experience managing cybersecurity risks

reasoning: The paragraph is entirely about the management role responsible for cybersecurity—responsibilities, reporting lines, career history, qualifications, and team experience—making it a clear MR. Multiple externally verifiable facts (named prior employers, specific university degrees, lower-bound years of experience) place this firmly at Level 4.

thinking:
Classifying this paragraph about Axogen's VP of IT, Security and Business Intelligence.

Category: This is clearly about Management Role - it describes who is responsible, their qualifications, career history, education, and team composition.

Specificity: Let me scan for facts.

Firm-specific facts:
- VP of Information Technology, Security and Business Intelligence (named role, VP+ with security qualifier)
- Coordination with CEO, CFO, General Counsel (generic roles)

Verifiable facts:
- "over 18 years" in IT/infosec roles - lower bound, verifiable
- Named prior employers: Biogen, AstraZeneca, Iron Mountain, Charles River Labs, Sunovion Pharmaceuticals, Agero, DentaQuest

- Advanced degrees including an MBA from Boston University and a Master's in electrical and computer engineering from Utah State University, plus a Bachelor's in electronics engineering from Mumbai University
- "over 10 years of experience" managing the IT team - another lower bound metric

This is clearly Level 4 with multiple verifiable facts across education, experience, and specific prior roles.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not materially affected') and a forward-looking SEC 106(b)(2) assessment ('reasonably likely to materially affect'), both triggering SI under Rule 5. The reporting period 'December 31, 2024' is contextual framing, the negative materiality assertion is not externally verifiable, and the cross-reference to Item 1A is N/O content but subordinate—no specific facts elevate above Level 1.

thinking: Materiality assessment paragraph.


fact: February 21, 2024 — specific date of Change Healthcare notification

fact: Change Healthcare — named third-party firm involved in the incident

fact: UnitedHealth Group — named parent company of Change Healthcare

fact: forensics conducted on systems after shared incident information

reasoning: The paragraph's dominant frame is describing a real cybersecurity incident — the Change Healthcare breach on a specific date, the company's response (severing connections, conducting forensics), and the operational impact (inability to submit claims). While it concludes with a materiality assessment (SI-eligible), the incident narrative constitutes the bulk of the text, making ID the primary category per Rule 4. Specificity reaches Level 4 via the specific date (February 21, 2024) and named firms (Change Healthcare, UnitedHealth Group), which are independently verifiable.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph describes a real cybersecurity incident (Change Healthcare on February 21, 2024) and its impact. It covers what happened, the response, and concludes with a materiality assessment. The dominant frame is incident disclosure - timeline, scope, response - with a materiality conclusion at the end. Per Rule 4, mixed with incident frame dominant → ID. But the last sentence is a clear SI materiality assessment. The bulk of the text describes the incident (Change Healthcare), so ID seems right. But there's also a clear SI conclusion at the end.

Actually, looking more carefully - the paragraph title is "Effects of Cybersecurity Risks on the Company" and it concludes with "did not materially affect our business strategy, results of operation or financial condition." The incident description is substantial but serves to set up the materiality assessment.

The majority of the text focuses on the incident itself, so I'm categorizing this as Incident Disclosure. The paragraph opens with a statement about not experiencing material compromise, provides substantial detail about the Change Healthcare incident, and wraps up with a materiality assessment - but the incident narrative dominates, making ID the appropriate classification.

For specificity, I'm noting the concrete details: the February 21, 2024 date, Change Healthcare and UnitedHealth Group as named entities - all verifiable. The materiality conclusion is a negative self-assertion that doesn't meet the verifiability standard. This puts it at Level 4 due to the specific date and named firms.


reasoning: The paragraph centrally addresses requirements imposed on third-party service providers and assessments of their security, making TP the clear category. The language is entirely generic—'security measure protocols,' 'assessments,' 'adequate security measures'—with no domain-specific terms (fails ERM test), no firm-specific details, and no verifiable claims.

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


fact: As of March 31, 2024 — specific date anchoring the assessment

reasoning: The paragraph states a backward-looking materiality conclusion ('have not identified any risks... that have materially affected') and a forward-looking cross-reference, making it SI per Rule 5. The specific date 'March 31, 2024' anchors the assessment but the negative assertion ('have not identified any risks') is not externally verifiable — one cannot independently confirm the absence of material impact. The cross-reference to Risk Factors is N/O-like but subordinate to the materiality assessment. The date is firm-specific context (reporting period end) rather than a verifiable cybersecurity fact, placing this at Level 3.


fact: CIO and his security management team possess primary responsibility

reasoning: The paragraph opens with CIO responsibility but devotes most of its text to Board and Audit Committee oversight activities (annual review, quarterly updates, review of enhancements and roadmap), making Board Governance the primary category. Specificity reaches Firm-Specific due to the CIO role, which qualifies as a cybersecurity leadership role at C-level; however, the remaining content (annual review, quarterly updates, identify/detect/respond language) is generic governance boilerplate that fails the ERM test.

thinking:
Let me analyze this paragraph.

Category: This paragraph covers multiple topics - CIO's team responsibility, Board oversight, and Audit Committee updates. The Board and Audit Committee oversight content dominates (Board annual review, Audit Committee quarterly updates). The CIO mention is brief. Primary question answered: "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- CIO (named role, firm-specific)
- Board of Directors conducts annual review (generic)
- Audit Committee receives quarterly cybersecurity updates (generic cadence)
- "annual review" and "quarterly" are generic cadences

Wait - CIO is a C-level title.

So CIO is firm-specific since it's a cybersecurity leadership role at the C-level, even though it's a common role across companies. For domain terms, "cybersecurity roadmap" doesn't pass the ERM test, and the other phrases like "identify and detect threats" and "monitor cyber risks" are too generic to qualify.


fact: Crisis simulation exercises involving shipboard and shoreside employees (industry-specific organizational distinction unique to maritime/cruise companies)

reasoning: The paragraph describes incident response planning, testing, and team structure — all program activities, making it RMP. The mention of 'shipboard and shoreside employees' is a firm-specific detail that narrows this to a maritime/cruise company, elevating to Level 3, though the rest is generic boilerplate about incident response plans and external experts.

thinking:
Classify this paragraph.

Content: Describes incident response plan, policies, protocols, testing through crisis simulation exercises, incident response team, collaboration with external experts.

Category: This is about what the cybersecurity program does - RMP.

Specificity: Let me scan for facts.
- "incident response plan" - L1 (generic)
- "crisis simulation exercises" - this is basically tabletop exercises without cybersecurity qualifier... borderline L1
- "shipboard and shoreside employees" - this is somewhat firm-specific to a cruise company

- "incident response team" - L1
- "external cybersecurity experts" - L1

The phrase "shipboard and shoreside" is distinctly maritime industry language that narrows the company down to a small set of cruise or shipping operators, making it firm-specific enough to classify as Level 3.


reasoning: The paragraph describes engaging external assessors and consultants to serve the company's security program (Rule 3: third parties hired to serve the company → RMP, not TP). The language is entirely generic—'improve our security,' 'stay aligned with industry best practices,' 'evaluate external threats,' 'independent security assessments'—all phrases any ERM professional could write without cybersecurity domain knowledge, yielding Level 1.

thinking:
Classify this paragraph.

Content: About engaging external assessors/consultants for security improvements, alignment with best practices, threat evaluation, forensic reviews, and security assessments. These are third parties hired to serve the company → RMP per Rule 3.

Specificity: Let me check for specific facts. "external assessors and consultants" - generic. "forensic reviews" - could be domain but pretty generic. "independent security assessments" - generic. No named firms, no specific tools, no named roles. The language is generic - "improve our security, stay aligned with industry best practices, evaluate external threats" - any ERM professional could write this.

Even the more technical-sounding terms like forensic reviews of cybersecurity incidents and independent security assessments don't provide enough specificity to move beyond generic language.

Level 1.


fact: denial of service attacks

fact: malicious software attacks on computer systems

reasoning: While the opening clause contains a backward-looking materiality assessment (SI), the bulk of the paragraph centers on third-party cyber risk exposure — card transaction intermediaries, third-party service providers who have been breached, and vendor security assessments — making Third-Party Risk the dominant topic. Specificity reaches Level 2 via domain-specific threat types (denial of service attacks, malicious software attacks) that pass the ERM test, but no firm-specific facts or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Discusses past cyber incidents (DoS attacks, malware), third-party risks related to card transactions, vendor security assessments, and general risk warnings.

Category: This is mixed. It mentions actual incidents (DoS, malware) but in a general/historical way, discusses third-party risks, and includes forward-looking risk language. The opening states they haven't been materially impacted - that's an SI materiality assessment. But the bulk discusses third-party risks and general risk speculation.

Let me think about what question this primarily answers:
- "Have not been materially impacted by cyber incidents" → SI (materiality assessment)

- The paragraph actually centers on third-party risks though - card transaction vendors, security assessments of service providers, and vendor-related vulnerabilities dominate the text. The materiality statement is just the opening, while the rest explores exposure through third parties. So despite the SI framing at the start, Third-Party Risk is really the main focus here. "Denial of service attacks" is specific enough that a general ERM person wouldn't use it naturally—that's domain language. The rest of the paragraph stays generic: vague timeframes, no named structures, no firm-specific facts. This lands at Level 2, Domain-Adapted language.


reasoning: This is an introductory preamble with no substantive cybersecurity disclosure—just generic statements about the importance of cybersecurity and a preview of the section. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Straightforward classification.


fact: Corporate Risk Committee of the Board oversees IT systems including information security

fact: CISO reports on cybersecurity matters to the Corporate Risk Committee

fact: CIO reports on cybersecurity matters

fact: ERM team reports annually on company risks to the Board

reasoning: The paragraph answers how the board oversees cybersecurity—describing committee responsibilities (Corporate Risk Committee, Audit Committee), briefing cadences, and information flow from management to the board—making it Board Governance. Specificity reaches Level 3 via the named Corporate Risk Committee (a non-generic board committee) and the CISO role; however, no externally verifiable claims (specific dates, named individuals, certifications) push it to Level 4.

thinking:
Classify this paragraph.

Category: Board governance - describes how the board oversees cybersecurity through committees, briefing frequency, information flow to the board.

Specific facts:
- Corporate Risk Committee (named non-generic committee) → firm-specific
- Audit Committee → generic, every company has this
- CIO → generic role
- CISO → firm-specific named role
- "at least bi-annually" reporting to Corporate Risk Committee → cadence
- ERM team → generic
- "annually" reporting by CIO and ERM team

The Corporate Risk Committee is a named non-generic committee → Level 3

The CISO is a firm-specific named role that also indicates Level 3, though the reporting cadences mentioned are standard frequencies without quantified metrics.


fact: Chief Innovation Officer reports to the Audit Committee on cybersecurity

reasoning: The paragraph primarily answers how the board oversees cybersecurity, detailing the Audit Committee's review topics and reporting structure, making it Board Governance. The mention of 'Chief Innovation Officer' as the executive reporting on cybersecurity is a firm-specific role title (distinctive from generic CISO/CIO), elevating specificity to Level 3.

thinking:
Classifying this paragraph.

Category: This describes board/Audit Committee oversight of cybersecurity - how the board oversees cybersecurity. BG.

Specific facts:
- "Chief Innovation Officer" - named role, VP+ equivalent? CIO-level title, firm-specific
- "Audit Committee" - generic, every company has one, NOT firm-specific
- "at least annually" - generic cadence

The Chief Innovation Officer is a distinctive title (not generic CIO/CISO). It's a firm-specific role title at the executive level.

The Chief Innovation Officer designation pushes this to Level 3 specificity since it's a unique firm-specific executive role, whereas the Audit Committee and annual cadence are standard across companies.