reasoning: The paragraph primarily describes the company's internal security programs, incident response procedures, and the roles involved in managing these processes, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies specific cybersecurity roles (CISO, CIO) involved in these internal processes.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal incident response plan and testing procedures, which falls squarely under Risk Management Process. It contains no specific facts (dates, named firms, named tools, or unique programs) that would elevate it beyond generic boilerplate.

provider: google


reasoning: The paragraph describes the company's internal vendor management program and risk assessment processes, which falls under Risk Management Process. While it mentions third-party providers, it describes the company's internal oversight process rather than specific vendor relationships or requirements imposed on them, and contains no specific facts.


reasoning: The paragraph describes the company's internal incident response and disaster recovery processes, including the role of the Crisis Management Team and the CIO, which falls squarely under Risk Management Process.


content_category: Board Governance

reasoning: The paragraph focuses primarily on the Board's oversight responsibilities and the reporting structure of management to the Board, making Board Governance the primary category. While it mentions management roles (CIO/CISO), these are presented in the context of their reporting obligations to the Board.


content_category: None/Other

reasoning: The paragraph consists entirely of standard legal disclaimers regarding forward-looking statements and safe harbor provisions, which is classified as None/Other.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident, including the nature of the unauthorized access, the exfiltration of files, and the operational impact, which qualifies it as an Incident Disclosure.


content_category: Strategy Integration

reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year (2023) in the context of its materiality assessment.


reasoning: The paragraph focuses on the Board's delegation of cybersecurity oversight to the Audit Committee and the committee's review activities, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies a specific management role (CTO) involved in these reviews, which is a cybersecurity-specific title.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including team responsibilities, risk assessment methodologies, and vendor management procedures. While it mentions the CIO and SOC 2, these are components of the broader internal risk management framework described.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight without referencing specific frameworks, roles, or unique programs, making it a standard risk management disclosure.


reasoning: The paragraph primarily describes the company's internal incident response plan and the roles responsible for executing it, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies specific cybersecurity roles (CISO, CIO) and references specific frameworks (NIST RMF, CMMC).


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as policies, audits, and access controls, which are standard components of a risk management framework.


reasoning: The paragraph describes a specific cybersecurity incident (website defacement), the timeline of events, and the operational impact (cancelled seminar), which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of the threat communication, the nature of the threat, and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the company's internal processes for conducting audits and risk assessments, including the specific roles involved in reviewing these results. While it mentions the Audit Committee, the focus is on the internal management process of auditing and remediation.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the unauthorized access, and the operational impact, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the ongoing narrative, scope, and response actions related to a specific cybersecurity incident, including financial impact and remediation steps.


reasoning: The paragraph describes the company's current state regarding cybersecurity risk management processes (or lack thereof), which falls under the Risk Management Process category. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph consists entirely of generic boilerplate language describing cybersecurity threats and risks that could apply to any company, without detailing specific internal processes, governance, or incidents.


content_category: Management Role

reasoning: The paragraph explicitly focuses on the responsibilities of senior management regarding cybersecurity risk appetite, fitting the Management Role category. It contains no specific roles, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes internal security measures and incident response planning, which are core components of a company's risk management process. It contains no specific facts, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the roles, reporting lines, and collaborative relationships of the CISO, CIO, and CTO, which takes precedence over the brief mention of board oversight.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment activities, and general security measures, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or specific cybersecurity roles, making it generic boilerplate.


reasoning: The paragraph describes the company's internal procedures for investigating and responding to cybersecurity threats, which falls under Risk Management Process. It is classified as Firm-Specific because it references a specific internal body, the 'ISC', which is not a generic governance term.


reasoning: The paragraph describes the company's internal procedures for risk management and policy implementation, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding the absence of material cybersecurity incidents, which falls under Strategy Integration according to the provided guidelines.


reasoning: The paragraph focuses on the operational responsibilities of management and specifically identifies the 'Software Engineer' as a key role involved in cybersecurity, which places it in the Management Role category.


reasoning: The paragraph focuses primarily on the oversight responsibilities of the board-level Risk Committee, making 'Board Governance' the most appropriate category. It is classified as 'Firm-Specific' because it names a specific committee (Risk Committee), a specific role (Chief Risk Officer), and a specific internal program (Cybersecurity Incident Response Plan).


reasoning: The paragraph describes internal security training practices, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications and experience of specific cybersecurity management roles (CISO and VP of Information Security), making it a clear Management Role disclosure.


reasoning: The paragraph describes internal organizational processes and team collaboration regarding risk management and vendor onboarding. It does not contain any specific facts (dates, named firms, specific tools, or unique programs) that would elevate it beyond boilerplate descriptions of internal functions.


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on the company's oversight of third-party service providers and their associated risk management processes, making 'Third-Party Risk' the most appropriate category. It contains no specific names, dates, or unique identifiers, resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes the company's general approach to using third-party service providers as part of its risk management process. It does not name specific vendors or provide unique details, making it generic boilerplate.


reasoning: The paragraph explains that the company is a blank check company with no operations and therefore no cybersecurity risk, which constitutes a disclaimer rather than a substantive disclosure of governance, management, or risk processes.


reasoning: The paragraph consists entirely of high-level, aspirational statements about the company's commitment to safety and cybersecurity without describing specific processes, governance, or incidents.


reasoning: The paragraph describes the company's internal incident response plan, which falls under Risk Management Process. It contains no specific facts, named roles (CEO is excluded per instructions), or frameworks, making it generic boilerplate.


reasoning: The paragraph explicitly addresses the company's lack of internal risk management processes, which falls directly under the Risk Management Process category.


reasoning: The paragraph focuses entirely on the Audit Committee's oversight responsibilities regarding cybersecurity risks and incident response, making 'Board Governance' the primary category. It contains no specific facts (Audit Committee is considered generic governance, and 'management' is generic), resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes internal security training and awareness programs, which are standard components of a company's risk management process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management objectives and processes. It is classified as Firm-Specific because it identifies a unique internal body ('Technology Leadership Centre') and a specific cybersecurity-related role ('Chief Technology Officer').


reasoning: The paragraph focuses on the board of directors' oversight role regarding cybersecurity risks and enterprise risk profiles. It contains no specific facts, named committees, or unique identifiers, relying entirely on generic descriptions of governance activities.


reasoning: The paragraph focuses entirely on the Board of Directors' oversight responsibilities regarding cybersecurity, making 'Board Governance' the correct category. It contains no specific facts, named committees, or unique identifiers, resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes the company's internal cybersecurity program, governance structure, and risk management framework. While it mentions third-party risk, it is presented as a component of the broader internal risk management process rather than the central topic.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and references risk factors, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph explicitly identifies specific management roles (CISO, VP of IT, Chief Compliance and Privacy Officer) responsible for cybersecurity oversight, making 'Management Role' the primary focus.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Director of IT) involved in the cybersecurity program, which takes precedence over the brief mention of the Board.


reasoning: This paragraph is a standard forward-looking disclaimer regarding the inherent limitations of cybersecurity controls and risk management, containing no substantive or specific details about the company's actual operations.


reasoning: This paragraph provides a standalone materiality conclusion regarding cybersecurity threats without referencing any specific incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management structure, specifically detailing the roles and committees responsible for cybersecurity oversight and implementation.


reasoning: The paragraph describes internal security measures and incident response planning, which are standard components of a risk management process, without providing any specific details or unique identifiers.


reasoning: The paragraph describes the company's internal incident response and vulnerability management processes, making 'Risk Management Process' the most appropriate category. It is classified as 'Firm-Specific' because it identifies a specific, non-generic role ('Vice President of Operational Engineering') involved in the escalation process.


reasoning: The paragraph focuses on the company's due diligence and contractual requirements for vendors, which is the definition of Third-Party Risk. It is Firm-Specific because it names 'PSCM' as the entity performing these actions.


reasoning: The paragraph discusses the company's general approach to implementing security controls and the inherent limitations of those controls, which falls under internal risk management processes. It contains no specific details, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Head of Cybersecurity, which places it squarely in the Management Role category. While it mentions the Board and Audit Committee, these are secondary to the description of the management role's function.


reasoning: The paragraph describes the company's internal process of using third-party providers to evaluate their cybersecurity program, which falls under Risk Management Process. It contains no specific facts, named entities, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk assessment, monitoring, and policy frameworks, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it references specific standards (CIS and FERPA) without providing unique, firm-specific details like named tools, specific dates, or internal team compositions.


reasoning: The paragraph describes the company's internal monitoring and testing processes, which falls under Risk Management Process. It is classified as Firm-Specific because it references 'OCC regulatory exams', which is a specific regulatory body relevant to the company's operations.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies the CISO role and a specific internal program, the 'Cybersecurity Incident Response Plan'.


reasoning: The paragraph describes internal security practices like penetration testing and vendor review processes, which are standard components of a risk management program. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the specific management roles responsible for the company's information security program, identifying the CIO, CTO, and Information Security Officer.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment methodologies, and operational security controls (e.g., network segmentation, patch management), which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or specific roles, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for risk management and security controls, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal enterprise risk management (ERM) process and how it identifies and monitors cybersecurity risks, which falls squarely under Risk Management Process. It contains no specific dates, named tools, specific roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph consists entirely of forward-looking disclaimers and a cross-reference to Item 1A, containing no substantive cybersecurity disclosure.


reasoning: The paragraph focuses on identifying specific management roles (SVP/IT Manager and ISO) and their qualifications, making it a clear Management Role disclosure.


reasoning: The paragraph describes general internal security measures (firewalls, anti-malware) which falls under the company's internal risk management processes. It contains no specific facts, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks without describing any specific incident, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it Generic Boilerplate.


reasoning: The paragraph focuses on the company's oversight of third-party vendors during procurement and contracting, which is the central topic of Third-Party Risk. It contains no specific facts, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to risk management, specifically mentioning penetration testing and collaboration with external experts, which are standard components of a cybersecurity program. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the specific management roles (Cybersecurity Incident Manager, VP Security) and their responsibilities in the incident response process, which aligns with the Management Role category.


reasoning: The paragraph focuses on the company's reliance on third-party service providers and the risks associated with them, which is the central topic of Third-Party Risk. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the internal process for assessing potential cybersecurity incidents, specifically detailing the role of a named internal committee and specific management roles involved in the response workflow.


reasoning: The paragraph focuses on the roles and responsibilities of the CCO and CISO in managing cybersecurity risks, making 'Management Role' the primary category. It qualifies as 'Quantified-Verifiable' because it contains multiple specific facts, including a specific start date for the CISO and quantified years of experience for the CCO.


reasoning: The paragraph describes the company's internal cybersecurity program, controls, and assessment processes, which falls under Risk Management Process. It is classified as Firm-Specific because it claims specific certifications (HITRUST and SOC 2 Type II), which goes beyond merely naming frameworks.


reasoning: The paragraph focuses on the leadership of the Information Security Department, specifically identifying the CIO and their reporting lines and responsibilities, which aligns with the Management Role category.


reasoning: The paragraph focuses on the reporting lines and responsibilities of a specific management role (Senior Director of Information Technology) regarding cybersecurity oversight.


reasoning: The paragraph focuses on the responsibilities of executive management regarding cybersecurity oversight, which falls under Management Role. It contains no specific facts, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including risk assessments, asset identification, and third-party oversight, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it explicitly references the NIST framework but lacks other firm-specific or verifiable facts.


reasoning: The paragraph focuses primarily on the qualifications, reporting lines, and responsibilities of the CISO, making 'Management Role' the most accurate category.


reasoning: The paragraph focuses on the oversight responsibilities of the Technology Committee, which is a board-level committee, placing it squarely in Board Governance.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management, including policies, monitoring, and training, which falls squarely under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the composition, leadership, and reporting structure of the company's internal 'Cybersecurity Council,' which is a management-led body. While it mentions board oversight, the primary subject is the management-level council and its specific roles.


reasoning: The paragraph discusses the company's internal approach (or lack thereof) to risk assessment and management processes, even though it explicitly states they currently lack a formal policy.


reasoning: The paragraph focuses on the oversight responsibilities of the Audit Committee and the Board of Directors regarding cybersecurity, which falls squarely under Board Governance. It contains no specific facts, named cybersecurity roles, or unique programs, relying entirely on generic governance terminology.


reasoning: The paragraph focuses on the CISO's reporting lines and interactions with a specific committee (IOC), which falls under the Management Role category.


reasoning: The paragraph describes the company's internal plans for security awareness training and policy updates, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph explicitly defines the cybersecurity responsibilities of a specific management role (VP of IT and Facilities), which falls under the Management Role category.


reasoning: The paragraph is a standard forward-looking risk disclaimer stating that no incidents have occurred and describing potential generic consequences, which falls under None/Other.


reasoning: The paragraph describes the company's internal approach to threat monitoring, testing, and incident response capabilities, which falls under Risk Management Process. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes general internal security operations and monitoring activities without referencing specific frameworks, roles, or tools, making it a standard description of risk management processes.


reasoning: The paragraph describes general internal security procedures and risk management activities, such as monitoring and backup protocols, without referencing specific tools, frameworks, or unique organizational entities.


reasoning: The paragraph describes the company's internal incident response protocols and risk mitigation strategies. All mentioned roles (CEO, CFO, etc.) and committees are generic, and the policy name is a generic internal reference, resulting in a classification of Generic Boilerplate.


reasoning: The paragraph describes the scope and impact of a specific cybersecurity incident, which is the definition of Incident Disclosure. It contains no specific dates, named third-party firms, or other hard verifiable facts from the provided list.


reasoning: This paragraph is general forward-looking cybersecurity risk boilerplate (dependency on digital technologies, potential breaches, and “not materially affected” language) without describing an internal process, specific roles/committees, named standards/tools, specific incidents, or firm-unique details.

provider: openai


reasoning: This paragraph is a forward-looking/section cross-reference statement about potential risk factors and does not describe any internal cyber risk management process or an actual incident. The only specificity is a general reference to a risk factor caption, which is not substantive disclosure in this paragraph.


reasoning: The paragraph focuses on the Board’s oversight of cybersecurity risk (presentations, incident reporting, and annual discussion). However, it provides no company-specific roles beyond generic titles and no named committees, frameworks, systems, dates, or other firm-unique details.


reasoning: The paragraph centers on the Information Security Officer’s role, reporting line to the CRO, and responsibilities for cybersecurity activities, which is management-role governance.


reasoning: This paragraph is a cross-reference to the risk factors section and includes generic risk language without substantive cybersecurity governance, management roles, internal processes, third-party oversight, or incident details.


reasoning: The paragraph describes the company’s own information security/risk management programs (how they assess and manage risks), not board oversight or an incident. It names ISO and NIST frameworks and the Identify/Protect/Detect/Respond/Recover concepts, making it Sector-Adapted rather than firm-specific.


reasoning: The paragraph describes the company’s internal/cross-functional process for identifying, assessing, and managing cybersecurity threats (monitoring, scanning, and assessments). Third-party IT administrators/providers are referenced as part of this internal risk-management approach rather than as the central topic of vendor oversight.


reasoning: The paragraph describes Emergent’s internal cybersecurity program alignment with its Enterprise Risk Management Program, including how risks are assessed, mitigated, monitored, and reported (a risk management process). It includes firm-specific internal program names (ERM/ERA) and a specific structure detail (12 risk categories).


reasoning: The paragraph describes the company’s own processes for assessing, identifying, and managing cybersecurity-related material risks and integrating them into enterprise risk management. It does not reference any incident, named roles/committees, specific dates, or specific tools/standards, so it remains generic.


specificity_confidence: medium

reasoning: The paragraph is centered on the Board of Directors’ responsibility and oversight of cybersecurity risk, including how the HSE Director reports to the Board and how the Board reviews cybersecurity processes and incidents.


reasoning: The paragraph’s central topic is oversight of third-party consultants/service providers for cybersecurity risk assessment and safeguard monitoring, including a requirement that providers certify security measures and promptly report suspected breaches. It contains no firm-specific named entities, dates, tools, or quantified details, so it is otherwise boilerplate.


reasoning: The paragraph is explicitly about the Board’s Audit Committee oversight of cybersecurity risk management, including review and discussion cadence and reporting to the full Board.


reasoning: The paragraph is explicitly about board-level oversight and delegation to a board audit committee, including reporting to that committee.


reasoning: The paragraph primarily describes the company’s internal risk management/cybersecurity program and how it is integrated into ERM, including how the CISO and related roles review and manage security. Board involvement is present but is not the main subject compared with the company’s own risk management processes.


reasoning: The paragraph is primarily about the Board’s responsibility for overseeing cybersecurity risk management, with supporting details about the ERM framework and committee/management structures.


reasoning: The paragraph is forward-looking and contains generalized statements about cybersecurity risk without describing an actual incident, board/management roles, or a specific internal process. It mainly includes boilerplate risk language and a cross-reference to a risk factor.


reasoning: The paragraph describes the Trustee’s internal cyber risk management program and related controls, assessments, and integration into its risk management process. However, it contains no specific cybersecurity roles, named committees/teams, identifiable internal programs, products/tools, third-party firms, or concrete dates/durations—only generic descriptions of common practices and “recognized best practices and standards.”


reasoning: The paragraph describes the company’s internal risk identification, threat review, control selection, and a process for mitigating risks from third-party service providers as part of its overall risk management system.


reasoning: The paragraph describes the company’s own cybersecurity/vulnerability management approach and incident response planning. Although it mentions escalation to the Audit Committee/Board, the central topic is the internal risk and incident response program, not board oversight as the primary subject.


reasoning: The paragraph describes the company’s internal procedures for notification, investigation, risk-level assignment, escalation, and incident mitigation/response planning (including a 24-hour reporting requirement), which is central to its risk management process.


reasoning: The paragraph centers on the Audit Committee’s oversight responsibilities and briefing/reporting structure for cybersecurity risk. It also includes firm-specific named entities like the ERM Committee and the CIO as reporting sources.


reasoning: The paragraph describes the Company’s own cybersecurity policies, controls, and risk-assessment process (how risks are assessed, evaluated, prioritized, and used to update security programs). It also names specific security frameworks (CIS Critical Security Controls and PCI DSS), making it company-specific enough to distinguish from boilerplate.


reasoning: The paragraph describes the company’s internal cybersecurity/risk activities (incident response plan, monitoring, mitigation measures, risk assessments, and testing). It contains no firm-unique identifiers, named roles/committees, tools, third parties, dates, or quantified facts that would make it firm-specific.


reasoning: The paragraph describes the company’s own cybersecurity preparedness and internal risk-management practices (incident response plan, tabletop exercises, BCDR plans, risk-based control selection). It contains no firm-specific roles, dates, named tools/standards, or other qualifying specific facts.


reasoning: The paragraph is explicitly about board/committee oversight responsibilities for cybersecurity risk and the creation/requirements of a named Cybersecurity Risk Subcommittee.


reasoning: The paragraph’s grammatical focus is on the named management cyber roles (CDIO/CISO) and their reporting line and oversight responsibilities, including quarterly briefing attendance to a specific committee (TCRC).


reasoning: The paragraph describes Alternus’s internal cybersecurity risk approach, team activities, monitoring/assessment, and how results are incorporated into its information security policy and enterprise risk review process, rather than an incident or board/management role.


reasoning: The paragraph centers on the Audit Committee and full Board oversight of cybersecurity risk and reporting/briefing cadence. However, it contains no company-unique cybersecurity facts beyond generic governance language, and “Audit Committee” is a standard generic committee reference.


reasoning: The paragraph centers on the Board and the Board’s Audit Committee overseeing the cybersecurity program. It also references the NIST Cybersecurity Framework, making the content more than generic boilerplate but not providing company-unique operational details.


reasoning: The paragraph describes the company’s own incident identification and response processes and tools used to detect and respond to cyber incidents (including monitoring via a security incident/event manager and testing). It is not centered on vendor security oversight as a contractual requirement, so it fits Risk Management Process rather than Third-Party Risk.


reasoning: The paragraph describes OFS Advisor/IT Department cybersecurity risk management policies, including vulnerability management, assessments, and monitoring, and how resources are allocated—so it is primarily an internal risk management process.


reasoning: The paragraph centers on the audit committee and board oversight of cybersecurity risks/incidents, with management roles described mainly in support of that oversight.


category_confidence: low

reasoning: The paragraph primarily provides materiality/risk conclusions about cybersecurity incidents (no material impact; no currently known material incidents; general risk of phishing/ransomware) rather than detailing internal cyber processes or an incident narrative. Board oversight is mentioned briefly, but the key disclosure is the stated lack of material financial impact and likelihood.


reasoning: The paragraph centers on specific cyber/security leadership (Director, IT Infrastructure & Security) and describes reporting relationships for security oversight, making Management Role the best fit.


reasoning: The paragraph centers on evaluating and imposing security requirements on third-party providers/vendors (security terms, incident/data breach notification, encryption, data disposal), which is the core of third-party risk oversight rather than an internal risk-management process.


reasoning: The paragraph is centered on the CISO’s role and responsibilities (reporting/ownership of cybersecurity risk, governance, compliance testing, remediation, and security awareness), making it a Management Role disclosure.


reasoning: The paragraph’s grammatical focus is board/Audit Committee oversight and reporting on cybersecurity risk and incidents. However, it does not include any firm-unique or cybersecurity-specific named roles/committees/tools beyond generic references (e.g., Audit Committee, CEO/CFO, quarterly reporting, outsourced managed service provider).


reasoning: The paragraph describes Equifax’s own incident detection and response processes (plans, exercises, preparedness) and ties them to NIST CSF functions, which makes it an internal risk management process description rather than an incident narrative or governance item.


reasoning: The paragraph centers on the Board/Audit Committee delegating and receiving oversight via a named “Cybersecurity Subcommittee,” including its establishment and membership.


reasoning: The paragraph is primarily about the company’s information security management structure and qualifications, including the CISO’s leadership role, reporting line to CITO and CEO, and detailed education/certification credentials.


category_confidence: medium

reasoning: The paragraph focuses on internal cybersecurity monitoring and response activities (assessment review, metrics, and an incident response/notification plan) rather than a board-oversight-only description. It also identifies the CIO and the ERM Committee as specific organizational elements.


reasoning: The paragraph is largely forward-looking and risk/disclaimer language about limitations of preventative measures and references to other sections. It does not provide a concrete cybersecurity incident narrative or describe a specific internal risk management process beyond generic statements.


reasoning: The paragraph focuses on the potential material business/financial impact of cybersecurity threats and notes that no material breaches have been identified, with a cross-reference to Risk Factors. It also mentions incident assessments involving executive officers, but without any firm-specific cyber roles, dates, tools, systems, or incident details.


reasoning: The paragraph is explicitly about board/committee oversight of cybersecurity risk, including the Audit Committee’s role and how it receives incident information.


reasoning: The paragraph describes the company’s internal risk management structure (ERM) and how it incorporates cybersecurity inputs (information security action plans from CISO/CDO) into risk decision-making. It is not primarily about board oversight or an external incident, and vendor oversight is not central.


reasoning: The paragraph narrates a real cybersecurity incident (when and how user data was accessed/downloaded) and describes post-incident response actions and affected account context (23andMe.com accounts).


reasoning: The paragraph describes the company’s own cybersecurity program elements (controls, monitoring, incident response procedures, access controls, and testing) aimed at reducing cyber risk. It also includes a firm-specific fact about maintaining ISO 27001 certification.


reasoning: The paragraph references a past cybersecurity incident and focuses on materiality/financial impact language about whether future incidents will affect operations and financial condition, with no detailed incident scope or response actions.


reasoning: The paragraph describes the company’s own cybersecurity risk management program and how it identifies, assesses, and manages cybersecurity risks, including named frameworks used to design and assess it.


reasoning: This paragraph is forward-looking and boilerplate (states no material incident to date, immaterial expenses, and refers to Item 1A). It does not describe a real incident, internal risk process, or board/management roles with any cybersecurity-specific detail.


reasoning: The paragraph describes the company/affiliate’s internal cybersecurity posture assessments and processes (patch/vulnerability management, DR/BC considerations, monitoring), which are components of risk management. It does not include qualifying named roles, committees, dates, tools, standards, or other firm-unique cybersecurity facts from the IS list.


reasoning: This paragraph is generic forward-looking risk-factor language about cybersecurity threats and prevention, with no incident description, no named roles/committees, no specific process details, and only a cross-reference to another section.


reasoning: The paragraph describes the company’s own cybersecurity training and readiness activities (awareness training, simulations, tabletop exercises, incident response preparedness), which are internal risk-management processes. It contains no firm-specific roles, dates, tools, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company’s internal cybersecurity measures and how it assesses and manages cybersecurity risk, including incorporation into its ERM program and evaluation against the NIST Cybersecurity Framework. Board/management are mentioned only in passing, while the main topic is the firm’s risk management process.


reasoning: The paragraph centers on the identification and qualifications of the Chief Information Security Officer and the reporting/oversight structure, which fits the Management Role category.


reasoning: The paragraph’s core focus is oversight of third-party providers through charter-based expectations, pre-engagement security assessments, and ongoing monitoring by the Information Security Department. It also mentions training and cyber insurance, but the vendor security program is the central disclosure.


specificity_confidence: low

reasoning: The paragraph focuses on the company’s own information security evaluation/testing approach (training, assessments, and refinement by senior management), with third parties included as part of that process. Although it mentions external experts and activities, it does not provide named firms, dates, tools, or other verifiable specifics, making it non-firm-specific boilerplate.


reasoning: The paragraph centers on the named cybersecurity management role (VP of IT/Information Security Officer) and describes reporting, responsibilities, and committee participation, making it primarily Management Role content.


reasoning: The paragraph primarily describes the company’s intended internal risk management program and cybersecurity processes (identification/assessment/treatment, monitoring, reviews, vulnerability management, testing, and ongoing assessments). Board oversight is mentioned only as context and does not drive the paragraph’s main substance.


reasoning: The paragraph describes the company’s general cybersecurity risk management processes (assess/identify/manage risks affecting confidentiality, integrity, availability) but provides no incident details and no firm-specific elements like named roles, dates, tools, standards, or systems.


reasoning: The paragraph narrates a specific cybersecurity incident (unauthorized access), the company’s containment/response actions, and resulting business disruption. It also includes a concrete date (March 10, 2024), making it firm-specific and verifiable.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized third-party access), the company’s response actions (activated cyber incident procedure; engaged external cybersecurity experts; notified law enforcement), and the operational impact (disruptions/limited access to financial and operating reporting systems).


reasoning: The paragraph describes an internal security governance body (ISC) that sets information security initiatives/priorities and is led by the CISO, indicating an internal risk management process rather than board oversight. It includes multiple firm-specific verifiable facts such as the ISC name and CISO qualifications/certifications (plus tenure).


reasoning: The paragraph is explicitly about Board/Audit Committee oversight and briefing cadence with the CSO, which makes it board governance rather than internal risk processes or incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access), provides scope of accessed data and affected systems (Dropbox Sign infrastructure), and outlines incident response actions and ongoing investigation.


reasoning: The paragraph describes a real, ongoing cybersecurity incident (unauthorized access and exfiltration from employee email accounts) and subsequent attempts to access source code repositories and internal systems, including investigation status.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access), the company’s response actions, and the operational impact (disruptions and limited access to business applications, including financial and operating reporting systems). It includes a specific incident date, but no named tools/firms or quantified amounts, so it is Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the status and impact of a real cybersecurity incident (third-party access removed, data theft/destruction, affected systems/functions, restoration and continued operations), which is characteristic of incident disclosure.


reasoning: The paragraph describes a real cybersecurity incident (what data was obtained, scope of customer accounts, what was not affected) and outlines ongoing investigation, regulator involvement, and penalty uncertainty.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access and exfiltration), includes a timeline of when it was detected and remediated, and provides scope/affected accounts and impact statements, which are core elements of Incident Disclosure.


reasoning: The paragraph describes an actual cybersecurity incident and its scope (access to customer personal information), along with response actions and impact/notification statements. It is therefore an incident disclosure rather than a general risk process or governance statement.


reasoning: This paragraph describes a specific ongoing cybersecurity incident (unauthorized access and exfiltration of video-meeting/screen images), ransom threat behavior, and the company’s response and expected operational/financial impacts tied to being offline.


reasoning: The paragraph describes a real cybersecurity incident (including the unauthorized access event, business disruption, and remediation status) and the Company’s response actions, which fits Incident Disclosure.


reasoning: The paragraph describes a real cybersecurity incident (defaced website), includes dates and the affected web address, and explains response actions (restoration, taking the site down, temporary page), so it fits Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (illegal access, temporary limitation of IT system access, halted production, and data exfiltration) along with response and notification actions. It contains no firm-unique identifiers such as dates, affected system names, or named third parties, so specificity is treated as generic.


reasoning: The paragraph describes an actual cybersecurity incident with specific unauthorized access and exfiltration details, including dates, affected data types (client information/PII, administrative/user data), and operational/account scope, along with response actions.


reasoning: This paragraph discusses materiality expectations and potential future financial impact of an incident but provides no concrete incident details (what happened, affected systems/data, or specific timelines). It is therefore best categorized as strategy/financial materiality integration rather than incident disclosure.


reasoning: This paragraph is a forward-looking statements safe-harbor disclaimer and does not describe any specific cybersecurity incident facts, governance, roles, or internal processes. It contains no unique, verifiable details beyond general references to an “Incident.”


reasoning: The paragraph describes the scope and contents of the affected data (what is included/excluded, e.g., call/text records, telephone numbers, interaction counts/durations, and some cell site identifiers), which is characteristic of incident/disclosure disclosures. However, it does not include any extractable ✓IS facts like named roles/committees, specific dates, named tools/vendors, or quantified verifiable details, so it is treated as Generic Boilerplate for specificity.


reasoning: The paragraph describes a real cybersecurity incident with a specific date and incident mechanics (unauthorized access, encryption of critical applications, exfiltration) plus operational impacts (delayed billing/collections/payments) and remediation activities, which squarely fits Incident Disclosure.


reasoning: The paragraph describes an actual cybersecurity incident with threat-actor file exfiltration, evaluation of the exfiltrated data, and downstream effects (personal information exposure and client notifications). It contains no extractable firm-specific details such as named roles/tools, exact dates, amounts, or named third parties from the allowed ✓ list.


reasoning: This paragraph describes a specific cybersecurity incident (detection date, what the threat actor did, and impacts to systems and operations) and the response actions taken, which is characteristic of incident disclosure.


reasoning: The paragraph focuses on material financial/operational impact assessment (earnings and sales) tied to the incident, with specific quarter/date references, but it does not provide an incident narrative or incident scope details beyond referencing “Affected Systems.”


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access to file systems), the response actions taken (incident response/business continuity protocols), and operational impact (temporary interruption), with a specific discovery date.


reasoning: The paragraph describes an actual cyber incident’s operational impacts (inventory replenishment, order fulfillment, e-commerce demand, wholesale shipment delays) and the company’s restoration status, which is characteristic of incident disclosure.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access and data exfiltration), includes incident investigation/containment/remediation actions, and provides affected scope (mailboxes) and timeline (May 2023, notified Dec 12, 2023). It also names the threat actor (Midnight Blizzard/Cozy Bear), making it highly specific.


reasoning: The paragraph narrates a real cybersecurity-related disruption/incident, describes response and remediation steps, and provides concrete operational impact and restoration dates.


reasoning: The paragraph discusses an ongoing investigation of unauthorized access tied to the reported security/operational incident, including operational effects (website offline, delayed communications) and an assessment of materiality/impact on IP and customer or stakeholder proprietary information.


reasoning: The paragraph focuses on materiality of the incident’s financial impact and insurance coverage/cost treatment, without describing what the incident did or governance/roles/process details.


reasoning: This paragraph describes a real cybersecurity incident’s operational impact and resolution status, and includes a quantified cost estimate with specific dates/expense period.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized occurrences), the company’s response actions (investigation, incident response plan activation, shutting down systems), and incident timeline with ejection date, which fits Incident Disclosure.


reasoning: The paragraph describes a real cybersecurity incident affecting the Company’s systems (attributed to CDK) with timing (June 19, 2024), restoration status, and resulting operational disruptions through July, along with affected system/application scope.


reasoning: The paragraph focuses on remediation-related evaluation, reimbursement through cybersecurity insurance recoveries, and explicit conclusions about whether the incident will or has materially impacted financial condition/results, without providing incident narrative or affected systems scope.


reasoning: The paragraph provides a preliminary financial estimate of incident-related expenses and states the impact is still being assessed, but it does not describe what the cybersecurity incident involved or its operational details. This aligns with incident-related financial impact assessment (Strategy Integration).


reasoning: The paragraph describes a specific real cybersecurity event (a ransomware incident), including when it occurred and what was determined during ongoing investigation (originating from a vulnerability of a third-party firewall service provider).


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity), the attacker action (encrypting data files), containment/response steps (activating an incident response plan, shutting down systems), and concrete operational impacts (manufacturing facilities not operating; order fulfillment impacted).


reasoning: The paragraph describes the impact of an actual cybersecurity incident on operations (halted operations, return to near capacity, restoration timing) and remediation actions (new IT infrastructure and engaged cyber security experts), indicating an incident narrative rather than general risk management.


reasoning: The paragraph describes financing/liquidity actions (interest and rent payment waivers) tied to cybersecurity incident remediation, including the dollar amount of additional capital, without narrating the incident’s technical details or affected systems.


reasoning: This paragraph describes an actual cybersecurity-related disruption event (originating from CDK) with specific impacted systems (DMS/CRM), restoration status, and ongoing outages, which constitutes incident disclosure.


reasoning: The paragraph describes an actual detected cybersecurity incident, including incident response/continuity actions, network isolation causing business disruption, and investigation steps with notifications. This is incident narrative and scope/impact rather than a forward-looking or purely procedural disclosure.


reasoning: The paragraph discusses expected material financial/business impact and cost categories (digital sales loss, advisor fees, restoration costs) and offsets from cybersecurity insurance, but it does not describe the incident itself (what happened, scope, affected systems). This fits strategy/financial integration rather than incident disclosure.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized third-party access) and the company’s response actions, along with investigation status and materiality uncertainty, which is characteristic of incident disclosure.


reasoning: The paragraph focuses on anticipated financial materiality and expected guidance outcomes (i.e., impact on financial results and operating metrics), not on describing incident mechanics or cybersecurity controls.


reasoning: This paragraph describes a real cybersecurity incident, including the initial unauthorized access, containment/investigation/remediation actions, and operational disruptions/limited access with systems taken offline.


reasoning: The paragraph explains financial/operational impact from an unspecified incident (delayed revenue recognition, revenue loss from moving transactions, and one-time expenses) without providing incident narrative details (what systems were affected, what occurred, or response actions).


reasoning: The paragraph describes an ongoing investigation into a cybersecurity incident, states findings about whether customer/client data was accessed, and provides materiality conclusions about operational/financial impact. However, it contains no hard identifiers such as dates, named systems/tools/firms, or quantified scope, so it remains generic.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation and states what the threat actor accessed/exfiltrated (customer/employee information including PII) plus resulting actions (planned notifications and law enforcement notification), which is central to Incident Disclosure. However, it does not include any hard verifiable details from the ✓ IS list (e.g., dates, named firms/tools/systems).


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access), the company’s response actions (activating incident response, engaging external experts, notifying law enforcement), and operational impact (disruptions and limited access to financial and operating reporting systems). It includes a specific incident date, but no named tools/firms/products or quantified amounts, so it is Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph provides a materiality conclusion about cybersecurity risks/incidents (whether they have materially affected the company) and is framed as forward-looking risk language with a cross-reference to Risk Factors, without describing any incident or named processes/roles/frameworks.


reasoning: The paragraph describes detection of a real cybersecurity incident, the incident response and containment actions taken (including isolating Canadian operations), and customer service delays with recovery timing.


reasoning: This paragraph describes board and audit committee oversight of cybersecurity risk management. However, it relies on generic entities (board, audit committee) and non-specific cadence without cybersecurity-specific roles, tools, dates, or firm-unique details.


reasoning: The paragraph describes the company’s internal risk management approach for cybersecurity (integration into ERM, review cadence, and mitigation planning), with the board review as part of that process rather than describing an incident or third-party oversight.


reasoning: This paragraph describes an actual cybersecurity incident (the cyberattack on the U.S. health system and Change Healthcare services) and provides response/status details, including restoration efforts and assertions about data/system impact scope.


reasoning: The paragraph centers on the identification and qualifications of management cybersecurity roles (CIO, Information Security Director) and the supporting Cybersecurity Team, describing their responsibilities and experience.


reasoning: This paragraph is a cross-reference to the risk factors section and contains no substantive discussion of cybersecurity governance, incidents, or risk management processes. It only includes boilerplate direction to Item 1A.


reasoning: The paragraph is centered on the cybersecurity responsibilities of the company’s Chief Technology Officer and describes how that role oversees and reports on cybersecurity risk management processes.


reasoning: The paragraph describes general internal activities related to cybersecurity risk management (compliance and protection/responding), but contains no company-specific details, named roles, programs, dates, tools, frameworks, or standards.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized third-party access), response actions (containment, activating an incident response plan, remediation/recovery), investigation with external experts, law enforcement notification, and operational impact (temporary production halt while restarting). However, it contains no extractable firm-specific identifiers, dates, systems, tools, or quantified scope.


reasoning: The paragraph is focused on materiality/impact conclusions (no material incidents; incident-related expenses/penalties immaterial; no evidence of material concern) rather than describing a specific past incident narrative or internal risk processes.


reasoning: The paragraph describes the company/adviser’s internal cybersecurity assessment, controls, incident classification, escalation, and reporting workflow—i.e., risk management processes. It does not name any specific role, committee, framework, tool, date, or incident details, so it remains generic.


reasoning: This paragraph is explicitly about Board and board-committee oversight of cybersecurity (training, approvals, delegation to the Enterprise Risk Management Committee, and quarterly reporting). It contains a named non-generic committee and specific oversight/reporting details, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph is focused on a named individual’s responsibilities related to cybersecurity (hiring, integrating cyber risk into risk management, budgets, incident preparedness, and reviewing security assessments), so it is best categorized as Management Role. It does not include any cybersecurity-specific title (e.g., CISO/CIO), named committee/team/program, dates, tools, standards, or other firm-unique identifiers needed for firm-specific labeling.


reasoning: The paragraph describes HPE’s internal cybersecurity and digital risk management program (how it identifies, assesses, manages, and mitigates cyber risk) and the integrated standards/framework approach, which is primarily a risk management process description rather than governance or incident disclosure.


reasoning: The paragraph centers on named cybersecurity and technology leadership roles (CISO/CTO) and their qualifications and tenure, describing management ownership of technology/security activities.


reasoning: The paragraph centers on a management executive (chief financial officer) having primary responsibility for cybersecurity risk assessment/monitoring and receiving reports, with limited additional board committee mention. It does not include any cybersecurity-specific role (e.g., CISO/CTO) or other qualifying firm-specific named cyber governance structure beyond generic language, so it is treated as generic.


reasoning: The paragraph describes the company’s internal incident response and escalation procedures (incident management and escalation paths), which is a risk management process rather than an external incident disclosure or vendor issue.


reasoning: The paragraph focuses on the materiality/financial impact of cybersecurity risk and the related strategy update, rather than describing an actual incident. However, it lacks firm-specific details (e.g., named tools, roles, dates, or programs), so it is not sufficiently specific beyond generic disclosure.


reasoning: The paragraph centers on the Audit Committee’s oversight responsibilities for cybersecurity risk and describes reporting to that committee. However, it uses generic references (e.g., Audit Committee, senior leadership, cybersecurity risks) without any firm-specific cybersecurity roles, tools, dates, or named programs.


reasoning: The paragraph describes the company’s own cybersecurity program being integrated into internal risk management and related programs (ERM, business continuity/crisis management, compliance), which is characteristic of internal risk management/processes rather than incident disclosure or third-party oversight.


reasoning: The paragraph describes the company’s internal cyber risk assessment and mitigation activities (risk measurement/prioritization, treatment, and incident response plans) without centering on a board role, specific management role, a named framework, a vendor, or an actual incident.


reasoning: The paragraph centers on the AGM board of directors’ oversight of Apollo’s cybersecurity risk management within its ERM. It also states that the cybersecurity policies/practices are based on recognized frameworks from NIST and ISO.


reasoning: The paragraph discusses whether cybersecurity incidents have materially impacted business/financial conditions and states that resources (including cyber insurance costs) are expended, but it contains no named roles, tools, frameworks, dates, incidents, or firm-specific details beyond generic risk language.


reasoning: The paragraph discusses engaging external experts/third parties to evaluate and test the company’s cybersecurity risk management systems, but it provides no company-specific details, named firms/tools/standards, or concrete dates or quantified facts.


reasoning: The paragraph discusses the (negative) materiality conclusion of cybersecurity impacts on business/financial condition without describing any real incident or internal governance/process specifics. The language is broadly applicable and contains no firm-unique cybersecurity facts.


reasoning: The paragraph centers on identifying a specific individual (Jack Wang) and describing his responsibilities for cybersecurity risk management and incident reporting, with the board’s role mentioned only as the reporting destination.


reasoning: The paragraph is explicitly about the Board/Audit Committee receiving cybersecurity-related reporting and education, with governance subjects (Audit Committee and full Board) at the core.


reasoning: The paragraph describes the company’s internal risk-management activities (employee cybersecurity training/awareness, employee testing, and penetration testing) aimed at mitigating impact from cybersecurity incidents. It contains no firm-specific details (no roles, dates, frameworks, tools, or named programs).


reasoning: The paragraph provides a standalone materiality/impact conclusion (no material cybersecurity incidents and immaterial expenses/penalties) and directs readers to Risk Factors, without describing any specific incident or internal risk-management process.


reasoning: The paragraph describes how cybersecurity risk management is integrated into internal business/decision processes, and it focuses on the company’s ERM and IT risk management efforts rather than an incident, board oversight, or third-party controls.


reasoning: The paragraph describes board/committee oversight (Audit Committee reviewing cybersecurity risk management/strategy and receiving reviews) and incident escalation to upper management, so it fits Board Governance. It contains no cybersecurity-specific named roles/committees beyond the generic “Audit Committee,” nor any firm-unique program identifiers or dates, making it generic boilerplate.


reasoning: The paragraph describes the company’s own cybersecurity risk management program activities (committee briefings, employee training, and internal security policies), so it fits Risk Management Process rather than incident disclosure or third-party risk.


reasoning: The paragraph is explicitly about the Board establishing and leveraging a standing Cybersecurity Committee for oversight of the company’s cybersecurity program and cyber risk exposure.


reasoning: The paragraph centers on named management roles (Vice President of Information Systems and Chief Financial Officer) and describes their experience and responsibilities related to cybersecurity risk management.


reasoning: The paragraph describes the company’s internal cybersecurity incident response plan and its constituent activities (triage, severity assessment, investigation, escalation, containment, remediation). It does not provide an actual incident or focus primarily on vendor/security-provider oversight as a standalone third-party risk topic.


reasoning: The paragraph describes the company’s internal processes for assessing/identifying/managing cybersecurity risks, but it does so in generic terms without any named framework, roles, dates, tools, or company-specific details.


reasoning: The paragraph centers on specific cybersecurity and technology leadership roles (CISO and CTO) and their responsibilities/reporting relationships over the information security program.


reasoning: The paragraph makes materiality-style conclusions about whether known cybersecurity risks have materially affected the company, without describing any incident details or internal risk processes. It also cross-references the Risk Factors section rather than stating firm-specific cyber governance or management actions.


reasoning: The paragraph describes the company’s internal IT department responsibilities for assessing and managing cybersecurity risk and for monitoring prevention, detection, remediation, and incident handling as part of its risk management process.


reasoning: The paragraph describes the company’s internal audit process and how cybersecurity risks are assessed and reported, but it contains no cybersecurity-specific roles, named programs by unique identifier, frameworks, dates, or tools.


reasoning: The paragraph describes the company’s internal cybersecurity process (identifying/threat mitigation, incident controls, escalation procedures). It does not name any cybersecurity-specific roles, committees, teams, dates, tools, programs, or other firm-specific details beyond generic practices.


reasoning: This paragraph is a cross-reference to a Risk Factors section and does not provide substantive cybersecurity governance, management, process, third-party oversight, incident details, or quantified/material business impact within the paragraph itself.


reasoning: This paragraph is forward-looking boilerplate about potential cybersecurity incidents and insurance coverage, with a cross-reference to Risk Factors. It contains no incident narrative, named roles/committees/tools, or described internal processes.


reasoning: This paragraph is generalized forward-looking and risk-language about cybersecurity threats and potential impact, with no board/management roles, internal processes, vendor requirements, incident narrative, or named standards/tools/dates.


reasoning: The paragraph is centered on Board and Audit Committee oversight of cybersecurity risks, including the committee’s designated role and update mechanism.


reasoning: The paragraph is focused on the Board and delegation to the Audit Committee for cybersecurity oversight. It uses generic governance language and does not include cybersecurity-specific roles, non-generic committee names, dates, or other firm-unique details beyond the standard Audit Committee reference.


reasoning: The paragraph is centered on the board of directors’ oversight of risk management and cybersecurity programs, including escalation to the board/audit committee. It contains no qualifying firm-specific cybersecurity role/tool/date facts from the provided ✓ list.


reasoning: The paragraph describes internal cybersecurity preparedness activities (crisis simulation and enhancing monitoring/incident response/detection/forensics), with external firms supporting those efforts, rather than focusing primarily on vendor requirements.


reasoning: The paragraph describes the company’s internal cybersecurity testing and program reviews (ethical hacks, penetration tests, and program alignment) using independent third parties as a supporting mechanism. It does not provide firm-specific details (no named standards/tools/vendors/dates/roles), so specificity is generic.


reasoning: The paragraph describes the company’s own cybersecurity risk management activities and how they integrate into its Enterprise Risk Management process, which is clearly internal process-level content. It contains no firm-specific named roles, tools, dates, frameworks, or other verifiable details, making it generic boilerplate.


reasoning: The paragraph is explicitly about Board/audit committee oversight of cybersecurity risk, including delegation and reporting cadence, making Board Governance the primary category.


reasoning: The paragraph’s grammatical focus is the named cybersecurity leader (Director of Cybersecurity) and how they report/operate, which aligns with the management-role category.


reasoning: The paragraph describes the company’s third-party risk assessment and mitigation activities related to vendors/suppliers/business partners and third-party incidents, making third-party risk the primary focus. It contains no firm-specific identifiers, named tools/frameworks, or verifiable details.


reasoning: The paragraph describes the company’s internal cybersecurity risk management processes, including how third-party provider risks are assessed and how third-party due diligence/oversight is conducted as part of those processes.


reasoning: The paragraph centers on a named management role (Vice President of Finance and Treasurer) being responsible for cybersecurity insurance policy coverage. While it also mentions internal planning and testing, the primary grammatical subject is the management responsibility for insurance coverage.


reasoning: The paragraph describes the company’s own cybersecurity measures (incident response, disaster recovery/BCP, risk assessments, encryption, monitoring, and training) to manage risks, which fits internal risk management processes. It contains no company-unique identifiers (e.g., named programs/tools), dates, or other specific verifiable facts.


reasoning: The paragraph describes the company’s internal information security practices (monitoring, DLP, remediation, tabletop exercises, security training) and how they are conducted through its own policies. It does not disclose any named roles/committees, tools/products, specific dates, or verifiable firm-specific details.


reasoning: The paragraph describes the company’s internal risk management approach by adopting and aligning with the NIST Cybersecurity Framework and related guidance/policies. It is sector-adapted because it names NIST but contains no firm-specific details (roles, dates, tools, or other unique facts).


reasoning: The paragraph describes internal processes to oversee cybersecurity risks from third-party providers and provides generic forward-looking materiality statements about impacts. It does not name any vendor oversight requirements or any firm-specific programs, tools, roles, committees, standards, or dates.


reasoning: The paragraph describes the company’s internal cybersecurity prevention/detection/mitigation workflow, including monitoring, severity assessment, and escalation through its incident response plan—i.e., an internal risk management process. It also identifies a specific management role (Senior Vice President, IT Operations) directing the information security team.


reasoning: The paragraph describes the company’s own vulnerability assessment and evaluation process (frequency, purpose, and how it reduces cybersecurity risk exposure), which is internal risk management rather than governance, incidents, or third-party oversight. It contains no company-unique program name, dates, tools, frameworks, roles, or other verifiable specifics.


reasoning: The paragraph describes a real cybersecurity incident, including what happened (illegal access and encryption), when it was first discovered, and immediate response actions (containment, internal investigation, engaging external specialists, restricting access).


reasoning: The paragraph primarily describes the company’s own cybersecurity risk management approach (adopting processes, risk-based assessment and management) as part of overall risk management. While it mentions board and an Audit Committee, those references are not specific enough (and the Audit Committee term is standard) to drive a Board Governance classification.


reasoning: The paragraph does not describe what happened or provide technical/operational incident details; it focuses on the materiality/impact assessment of an incident being ongoing and unknown. This aligns best with Strategy Integration (material impact assessment) rather than Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including detection date, unauthorized access, and concrete response actions (containment/remediation steps, activating an incident response plan, shutting down systems, and notifying law enforcement). It includes at least one firm-specific fact (May 1, 2024).


reasoning: This paragraph describes an actual cybersecurity incident (threat actor access and data exfiltration) and its scope includes personally identifiable information, along with notification actions to affected parties and regulators.


reasoning: The paragraph describes an actual cybersecurity event (unauthorized activity), actions taken to contain/assess/remediate, and incident response steps, including a specific response action tied to a date.


reasoning: The paragraph focuses on materiality/financial impact conclusions (no material impact; not reasonably likely to materially impact financial condition/results) and mentions assessing regulatory notification obligations, without describing incident specifics. It reads as a strategy/materiality disclosure rather than an operational incident narrative.


reasoning: The paragraph describes a real cybersecurity incident with a specific detection date, outlines incident response/business continuity actions, and states that regulators/law enforcement were notified and the impact was contained.


reasoning: The paragraph describes actions taken to remediate a cybersecurity incident and provides incident scope/impact (systems/network not compromised, no unauthorized transactions or money transfers). However, it contains no extractable firm-specific identifiers, dates, tools, or other ✓-listed facts for the specificity checklist.


reasoning: The paragraph focuses on a materiality/financial impact assessment of a disclosed incident (EPS amounts and effect size) rather than describing what occurred or mitigation steps. While it references the incident, the dominant content is the quantified earnings impact, which maps to Strategy Integration.


reasoning: The paragraph describes the company’s own cybersecurity controls and internal risk-management activities (e.g., detection/response, vulnerability management, DR/BCP, encryption, monitoring) rather than an incident or board/management role. Although it mentions “vendor risks management processes,” it is only one component within a broader internal control list and lacks any firm-specific identifiers.


reasoning: The paragraph describes the company’s internal incident-handling workflow (SOC operations, severity matrix, notification/escalation, triage, severity tiers), which is a risk management process rather than an incident narrative or board/management role.


reasoning: This paragraph describes the current findings from an ongoing cybersecurity incident investigation (no evidence of malware/ransomware and no evidence of current access) and ongoing efforts to assess extent and impact, which is core incident-disclosure content.


reasoning: The paragraph describes an ongoing investigation that links the current incident to earlier unauthorized access and exfiltration activity, including timing (May 2023, June 2023) and affected system (SharePoint files), along with response actions and an impact determination.


reasoning: This paragraph is a standard forward-looking statements disclaimer with no cybersecurity substance, incident narrative, governance, management roles, or risk/process details.


reasoning: The paragraph focuses on expected financial/operations impact from the incident (material impact for the quarter ended December 31, 2024; not material for full-year 2024) without describing what occurred in the incident. It is therefore best categorized as strategy/impact integration rather than incident disclosure or internal risk management.


reasoning: The paragraph describes a real cybersecurity incident, including unauthorized access and data encryption, along with immediate containment and remediation actions. It is clearly incident narrative rather than governance, process, or strategy.


reasoning: The paragraph provides forward-looking materiality/financial impact assessments (incident not reasonably likely to materially impact financial condition/results) and does not describe what systems/data were affected or incident specifics.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized activity) and the company’s response actions, including a specific operational step taken on a specific date (isolating systems from the Internet).


reasoning: The paragraph describes the real impact of a cybersecurity incident on operational functions (distribution, billing/collections, vendor payments) and provides incident-scoped status and recovery expectations with a specific date and a quantified revenue share.


reasoning: The paragraph describes a real cybersecurity incident and its operational impact (shipping/receiving/manufacturing), evidence of files taken, interim restoration efforts, and actions such as reviewing involved files and notifying individuals/regulators.


reasoning: This paragraph is a materiality/disclaimer statement about the impact of an (unspecified) cybersecurity incident on business operations and financial condition, without describing incident details or other firm-specific facts.


reasoning: The paragraph describes a cybersecurity incident progression (additional data exfiltrated) and confirms affected data types (PII and PHI) along with affected data custody (a subsidiary providing patient support services). However, it contains no ✓IS-specific details like named tools/firms, exact dates, or quantified scope figures.


reasoning: The paragraph provides a materiality/cost impact assessment (no material operating impacts, material non-recurring expenses in the first quarter) and mentions insurance, but does not describe what the cybersecurity event was.


reasoning: The paragraph references a real event timeline tied to the incident-disclosure delay under Item 1.05(c) and describes ongoing law-enforcement activity (apprehension) and the belief about whether the data is publicly available.


reasoning: The paragraph describes an ongoing investigation’s preliminary findings about a threat actor stealing consumer personal data, including the estimated scope of stolen data and what types of sensitive data were not implicated.


reasoning: The paragraph describes a real cybersecurity event (a ransomware incident), including discovery/response actions (containment, taking platforms offline) and subsequent steps like investigation and notifications.


reasoning: This paragraph provides a materiality/impact assessment of a disclosed incident (no material impact expected) and mentions ongoing remediation, but it does not describe what happened and contains no incident scope details beyond the generic statement of being limited to an internal area.


reasoning: The paragraph describes data exfiltration and relates it to specific categories of information, tying it to the company’s preparation of its 10-K. It also references the fiscal year ended August 31, 2025 and an expected mid-November release timeframe.


reasoning: The paragraph is a materiality/financial-impact assessment and forward-looking statement about costs and whether the incident may materially affect financial condition, without describing incident details, systems, or response actions tied to specific facts.


reasoning: The paragraph focuses on whether the incident is expected to have a material financial impact and mentions general risk exposures from the disruption, without describing what happened or any concrete incident scope or timeline. This aligns with strategy/financial materiality assessment rather than incident disclosure or internal risk/process details.


reasoning: The paragraph describes actions taken after the company became aware of a cybersecurity incident (investigation, mitigation, and notifications) and indicates unauthorized access to personal information, which constitutes incident disclosure. It contains no firm-specific identifiers such as named tools/firms, exact dates, or quantified impacts.


reasoning: The paragraph describes an active cybersecurity-related disruption (network interruption) and the scope/affected systems (limited to Change Healthcare systems) along with restoration efforts and response actions.


reasoning: The paragraph describes a real cybersecurity incident (illegal access, file/email impacts) and specific response context (wire payment misdirected and not recovered), which is the core of incident disclosure.


reasoning: This paragraph narrates a specific cybersecurity incident (unauthorized access by a threat actor), describes incident response actions (activate response plan, contain/assess/remediate), and includes operational impact (restored systems quickly) and a materiality conclusion.


reasoning: The paragraph provides quantified financial impact (additional expenses and unfulfilled revenue) attributed to a cybersecurity incident, but it does not describe what happened or the incident’s technical scope; this aligns with strategy/financial impact integration rather than incident narrative disclosure.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access) and the company’s response actions (activating its incident response plan) with an incident discovery timeline anchored to a specific date.


reasoning: The paragraph describes a specific cybersecurity incident (threat actor access/copying, investigation, and exfiltration) and provides concrete scope details about affected customer call/text records and relevant dates.


reasoning: The paragraph describes a real cybersecurity incident (detection of unauthorized occurrences), key response actions (investigation, activating an incident response plan, shutting down systems), and incident status (threat actor ejected on July 10, 2024). It includes a specific event date, but no hard quantities, tools, or third-party firm names beyond generic wording.


reasoning: The paragraph describes an ongoing cybersecurity incident with data exfiltration, investigation into whether personal information was taken, and potential legal/regulatory notifications—core incident-disclosure content. It contains no firm-specific identifiers, named tools/firms, or specific dates/quantities to raise specificity.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized activity), the company’s response actions (containment, assessment/remediation, isolating systems), and outcome (resumed operations). It also includes a specific incident-related date (December 20, 2023), making it firm-specific rather than generic boilerplate.


reasoning: This paragraph describes a real cybersecurity incident (unauthorized access) with timing, response actions (protocols, investigation, law enforcement notification), and containment/preservation assertions. It does not include enough hard verifiable facts to reach Quantified-Verifiable (only one clear date, with no named vendors/tools or dollar amounts).


reasoning: This paragraph is a standard forward-looking statements disclaimer and includes no cybersecurity governance, roles, risk processes, incidents, or strategy-specific materiality conclusions.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized third-party access) and provides affected-data scope (types of personal information) and scale (approximately 8.4 million users), which is characteristic of incident disclosure.


reasoning: The paragraph describes a cybersecurity event with detection and response actions (assessment, containment, remediation, isolating affected systems) tied to a specific detection date.


reasoning: This paragraph discusses an actual cybersecurity incident’s financial impact, including specific incurred expert expenses and operational disruption (lost production) with a quantified timeframe and the quarter ending June 29, 2024.


reasoning: This paragraph describes an actual cybersecurity incident (unauthorized activity and data exfiltration) including initial response actions and the potential presence of personal information, making it incident disclosure. It includes one specific date and a concrete incident impact detail, but not enough for Quantified-Verifiable.


reasoning: The paragraph provides forward-looking materiality/disruption expectations related to an incident (financial statement impact and disruption status) but does not describe the incident itself (what happened, affected systems/data).


reasoning: This paragraph only provides boilerplate materiality/financial impact language about the incident, without describing what happened, incident scope, systems/data affected, or any concrete cyber process details.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (containment, monitoring, access control reviews, and cooperation with regulators/law enforcement), which constitutes incident disclosure. It contains no firm-unique, named, dated, or tool-specific facts.


reasoning: The paragraph describes an actual cybersecurity incident response (activation of response protocols, containment by taking the network offline, investigation, restoration, monitoring, and notifications). However, it contains no extractable firm-specific details such as named tools, firms, exact dates, or quantified impacts from the provided ✓ IS list.


reasoning: The paragraph provides an update tied to a specific disclosed cybersecurity incident (Change Healthcare cyberattack) and mentions restoration progress and ongoing data assessment. It includes a concrete date for the related press release, but no quantitative metrics or named external tools/vendors.


reasoning: The paragraph provides a materiality/financial impact conclusion about an incident (no material impact; not likely to materially affect financial condition or results) without describing what happened or any specific affected systems/data scope.


reasoning: The paragraph provides a real incident timeline (ransomware, encryption, unauthorized disclosure) with specific dates and management’s materiality conclusions, which fits the incident-disclosure category.


reasoning: The paragraph provides a materiality/financial impact assessment of a cyber incident but does not describe what happened, nor any concrete incident scope or response actions. No firm-specific details beyond generic materiality language are provided.


reasoning: The paragraph describes an actual incident outcome and scope, stating what was not compromised and what affected data categories were included (e.g., masked SSNs, bank identifiers, government ID images). However, it contains no extractable ✓-list facts such as named roles/committees, specific dates, tools/firms, or other firm-unique identifiers.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation (exfiltrated files, assessing sensitive/personal information, and determining regulatory notifications). However, it provides no ✓-list firm-specific details such as dates, tools, roles, or named entities beyond generic incident language.


reasoning: The paragraph describes remediation outcomes (third party removed, access restored, and integrity/completeness confirmed) tied to affected information, which is characteristic of incident disclosure. However, it contains no named roles, dates, tools, products, or other firm-unique details.


reasoning: This paragraph is a standard legal/filing disclaimer about whether information is deemed filed and incorporation by reference; it contains no cybersecurity governance, process, incident, or strategy content.


reasoning: The paragraph describes a realized cybersecurity incident (unauthorized data exfiltration) and the company’s response actions (containment and investigation). The inclusion of a specific incident date makes it firm-specific rather than generic.


reasoning: The paragraph focuses on the Company’s internal process (Halliburton Management System and identifying effects) rather than describing a concrete incident event, scope, or impact.


reasoning: The paragraph describes an internal cybersecurity risk management process for evaluating third-party vendors (a risk-based vendor review), but it provides no firm-specific details or named standards/tools/dates.


reasoning: The paragraph is centered on board oversight of cybersecurity risks and mentions information flow via a committee and executive leadership. However, it uses generic terms (“board of directors,” “audit committee,” “annual basis”) without any cybersecurity-specific roles, unique committees, or firm-specific details from the ✓ list.


reasoning: The paragraph describes a real cybersecurity event (“unauthorized activity”) and the company’s response actions (activating a cybersecurity response plan, investigating, taking systems offline, notifying law enforcement, restoring systems, and assessing impacted data). However, it contains no firm-specific or hard verifiable details (no dates, tools, third-party names, or quantified scope), so specificity is generic.


reasoning: The paragraph describes integration of cybersecurity risk management procedures into the company’s enterprise risk management (ERM) program, but it does not provide any company-specific roles, named frameworks, dates, systems, or other verifiable details.


reasoning: The paragraph describes board and audit-committee oversight of cybersecurity risk management, but it provides no firm-unique details (e.g., no named cyber committee, dates, roles like CISO, or specific frameworks/tools).


reasoning: This is forward-looking boilerplate about potential cybersecurity risk and directs readers to another section, without describing any internal processes, named roles/committees, standards, incidents, or firm-specific facts.


reasoning: This paragraph describes board/committee oversight as the grammatical subject (the Committee receiving reports and reporting to the full Board). It does not include any named non-generic cybersecurity committee, specific cadence/date, or other firm-unique cybersecurity governance details.


reasoning: The paragraph describes an ongoing cybersecurity incident’s operational disruption at the subsidiary level and provides the company’s view on whether it will materially impact financial condition/results, which is incident-disclosure style content.


reasoning: The paragraph describes general cybersecurity and internal control enhancement but does not identify any specific internal program, named framework, roles, committees, or verifiable details from the disclosure.


reasoning: The paragraph describes ongoing remediation and efforts to reinforce systems and improve surveillance to prevent unauthorized occurrences, which is an internal risk management/process description. It does not provide concrete incident narrative details, dates, or affected system/data scope required for Incident Disclosure.


reasoning: The paragraph describes the company’s own cyber risk management program and how it integrates with enterprise risk management to address cybersecurity risks. It contains no named roles, frameworks, systems, tools, standards, dates, or other firm-specific facts.


reasoning: The paragraph is focused on identifying and describing the cybersecurity/information security officer role (Group Head) and her experience and start date, which is management-role content.


reasoning: The paragraph describes the company’s own cybersecurity program within its enterprise risk management process, focusing on assessing and managing cyber risks. It contains no named roles, committees, frameworks, tools, dates, or other firm-specific details.


reasoning: The paragraph describes oversight and evaluation responsibilities tied to a board-level Cybersecurity Committee, making Board Governance the primary category.


reasoning: The paragraph centers on an identified management individual (Mr. Tao) and his background/experience, which fits the Management Role category. It includes a verifiable quantitative detail ("more than 20 years").


reasoning: The paragraph discusses general reliance on software/infrastructure and mentions contractors/vendors without describing a specific cybersecurity risk management process, controls, frameworks, or any incident. It contains no extractable cybersecurity-specific roles, standards, products, dates, or other firm-specific facts.


reasoning: The paragraph provides a materiality assessment of the cybersecurity incident’s financial impact (no material impact; not reasonably likely to be material) without describing incident specifics. That aligns with Strategy Integration rather than Incident Disclosure or internal process categories.


reasoning: The paragraph describes a general purpose of the company’s cybersecurity program (protecting against common threat types) without any firm-specific elements, named frameworks, roles, or dates.


reasoning: The paragraph describes the company’s own incident response and recovery preparedness activities (frameworks, testing, simulations/tabletop exercises) but includes no named roles, dates, tools, or firm-specific identifiers. This is internal risk-management/process content, not an incident disclosure or third-party/vendor oversight.


reasoning: The paragraph discusses oversight and briefings between the board, an audit committee, and management on cybersecurity, but it contains no cybersecurity-specific roles, named cyber committees, dates, frameworks, or other firm-unique details beyond generic governance language.


reasoning: The paragraph provides generic statements about the board monitoring strategic risk and executive officers managing risks, with no cyber-specific roles, committees, or processes described.


reasoning: The paragraph discusses how cybersecurity risk management is integrated into the company’s enterprise risk management, which fits the Risk Management Process category. However, it contains no named roles, frameworks, dates, tools, or other firm-unique details beyond generic integration language, so it is treated as boilerplate.


reasoning: The paragraph centers on how the company evaluates and monitors third-party IT service providers’ cybersecurity using third-party data (Security Scorecard).


reasoning: The paragraph references the company’s IT team qualifications, but it does not identify a specific cybersecurity role, committee, team composition, named programs, or any verifiable details that would make it firm-specific beyond generic staffing language.


reasoning: The paragraph is a materiality statement about not experiencing a cybersecurity incident with business/financial impact, with no incident narrative, named roles, frameworks, or other company-specific details.


reasoning: This paragraph provides generic risk statements about potential cybersecurity threats without describing a company-specific program, roles, dates, tools, standards, incidents, or third-party oversight.


reasoning: The paragraph identifies named management/role holders (CIO and Director of IT Security, Risk and Compliance) as ISC members, along with their experience, making management role the central subject.


reasoning: The paragraph mentions third-party software/services (e-mail and cloud storage) and that they incorporate cybersecurity protections, but provides no named vendors, standards, roles, dates, or specific oversight requirements, making it non-substantive and indistinguishable from generic boilerplate.


reasoning: The paragraph discusses the company’s overall risk management approach and identifies that its cybersecurity program covers key areas, but it provides no named frameworks, tools, roles, dates, or company-specific details.


reasoning: The paragraph describes the company’s internal cybersecurity controls (PII policy compliance and training/testing cadence) but contains no firm-specific named roles, programs, standards, tools, dates, or other verifiable specifics.


reasoning: This paragraph describes generic remediation/eradication steps (remove malware, identify root cause, prevent recurrence) but does not reference any company-specific program, framework, roles, or incident details.


reasoning: The paragraph is primarily centered on the CSO and CISO’s role in staying informed and reporting on cybersecurity risks, with board-level reporting described as part of the communications chain.


reasoning: This is a short, boilerplate-style materiality/disclosure statement about not having significant breaches or related expenses, with no incident narrative or cybersecurity-specific details.