reasoning: The paragraph describes a management committee (IT Committee) approved by the board, detailing its composition (IT Director as chair, CISO, COO, CRO), meeting cadence, and the CISO's reporting line to the board. The primary actors are management-level roles and a management committee, not the board itself—the board is mentioned only as having approved the committee and as the recipient of annual reports. The IT Committee is a named non-generic committee and CISO is a cybersecurity-specific title (both on the IS list), yielding Firm-Specific. No QV-eligible hard facts (specific dates, dollar amounts, headcounts, named firms/tools/certifications) are present, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes a management committee (Information Technology Committee) approved by the board, its composition, meeting cadence, and reporting to the board.

Category analysis:
- The board approved the committee, but the paragraph is primarily about the committee itself - its composition, what it does, how often it meets
- The IT Committee is a management committee, not a board committee
- The CISO reports to the board annually - this is about management reporting up
- The primary actors are the management committee and the CISO

This is about management structure and reporting. The grammatical subjects are the committee and the CISO. The board is mentioned as having approved the committee and as the recipient of reports.

The paragraph focuses on the committee's structure and oversight function rather than individual credentials. It's describing what the committee does—governance, risk management, policies, and controls—not who the people are or their backgrounds. The key distinction is that this is fundamentally about the committee's role and processes, not a management role focused on a specific person. The organizational structure here is really about management oversight—who's on the committee and how they report—rather than specific cybersecurity processes or methodologies. Looking at the specificity markers, "Information Technology Committee" and "CISO" clearly fit the list, though some titles like "Chief Risk Officer" and "Information Technology Director" are close but not exact matches to what's defined.

When I count the hard verifiable facts—dates, dollar amounts, headcounts, named firms, tools, or certifications—there's nothing concrete here. Terms like "quarterly" and "annually" are just generic cadences. So I'm left with the IT Committee and CISO as firm-specific facts, but neither qualifies as QV-eligible, which puts this at Firm-Specific (3).

fact: Information Technology Committee

fact: Chief Information Security Officer

fact: Information Technology Director chairs the committee


content_category: Risk Management Process

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph describes how the company monitors and stays informed about cybersecurity risks through briefings, threat intelligence, and security tools. Applying the person-vs-function test: replacing 'Our IT Senior Director' with 'The Company' leaves a coherent process description, so this is about the function, not the person. 'IT Senior Director' is a generic IT leadership title (comparable to 'Director of IT' on the NOT list), not a cybersecurity-specific role like CISO or Director of IT Security. No named frameworks, tools, firms, dates, or other specific facts are present — all entities are unnamed ('internal security personnel,' 'external consultants,' 'security tools').

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes what the IT Senior Director does - stays informed, monitors cybersecurity efforts through briefings, threat intelligence, security tools. This is about what the person does functionally, not about who they are (credentials, background, etc.).

The grammatical subject is "Our IT Senior Director" - a management role. But the content describes processes/activities (monitoring, briefings, threat intelligence, security tools). Apply the person-vs-function test: if I remove "Our IT Senior Director," the paragraph describes monitoring and information-gathering processes. → Risk Management Process.

Wait, let me reconsider. The paragraph is about HOW the IT Senior Director stays informed. It's describing the person's activities in their role.

But when I apply the person-vs-function test more carefully - replacing the role with "the Company" - the sentence still works: "The Company takes steps to stay informed about and monitor efforts to prevent, detect, mitigate, and remediate cybersecurity risks." This reads as a process description, not a person description. → Risk Management Process.

Now checking specificity: "IT Senior Director" isn't explicitly listed in the IS criteria like "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security, HSE Director overseeing cybersecurity." It's similar to "Director of IT Security" but not quite the same.

Looking at the NOT list, I see "Head of IT," "IT Manager," and "Director of IT" are all flagged as generic IT leadership. "IT Senior Director" falls into that same category - it's a generic IT title, not a cybersecurity-specific one. Combined with the lack of named frameworks, specific dates, named firms, or named tools - everything here is just generic language like "internal security personnel," "external consultants," "security tools," and "threat intelligence."

→ Generic Boilerplate, Specificity 1.


category_confidence: high

reasoning: The paragraph describes the company's internal cybersecurity improvement projects — endpoint detection, planned SIEM implementation, vulnerability management expansion, and data migration — all of which are internal processes and tools. The specific fiscal year date (December 31, 2025) is one IS-list fact, reaching Firm-Specific. Note that 'SIEM' is a generic technology category, not a named product, and no named frameworks, tools, or firms are mentioned, so QV is not reached.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity improvement projects - logging/monitoring, vulnerability assessments, AI-driven endpoint detection, SIEM implementation plans, vulnerability management expansion, data migration project.

Category: This is about the company's internal cybersecurity processes, tools, and methodologies. → Risk Management Process

Specific facts:
- "For the year ending December 31, 2025" - specific date
- "AI-driven endpoint threat detection and prevention system" - describes a system but doesn't name a specific product
- "Security Information and Event Management (SIEM)" - generic term, not a named product
- No named frameworks, no named tools/products, no named roles

- The specific date "December 31, 2025" is the only IS fact present, making this Firm-Specific rather than Quantitative Verification.

fact: For the year ending December 31, 2025


reasoning: The paragraph describes the company's internal cybersecurity processes: risk assessment integrated into broader risk management, employee/contractor training, and continuous monitoring technologies. These are all internal process descriptions, making this Risk Management Process. The specific date 'December 31, 2024' is the only IS-list fact; training topics (browser safety, data protection, email fraud) and practices (awareness training, continuous monitoring) are common/generic and do not qualify. One specific fact yields Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity processes - policies, risk assessment, employee training, monitoring technologies. This is about internal processes.

Category: Risk Management Process - describes risk assessment, training, monitoring, internal controls.

Specific facts:
- "At December 31, 2024" - specific date
- "annual cybersecurity awareness trainings" - common practice, not specific
- "browser safety, data protection, and email fraud" - training topics, somewhat specific but generic training topics

Let me check the IS/NOT lists:
- "December 31, 2024" → specific date ✓ IS

- Training topics are fairly common across most companies, so they don't qualify as firm-specific. The only concrete fact here is the date itself, which gives me one IS item and therefore a Firm-Specific classification rather than Quantified Value.

fact: At December 31, 2024


reasoning: The paragraph primarily describes internal cybersecurity processes — designing safeguards, addressing gaps, monitoring effectiveness — with responsibility attributed to an IT consultant and Chief Compliance Officer. Applying the person-vs-function test, the first sentence is entirely about processes, and the second sentence assigns responsibility without describing the person's credentials or background, making this a process description with incidental role attribution. No named frameworks, no cybersecurity-specific titles from the IS list (CCO is generic C-suite; 'IT consultant' is not a cybersecurity-specific role), and no other firm-specific facts, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up (re-design, implement, maintain safeguards, monitor effectiveness) and assigns responsibility to an IT consultant who reports to CCO.

Category: The paragraph describes internal processes (safeguards, monitoring) and then attributes responsibility. The primary content is about what the company does (processes) with a brief attribution of who manages it. The person-vs-function test: remove the IT consultant/CCO mention and you still have a process description. But the second sentence is about reporting structure. The dominant content is split - first sentence is process, second is about who is responsible. I'd say Risk Management Process is dominant since the first sentence is all process and the second sentence's main point is organizational responsibility for those processes.

The roles mentioned here don't match the specificity criteria—CCO is a generic C-suite title that's excluded, and "IT consultant" isn't a cybersecurity-specific designation from the approved list. This reads as generic boilerplate without concrete details or named frameworks.


reasoning: The paragraph describes the company's own internal technical safeguards (firewalls, intrusion prevention/detection, anti-malware, patching, access controls, vulnerability assessments), which are all standard security practices. No named frameworks, tools, roles, dates, or firm-specific details are present—these controls could appear in any company's filing unchanged.

thinking:
Classify this paragraph.

Content: Describes technical safeguards - firewalls, intrusion prevention/detection, anti-malware, patching, access controls, vulnerability assessments. This is about internal cybersecurity processes/tools.

Category: Risk Management Process - describes the company's own internal technical controls and processes.

Specificity: No named frameworks, no named tools/products, no specific roles, no dates, no numbers. All items listed are common practices (firewalls, intrusion prevention, anti-malware, patching, access controls, vulnerability assessments). → Generic Boilerplate.


content_category: Strategy Integration

reasoning: The paragraph contains an explicit materiality assessment ('not aware of any cybersecurity threats that have materially affected or are likely to affect us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No specific facts from the IS list are present — all language is boilerplate materiality disclaimer.

thinking: Materiality assessment paragraph with cross-reference.


content_category: Board Governance

reasoning: The board and audit committee are the grammatical subjects performing oversight actions (oversees, discusses, receives reports), making this Board Governance. 'Head of IT' is on the IS-NOT list as a generic IT title (not cybersecurity-specific like CISO/CIO), 'audit committee' and 'board of directors' are generic governance entities, and 'regular basis'/'regular reports' are generic cadences — no specific facts survive the validation filter.

thinking:
Let me analyze this paragraph.

Content: Board and audit committee oversight of cybersecurity risk management. The board and audit committee are the primary subjects. "Head of IT" is mentioned but in context of reporting TO the audit committee.

Category: Board Governance - the board/audit committee are the grammatical subjects performing oversight. The Head of IT reports to them.

Specificity: Let me check facts:
- "Head of IT" - is this a cybersecurity-specific title? The IS list includes "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security." "Head of IT" is more like generic IT leadership. The NOT list says: "Head of IT", "IT Manager", "Director of IT" are generic IT titles, not cybersecurity-specific. So Head of IT is NOT a specific fact.

- "audit committee" - generic, on NOT list
- "board of directors" - generic
- "regular basis" / "regular reports" - generic cadence
- No named frameworks, no specific dates, no named firms

After filtering: no specific facts remain. No named standards either.

→ Generic Boilerplate, Specificity 1.


reasoning: The paragraph's primary communicative purpose is the governance oversight chain: operational risk group → CSRC (a Board Sub-Committee) → Audit Committee. The CSRC is the central entity, described as a 'Board Sub-Committee' with defined responsibilities including strategic risk review, funding recommendations, and materiality assessment. While management roles are listed as CSRC members, they are described in service of the committee's composition, not as individual credential disclosures. Multiple IS-list facts (CSRC as a named non-generic committee, CTO and Director of Information Security as cybersecurity-specific titles) establish Firm-Specific, but no two QV-eligible hard facts (dates, dollars, headcounts, named third-party firms, named tools) are present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes a governance structure involving both management and board oversight. Let me trace through:

1. "governance program which facilitates senior management oversight" - management
2. "operational risk group comprising senior SHCO Cyber Risk and third-party Cyber Risk professionals together with the IT Infrastructure lead meet monthly" - this is a management-level group
3. "output from this group is shared quarterly with the Cyber Security Risk Committee ("CSRC") a Board Sub-Committee" - board governance
4. The CSRC comprises CEO, CFO, CTO, CLO, and Director of Information Security

5. The CSRC reviews strategic cyber risks and recommends funding, reports twice yearly to the Audit Committee, and assesses materiality of incidents

The dominant topic here is the governance structure itself—specifically how the operational risk group feeds into the CSRC, which serves as the board-level oversight body. Since the CSRC is explicitly identified as a Board Sub-Committee and represents the central coordinating entity in this structure, this falls under board governance.

I'm also noting the cybersecurity-specific titles mentioned—CTO and Director of Information Security—which are clearly relevant to the domain, though the paragraph's focus remains on the oversight chain rather than individual qualifications.

Looking at what would count as quantifiably verifiable facts, I don't see any specific dates, dollar amounts, headcounts, or named third-party vendors that would push this into that category. The meeting cadences and generic C-suite roles don't add specificity either. So this lands as Firm-Specific based on the multiple industry-specific facts like the named CSRC committee and those cybersecurity titles.

fact: Cyber Security Risk Committee ("CSRC") — a named, non-generic Board Sub-Committee

fact: Chief Technology Officer (CTO) sits on the CSRC

fact: Director of Information Security sits on the CSRC


reasoning: The opening two sentences touch on Board Governance (Audit Committee reports to the Board, Board receives briefings), but the dominant content by volume describes what the management team does: assessing risks, developing methodology, supervising personnel and consultants, and preventing/detecting/mitigating threats. Applying the person-vs-function test, no individual is named, no credentials or background are given — 'management team' is generic attribution for a process description. No named frameworks, roles from the IS list, dates, tools, or firms appear; all entities are unnamed ('external consultants,' 'security tools,' 'internal security personnel'), placing this squarely at Generic Boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. Audit Committee reports to Board, Board receives briefings from management - Board Governance signals
2. Management team responsible for assessing/managing cyber risks, developing methodology, supervising personnel and consultants, prevention/detection/mitigation efforts - this is about what the management team does (processes)

The dominant content: The majority of the paragraph describes what the management team does - assessing risks, developing methodology, supervising personnel, preventing/detecting/mitigating threats. The board mention is brief (first two sentences).

Person vs function test: This is about the function, not about who the person is.

The paragraph focuses on generic management responsibilities and processes rather than specific individuals or credentials. The management team serves as the subject, but the real substance is describing their activities—risk assessment, methodology development, personnel oversight, and threat mitigation. The tiebreaker here is clear: when a role is mentioned as the attribution for process descriptions, that points toward Risk Management Process rather than a specific person or role title.

There's board governance content woven in—the Audit Committee reporting structure and board briefings—but that's secondary to the dominant theme of management's operational responsibilities. The specificity check shows generic references like "Audit Committee" without named individuals or concrete details, which reinforces that this is about processes and functions rather than people.


content_category: Third-Party Risk

reasoning: The entire paragraph is about oversight of external service providers — due diligence, monitoring of an MSP, communication protocols, and scheduled meetings with third-party providers. This is centrally about vendor oversight, not internal processes. No named firms, frameworks, dates, roles, or quantified details appear; references to 'MSP firm,' 'third-party service provider,' and 'industry best practice' are all generic.

thinking:
Let me analyze this paragraph.

Content: Third-party service provider oversight - due diligence, monitoring of MSP, protocols, meetings with providers. Central topic is vendor oversight.

Category: Third-Party Risk - the entire paragraph is about oversight of external parties.

Specificity: Let me check for specific facts. "MSP firm" - generic reference. No named firms, no dates, no frameworks, no specific roles, no numbers. "industry best practice" - not a named standard. Everything here is generic.

Generic Boilerplate.


reasoning: The paragraph's framing is about the 'governance of our risk management program' as a partnership between management and the Board, with the Audit Committee identified as primarily responsible for risk oversight — making governance the dominant communicative purpose. The CIO's credentials (30 years IT experience, 4 years infosec oversight) are subordinate detail within this governance frame, similar to Borderline Case 5. Two QV-eligible hard facts (specific years of experience: 30 years, 4 years) push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes governance structure - cross-functional management team, Board partnership, CIO leading cyber team, ERM program led by head of compliance, CIO's experience, Audit Committee oversight with quarterly updates.

Category: This is a mixed paragraph. It mentions board oversight (Audit Committee), management roles (CIO with experience), and risk management structure. The paragraph covers governance structure broadly. Let me apply the dominant category test.

The paragraph touches:
- Board Governance: Audit Committee oversight, quarterly updates
- Management Role: CIO with 30 years IT experience, 4 years infosec oversight

- Risk Management Process: ERM program structure

The primary communicative purpose seems to be describing the overall governance partnership between the Audit Committee and management, with the CIO's qualifications and the ERM program structure all contributing to that picture. The Audit Committee holds the formal responsibility for risk oversight, but the CIO's experience and the ERM program are integral to how that governance actually functions. I'm checking the specificity of each element against the codebook criteria. The CIO title qualifies as cybersecurity-specific, and both experience figures—30 years in IT and 4 years in information security—are concrete, verifiable numbers. That gives me two quantified-verifiable facts, which points toward the Quantified-Verifiable category rather than Board Governance, since the hard numbers are what make this codable.

fact: Chief Information Officer (CIO)

fact: over 30 years of information technology experience

type: quantified

fact: over 4 years of direct oversight of information security


reasoning: The paragraph describes the company's internal incident response and threat assessment processes — how the cybersecurity team responds to threats, what factors they assess (safety, data impact, disruption, cost, reputational harm), and that they use external support. This is squarely about internal cybersecurity processes. No named frameworks, no IS-list roles, no specific dates, numbers, tools, or firms are mentioned; all entities are generic ('cybersecurity team,' 'external technical, legal and law enforcement support').

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity threats the company faces, then describes how the cybersecurity team responds to threats - assessment factors, containment, etc. This is about internal processes for responding to threats.

Category: Risk Management Process - describes the company's internal incident response processes and threat assessment methodology.

Specificity: Let me check for specific facts:
- "cybersecurity team" - generic
- "student and employee information" - interesting, suggests education sector, but not a named entity
- "external technical, legal and law enforcement support" - unnamed entities
- No named frameworks, no named roles from the IS list, no dates, no numbers, no named tools

- No IS-list facts, no named standards - this is generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes — risk assessment, monitoring, vulnerability testing, security tools, and incident lifecycle — making Risk Management Process the dominant category. The brief mentions of senior management, an unnamed third-party IT vendor, and board oversight are subordinate components. No named frameworks, cybersecurity-specific titles, tools, firms, dates, or quantified facts appear; all language is generic and interchangeable across filings.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment, monitoring, vulnerability testing, security tools, and risk management processes. Senior management consults with third-party IT vendor. Board oversight mentioned at the end.

Category: This is primarily about the company's internal cybersecurity processes - risk assessment, monitoring, testing, security tools, incident lifecycle. The third-party IT vendor is mentioned as one component. The board mention is brief at the end. → Risk Management Process

Specificity: Let me check for specific facts:
- No named frameworks
- No cybersecurity-specific titles (just "senior management" - generic)
- No named tools, firms, dates, numbers

- References to "third-party information technology vendor" and "board of directors" are both vague and unnamed

No IS-list facts. No named standards. → Generic Boilerplate


reasoning: The paragraph primarily describes the organizational structure and function of cybersecurity risk management — the ISM team's role in maintaining controls for availability, confidentiality, and integrity, and how risk management informs decision-making. Board/Audit Committee oversight appears in the final sentence as a subordinate element. The ISM team is described by function (what it does), not by personnel credentials, so it is not Management Role. The named 'ISM' team with its unique abbreviation is a firm-specific fact, but no second QV-eligible hard fact exists (Audit Committee and 'quarterly' are on the NOT list), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. ISM team leading cybersecurity governance
2. What the ISM team does (controls, protection)
3. Risk management approach informing decisions
4. Board/Audit Committee oversight with quarterly updates

This is a mixed paragraph. Let me determine the dominant category.

The paragraph starts with the ISM team (management/process), describes what they do (process), then shifts to board governance. The primary communicative purpose seems split between describing the governance structure (who oversees what) and the process.

The grammatical subjects: ISM team (first two sentences), "this risk management approach" (third), "governance... is the responsibility of the Board" (fourth).

The core tension here is whether this is primarily about the ISM team's role or the overall governance structure. The Board/Audit Committee gets the final emphasis with ultimate responsibility, but the ISM team receives more detailed description of their activities. I'm leaning toward this being fundamentally about governance structure—the paragraph maps out the hierarchy of who does what and who oversees whom. The ISM team is the main focus here, described by its function rather than credentials, which points toward Risk Management Process. But the paragraph's emphasis on the governance hierarchy—with the Board and Audit Committee as ultimate authorities—keeps pulling me toward Board Governance. I'm settling on Risk Management Process since the ISM team is the primary subject managing the cybersecurity program structure, even though governance elements are present. I keep circling back on this because the paragraph really is about governance structure—who oversees what at each level. The ISM team, the risk management approach, and the Board oversight are all pieces of the same governance hierarchy. Since the majority of the text focuses on the ISM team's role and function rather than specific processes or methodologies, I'll settle on Risk Management Process as the dominant category, with the understanding that it encompasses the governance structure being described.

Now for specificity—the ISM team is explicitly named with an abbreviation, making it a specific internal program with a unique identifier, so that's Firm-Specific. The Audit Committee, quarterly cadence, and Board of Directors are all generic references without firm-specific details. Since the ISM team itself isn't a QV-eligible fact, I'm looking at Firm-Specific (3) as the classification.

Actually, stepping back—this paragraph is fundamentally about governance structure, but the bulk of the content focuses on the ISM team's management-level activities around controls and risk management rather than board-level oversight. The board mention feels secondary. So I'm settling on Risk Management Process as the category, with Firm-Specific as the specificity level.

fact: Information Security Management 'ISM' team — named internal team with unique identifier


reasoning: The paragraph describes the company's internal cybersecurity processes: collaboration between cybersecurity and physical security teams on risk assessment, incident response, and security training. Third parties are mentioned only as training participants, not as the central topic. No named frameworks, cybersecurity-specific roles, named tools, dates, or other IS-list facts are present. PCI, CUI, and PII are generic data categories, not named standards like PCI DSS or NIST. The practices described (joint training, focused training for sensitive data handlers) are common and non-firm-specific.

thinking:
Let me analyze this paragraph.

Content: Describes collaboration between cybersecurity and physical security teams on planning, risk assessment, incident response, and training. Mentions specific types of sensitive information (PCI, CUI, PII).

Category: This is about internal cybersecurity processes - training, risk assessment, incident response planning. The mention of third parties is incidental (partners in training), not about vendor oversight. → Risk Management Process

Specificity: Let me check for specific facts:
- PCI, CUI, PII are types of information, not named frameworks/standards per se. PCI could reference PCI DSS standard implicitly, but these are just information categories.

- The teams mentioned are generic references without named roles, the training cadence is standard annual practice, and there are no specific tools, dates, dollar amounts, or named firms referenced.
- While PCI DSS is a recognized standard, the paragraph only mentions "payment card information (PCI)" as a data category rather than explicitly naming the framework. CUI and PII are similarly just data classifications, not standards themselves.

This reads as generic boilerplate describing common security practices without any firm-specific details or named standards.


reasoning: The paragraph describes the company's own cybersecurity processes — risk assessment with a consultant, policies, and engaging third parties for penetration testing and audits. Per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. The FDA is a named regulatory body (analogous to HIPAA/GDPR), triggering Sector-Adapted, but all other details (unnamed consultant, unnamed third-party services, generic practices) are on the NOT list and provide no firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Mentions FDA regulations, cybersecurity consultant, risk assessment, policies, third-party services for security evaluations (pen testing, audits, consulting).

Category: This mentions third parties but also internal processes. The paragraph covers regulatory compliance, working with a consultant on risk assessment, and engaging third parties for evaluations. The third-party mentions serve the company's own security program - they're components of the internal process. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." So this is Risk Management Process.

Specificity: Let me check for specific facts.

FDA is a named regulatory body, which counts as a recognized standard similar to NIST or HIPAA. The cybersecurity consultant and third-party services are generic references, while penetration testing and independent audits are common practices rather than specific facts. Since FDA is explicitly named, this would be Sector-Adapted.

fact: FDA regulations related to safeguarding patient information

type: framework


reasoning: The Board of Directors and Audit Committee are the grammatical subjects in two of three sentences, making board oversight the dominant topic. The final sentence about testing systems is subordinate. No named frameworks, cybersecurity-specific roles, or firm-specific facts are present — 'Board of Directors,' 'Audit Committee,' 'management,' and 'ongoing testing' all appear on the NOT list.

thinking:
Let me analyze this paragraph.

The paragraph has two main parts: board oversight and some process description.

First sentence: Board of Directors oversight - Board Governance
Second sentence: Audit Committee evaluates cybersecurity - Board Governance
Third sentence: Systems for testing/defense - Risk Management Process

The dominant subject is the Board/Audit Committee (2 of 3 sentences). Board Governance.

Specificity: Let me check facts.
- "Board of Directors" - NOT list (generic governance)
- "Audit Committee" - NOT list (generic governance)
- "management" - NOT list
- "information technology department" - generic

- "ongoing testing" - generic practice

No named standards, no firm-specific facts. This is generic boilerplate language without any concrete details or company-specific information.


content_category: Management Role

specificity_confidence: medium

reasoning: The paragraph's primary content is about the VP of IT as a person — their qualifications (20 years of experience across cybersecurity and IT domains), reporting line to the CFO, and responsibilities. While the last two sentences touch on risk assessment processes and Audit Committee interaction, these are subordinate to the framing around the management role holder's identity and structure. The 20 years of experience is a specific quantified fact (QV-eligible), but it is the only hard verifiable fact — VP of IT is a general IT title (per the NOT list), CFO and Audit Committee are generic — so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the VP of IT's role, qualifications (20 years experience), reporting line (to CFO), and mentions Audit Committee oversight.

Category: The paragraph is primarily about the person - their experience, reporting line. But it also describes what they do (implement/maintain info security program, coordinate risk assessments, oversee testing). Let me apply the person-vs-function test.

The first two sentences are about the person (role, experience). The third sentence describes reporting and what they do together (risk assessments, testing). The fourth sentence shifts to CFO meeting with Audit Committee.

The dominant content is about the VP of IT as a person - their qualifications and reporting structure.

Now I'm checking whether this title qualifies as information security-specific. "Vice President of IT" is a general technology title, not the same as "VP of IT/Security" which appears on the IS list. The IS list includes cybersecurity-specific titles like CISO and CIO, but this is just a generic VP of IT role. I'm realizing "Vice President of IT" is essentially the same tier as the explicitly non-specific titles like "Director of IT" and "Associate Vice President of IT," so it doesn't qualify as a specific fact. That leaves me with just one quantified fact—the 20+ years of experience—which isn't enough to reach the QV threshold of two facts.

fact: over 20 years of experience in enterprise-level IT operations, cybersecurity operations, and IT/Cyber architecture


reasoning: The Audit Committee is the grammatical subject and primary actor throughout—it oversees cybersecurity programs and receives briefings. The CIO is mentioned in a reporting-up capacity (briefing the committee), which is subordinate to the board oversight frame. The CIO (a cybersecurity-specific title on the IS list) is the only firm-specific fact; 'Audit Committee,' 'Board of Directors,' and 'regular briefings' are all on the NOT list. One IS-list fact yields Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee oversees cybersecurity. It receives briefings from the CIO. The CIO prepares updates integrated into Board's ERM oversight.

Category: The grammatical subject is the Audit Committee (board committee) for the first two sentences. Third sentence has CIO as subject but it's about how updates feed into Board oversight. Primary actor is the Board/Audit Committee. → Board Governance

Specificity: Let me check facts:
- "Audit Committee" — NOT list (generic)
- "Board of Directors" — NOT list
- "CIO" — IS list (cybersecurity-specific title)

- "regular briefings" — NOT list (generic cadence)
- No named frameworks, no dates, no dollar amounts, no named firms

CIO is the only firm-specific fact here, and it doesn't qualify as QV-eligible since named roles don't count. This lands in Firm-Specific with just one fact.

fact: CIO provides briefings to the Audit Committee


reasoning: The paragraph's grammatical subject is 'our management' and its primary content is management's responsibility for cybersecurity risk — fitting Management Role. However, it contains no named roles, frameworks, dates, or any specific facts, making it Generic Boilerplate.

thinking:
Classify this paragraph.

"Management of and Reporting on Cybersecurity Matters Our management assumes responsibility for assessing, identifying, and managing cybersecurity risks, threats, and incidents."

This is about management's responsibility for cybersecurity. The subject is "our management" - generic, no named roles. This is Management Role with generic language.

No specific facts - no CISO, no named roles, no frameworks, no dates. Generic boilerplate.


reasoning: The paragraph primarily describes the company's integrated enterprise risk management program — its design, risk assessment methodology, and governance structure. The board is mentioned only in passing ('with Ameren board of directors' oversight'), while the substantive content is about internal processes and the management-level steering committee. The 'risk management steering committee' is a named non-generic committee (analogous to an ERM Committee on the IS list), providing one firm-specific fact, but no second hard verifiable fact for QV.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity as an enterprise risk managed through an integrated ERM program. Describes the program's design, risk assessment approach, and the risk management steering committee's composition and role.

Category: This is about the company's internal risk management processes - ERM integration, risk assessment methodology, program design. The steering committee is a management-level committee, not a board committee. The board is mentioned only briefly ("with Ameren board of directors' oversight"). The primary content is about the risk management program and process.

→ Risk Management Process

Specificity: Let me check for specific facts:
- "risk management steering committee" - this is a named internal committee, but is it on the IS list? It's not a "Technology Committee, Cybersecurity Committee, Risk Committee, ERM Committee" exactly.

Actually, a "risk management steering committee" functions as a Risk or ERM Committee, which are on the IS list as named non-generic committees. That would count as firm-specific and give us one IS point. The composition details about executive management and senior officers are somewhat vague, and there are no named frameworks, specific dates, tools, or headcounts mentioned.

fact: risk management steering committee (composed of executive management and senior-level Ameren officers)


reasoning: The Board and Audit Committee are the grammatical subjects throughout, describing delegation of cybersecurity oversight responsibility — classic Board Governance. All entities mentioned (Board, Audit Committee) are on the NOT list as generic governance terms, with no named frameworks, cybersecurity-specific roles, dates, or firm-specific details.

thinking:
Classify this paragraph.

Content: Board delegates cyber oversight to Audit Committee. Board and Audit Committee are the subjects throughout.

Category: Board Governance - the board/committee is the grammatical subject throughout.

Specificity: Let me check facts. "Audit Committee" is on the NOT list (generic governance). "Board of Directors" is generic. No named frameworks, no specific roles like CISO, no dates, no numbers. Everything here is generic boilerplate.

Specificity: Generic Boilerplate (1)


reasoning: The paragraph describes the company's internal cybersecurity risk management processes—risk identification, threat evaluation, vulnerability assessment, staff training, and incident response planning. All content concerns the company's own processes, making it Risk Management Process. No named frameworks, roles, dates, tools, or firm-specific facts are present; every element is generic language that could appear in any filing.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity risk management processes - risk identification, threat evaluation, vulnerability assessment, training, incident response planning.

Category: Risk Management Process - describes internal processes, methodology, no board/management focus.

Specificity: Let me check for specific facts. No named frameworks, no named roles, no dates, no numbers, no named tools/firms. "cybersecurity incident response plan" is generic. "cybersecurity training" is a common practice. Everything here is generic language that could apply to any company.

→ Generic Boilerplate (1)


reasoning: The paragraph opens with the CCO's responsibility but immediately shifts to describing program activities — simulations, annual training, shared responsibility, and use of external advisors. The CCO mention is attribution, not a description of the person's credentials or background; the substantive content is about internal processes. CCO (Chief Compliance Officer) is a generic C-suite title, not a cybersecurity-specific role on the IS list, and all other elements (unnamed third-party providers, 'periodically,' 'annually,' generic training) fall on the NOT list, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes CCO's responsibility for cybersecurity program, third-party providers' expertise, shared responsibility, simulations, training.

Category: The paragraph starts with CCO's responsibility but then shifts to describing program activities (simulations, training, shared responsibility). The CCO mention is attribution - "is responsible for developing and implementing the cybersecurity risk management program." Then it describes what the program includes. Apply person-vs-function test: remove the CCO attribution and the paragraph still describes processes (simulations, training, third-party expertise). But the CCO is a specific role... wait, CCO = Chief Compliance Officer, which is on the NOT list as a generic C-suite title.

Actually, CCO could be Chief Compliance Officer or Chief Commercial Officer - neither is a cybersecurity-specific title. The dominant content here is really about the program activities themselves: training, simulations, shared responsibility with third parties. That points to Risk Management Process.

Looking at specificity: CCO is generic C-suite, third-party service providers are unnamed, the cadences like "periodically" and "annually" are vague, and simulations and cybersecurity training are standard practices. Nothing specific enough to qualify.

No named frameworks or specific facts from the IS list - this is just generic boilerplate.


reasoning: The paragraph's primary communicative purpose is describing the company's post-assessment risk management process (re-designing safeguards, addressing gaps, monitoring effectiveness). The second sentence attributes this process to two roles with their years of experience, but applying the person-vs-function test, the process description is the frame and the role attributions are subordinate. Note: 'Manager of Information Technology' and 'COO' are generic titles (NOT list), but the specific years of experience (25 years, 15 years) are two QV-eligible quantified facts, reaching the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up activities (re-design, implement, maintain safeguards, address gaps, monitor effectiveness) and identifies who manages the process (Manager of IT with 25+ years experience, COO with 15+ years IT management experience).

Category: This is a mix of Risk Management Process (the safeguard activities) and Management Role (the people managing it). The first sentence describes processes. The second sentence describes who manages it with their qualifications. Let me apply the person-vs-function test.

The first sentence is about processes. The second sentence names specific roles with years of experience. If I remove the people, the first sentence still stands as process description.

The second sentence is entirely about the people—their roles and qualifications. When I strip away the role holders and their experience, the process description remains intact, but the second sentence collapses. This suggests the paragraph is primarily about the process, with the people serving as supporting context for who executes it. I'm wrestling with whether the dominant category here is really Risk Management Process or Management Role. The codebook example suggests that when you lead with process description and then name who does it, that's RMP with incidental role attribution. But this paragraph gives substantial credentials—25 and 15 years of experience—which feels like meaningful Management Role content. The first sentence is clearly process-focused, but the second sentence is doing real work identifying specific people and their qualifications. I think the process framing wins out since it sets the structure, but I can see how the experience levels make this genuinely close to 50/50.

Now looking at the specificity question: "Manager of Information Technology" and "Chief Operating Officer" are both generic titles on the NOT list, so those don't count. But "over 25 years of information technology experience" and "over 15 years of information technology management experience" are specific numbers—those are quantified and verifiable facts. That's two hard data points, which pushes this toward Quantified-Verifiable. The years of experience are independently verifiable facts—specific numbers that count as QV-eligible regardless of the roles themselves not being cybersecurity-specific. So I'm settling on Quantified-Verifiable, with the two experience durations (25 and 15 years) as my QV facts.

fact: Manager of Information Technology has over 25 years of IT experience

fact: COO has over 15 years of IT management experience


reasoning: The paragraph describes an internal monitoring process (periodic network monitoring to detect cybersecurity events), making it about the function rather than the person. The CISO is mentioned as attribution for who performs the monitoring. CISO is a cybersecurity-specific title triggering Firm-Specific, but no second hard verifiable fact exists for QV.

fact: CISO


reasoning: The paragraph describes a security assessment process (FedRAMP certification for a named product) with a role mentioned as attribution for who reviews assessments and reports — the primary content is about the process, not the person. Contains multiple firm-specific facts (named product, FedRAMP certification claim, cybersecurity-specific role title, named internal group) but only one QV-eligible hard fact (named product 'Pega Cloud for Government'), so it does not reach the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes FedRAMP certification for a specific product (Pega Cloud for Government), security assessments, and a named role (Chief Technical Systems Officer) reviewing and reporting to SSG.

Category: This is about internal security processes - assessments, certification. The Chief Technical Systems Officer is mentioned as attribution for who reviews assessments. The paragraph is about the process (FedRAMP assessments), not about the person. → Risk Management Process

Specificity facts:
- "Pega Cloud for Government" - named product/system ✓
- "FedRAMP Moderate" - named standard/framework (and certification claim) ✓

- "Chief Technical Systems Officer" - cybersecurity-adjacent specific title ✓
- "SSG" - named internal group (specific team/committee)

Now checking what's actually verifiable: Pega Cloud for Government is a named system, and FedRAMP Moderate certification is a claim I can verify. The QV-eligible facts here are the named product and the specific certification standard mentioned.

Actually, I need to be more careful about what counts as QV-eligible. FedRAMP Moderate is a product certification rather than an individual credential like CISSP or CISM, so I'm reconsidering whether it fits the same category. But the named product itself definitely qualifies, and the FedRAMP rating is a concrete, verifiable fact about that product's compliance status.

Looking at what I have: the named product is QV-eligible, but that's just one fact. For Firm-Specific, I've got multiple anchors—the product name, the FedRAMP certification claim, a cybersecurity-specific title, and an internal group reference. That's enough to classify this as Firm-Specific.

fact: Pega Cloud for Government

fact: FedRAMP Moderate certification

fact: Chief Technical Systems Officer

fact: SSG (Security/Strategy group)


reasoning: The paragraph describes the ISC management committee's composition, function, and activities within the cybersecurity program — receiving updates on cybersecurity posture, emerging risks, and providing incident response support. While Management Role covers 'management committees responsible for cybersecurity,' the person-vs-function test points to Risk Management Process: the substantive content is about the committee's operational role in the cybersecurity program (what it does), not about individual credentials or qualifications. The CISO mention is incidental attribution. Firm-Specific due to the uniquely named ISC committee, CISO title, and specific departmental composition.

thinking:
Let me analyze this paragraph.

Content: Describes a business information security committee (ISC), its composition, management by CISO, and its functions.

Category: This is about an internal committee structure. The ISC is a management-level committee, not a board committee. It's managed by the CISO. The paragraph describes the committee's composition, purpose, and activities. This is about internal risk management processes/organizational structure rather than board governance. The CISO is mentioned as managing the ISC, but the paragraph is about the committee and its function, not about the CISO as a person. This is Risk Management Process - it describes an internal organizational structure for managing cybersecurity.

Now I'm reconsidering whether this fits Management Role instead. The codebook does define that category as covering management committees responsible for cybersecurity. But looking at what the paragraph actually emphasizes—the ISC's composition, what it does during incident response, the updates it receives—this is really describing the committee's function and processes rather than focusing on the role itself. So Risk Management Process still seems like the better fit. The codebook explicitly lists management committees under Management Role, but the paragraph's focus is really on what the ISC does functionally—the oversight activities, posture updates, and incident response support—rather than on the committee's structure or the CISO's credentials. I'm leaning toward Risk Management Process since the function dominates over the organizational aspect.

For specificity, I've got the ISC name, the CISO title, and the specific department composition all marked for the IS list. On the QV check, the CISO is just a role title without verification potential, and while the ISC name and department list are firm-specific, neither qualifies as a hard verifiable fact—no dates, amounts, or headcounts to anchor it.

fact: Chief Information Security Officer

fact: Cross-functional composition: operations, digital product solutions, information technology, compliance, security, finance, privacy, internal audit and legal risk mitigation


content_category: Incident Disclosure

reasoning: The paragraph primarily describes what happened in a cybersecurity incident — unauthorized activity detected, IR plan activated, systems taken offline, and operational disruption. While it also discusses financial impact (reduced sales, increased costs), the incident narrative dominates and the financial details are consequences woven into the event description. Only one hard verifiable fact (fiscal quarter) prevents QV; no named firms, tools, or dollar amounts are provided.

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity incident - unauthorized activity detected, response actions taken, operational impact, financial impact.

Category: This paragraph describes what happened (unauthorized activity, activated IR plan, containment, systems taken offline) AND describes business/financial impact (reduced sales, increased costs, negatively impacted results). The dominant content is the incident narrative - what happened, when, what they did, what was affected. The financial impact sentences are subordinate to the incident description. → Incident Disclosure

Specificity: Let me check for facts:
- "fourth quarter of fiscal 2025" - specific date → yes, this is a specific date

- Most other details are vague or generic: "Cybersecurity Incident" is just a label, "certain of our information technology systems" lacks specificity, "incident response plan" and "taking certain systems offline" are standard terminology without concrete details. Only the fiscal quarter gives me a hard verifiable fact, so this lands in Firm-Specific territory.

IS list check: The specific date "fourth quarter of fiscal 2025" qualifies as a firm-specific item.

fact: fourth quarter of fiscal 2025


reasoning: The paragraph makes an explicit materiality assessment — that no cybersecurity incident has or is likely to materially affect the company's business strategy, results of operations, or financial condition. Per Rule 6, any paragraph containing a materiality conclusion is Strategy Integration. The prefatory clause about vendors/government agencies is generic risk acknowledgment, not the primary content. No specific facts are present; the language is standard boilerplate materiality disclaimer found across thousands of filings.

thinking:
Classify this paragraph.

Content: Materiality assessment ("no cybersecurity incident that has or is likely to materially affect us, our business strategy, or our results of operations, or financial condition") → Strategy Integration per Rule 6.

Specificity: Boilerplate materiality language, no specific facts. → Generic Boilerplate.


reasoning: The paragraph is framed around the company's incident response plan — its procedures, training, drilling, and performance. The CDK incident in June 2024 is presented as a real-world validation of the plan rather than as an incident narrative in its own right; the opening and closing sentences focus on the plan's design and refinement. The materiality conclusion is subordinate. Two QV-eligible hard facts: specific date (June 2024) and named third-party firm (CDK).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Description of their incident response plan (Risk Management Process)
2. A specific incident involving CDK (Incident Disclosure)
3. Materiality assessment (Strategy Integration)

Let me determine the dominant category. The paragraph:
- Opens with describing the IR plan (generic)
- Then describes the CDK incident in June 2024
- Then assesses materiality
- Then discusses lessons learned

The CDK incident is a significant portion, but the paragraph frames everything around their incident response plan - how it works, how it was triggered, how it performed. The incident is used as evidence that the plan works.

But looking at the actual content distribution, the incident narrative and materiality assessment together take up more space and seem to be the real focus. The IR plan description is just the framing device. The paragraph's actual substance is about what happened with CDK—the specific date, the named third party, the operational impact—and whether it was material. So the dominant category is probably Incident Disclosure, with Strategy Integration as a secondary component. The incident itself is substantial—June 2024, CDK as a named third-party, operational disruption—but the paragraph's real focus is on validating that the IR plan worked as intended. The materiality assessment is secondary to demonstrating the plan's effectiveness. This lands in Risk Management Process, and with the specific date and named provider, it qualifies as Quant.

fact: June 2024

fact: CDK (named third-party provider)


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any cybersecurity incidents... that have had or are reasonably likely to have a material impact on the Company's results of operations or financial condition'), which per Rule 6 makes it Strategy Integration even though a cross-reference to Risk Factors is appended. No specific facts from the IS list are present — 'As of the date of this Report' is not a specific date, and the cross-reference is boilerplate.

thinking: Materiality assessment + cross-reference. Per Rule 6, the materiality assessment makes this Strategy Integration.


reasoning: The Board of Directors and its delegated committee (AFC) are the grammatical subjects performing oversight of cybersecurity risk, making this Board Governance. The AFC appears to be an audit committee variant (Audit and Finance Committee), which is standard/generic per the codebook; cadences are vague ('periodically', 'regularly scheduled'), and no cybersecurity-specific roles, named frameworks, or firm-specific facts appear.

thinking:
Let me analyze this paragraph.

Content: Board delegates cyber oversight to AFC (Audit and Finance Committee?), AFC evaluates programs, chair reports to full board.

Category: Board Governance - the Board and AFC are the primary subjects performing oversight actions.

Specificity: "AFC" - this appears to be a named committee. But is it just the Audit Committee by another name? "AFC" likely stands for "Audit and Finance Committee" which is essentially the audit committee variant. Per the codebook, "Audit Committee" is generic/standard. AFC is basically the same thing. No cybersecurity-specific titles, no specific dates, no named frameworks.

The language here is generic boilerplate—just standard audit committee oversight with vague cadences like "periodically" and "regularly scheduled." There are no named frameworks or specific facts from the IS list, so this rates as Generic Boilerplate (1).


reasoning: The paragraph's primary subject is the Board of Directors and its dedicated Cybersecurity Special Committee — their empowerment, composition, and oversight activities — making Board Governance the dominant category. It contains multiple firm-specific facts (a named non-generic committee, a cybersecurity-specific leadership title, and specific departmental composition) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools), so it is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes a dedicated Cybersecurity Special Committee, its composition, leadership, and external expert presentations to the Board.

Category: The paragraph starts with "Our Board of Directors" and describes a board-level committee (Cybersecurity Special Committee) with board members on it. The committee is led by the Chief Information and Business Services Officer and two Board members. This is about board/committee oversight of cyber risk. The grammatical subject is the Board and its committee. → Board Governance

Specific facts:
- "Cybersecurity Special Committee" — named non-generic committee ✓
- "Chief Information and Business Services Officer" — cybersecurity-specific title ✓

- "Chair of the AFC" — refers to Audit and Finance Committee chair, generic governance
- Team composition includes information technology, digital operations, corporate affairs, legal, compliance, human resources and finance departments ✓

Checking for quantifiable facts: no dates, dollars, headcounts, named third-party firms, tools, or certifications present, so this doesn't meet the QV threshold.

For the IS list: I have the named Cybersecurity Special Committee and the cybersecurity-specific Chief Information and Business Services Officer title, which are the key indicators.

This is Firm-Specific (3) based on the specific committee name and departmental composition.

fact: Cybersecurity Special Committee

fact: Committee consists of members from information technology, digital operations, corporate affairs, legal, compliance, human resources and finance


reasoning: The paragraph centers on the CISO as a person — their certification (CISSP), years of experience (20+), team composition, and reporting line to the ERM Committee. While it mentions program responsibilities, the primary content is about who the CISO is and their qualifications. Two QV-eligible hard facts: named certification (CISSP) and specific years of experience (over 20 years).

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's responsibilities, qualifications (CISSP, 20+ years experience), team composition, and reporting to the ERM Committee.

Category: This is about the person - their certifications, experience, and what they oversee. The person-vs-function test: the paragraph focuses on who the CISO is (certified, 20 years experience), their team, and their reporting structure. This is Management Role.

Specificity:
- CISO (cybersecurity-specific role) ✓
- CIO (cybersecurity-specific role) ✓

- CRO (not on the IS list)
- CISSP certification (named certification) ✓ - QV eligible
- "over 20 years" of experience ✓ - QV eligible (specific number)
- Enterprise Risk Management Committee (named non-generic committee) ✓
- "certified security professionals" - generic, no names

I've identified two hard verifiable facts here: the CISSP certification and the specific experience threshold of over 20 years, which makes this Quantified-Verifiable.

fact: CIO

fact: Certified Information Security System Professional (CISSP)

fact: over 20 years of technical and cybersecurity leadership experience

fact: Enterprise Risk Management Committee


reasoning: The paragraph is about the people filling cybersecurity leadership roles — their titles, reporting lines, combined experience, and credentials. This is the person-focused content characteristic of Management Role. Multiple hard verifiable facts (50+ years combined experience, named CISA certification, two master's degrees) meet the QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the ISO (Information Security Officer), Chief Risk Officer, CIO, team composition, experience, and certifications. This is about the people - their roles, qualifications, credentials.

Category: Management Role - the paragraph is about who the people are, their qualifications, certifications, experience, reporting lines.

Specific facts:
- ISO (Information Security Officer) - named cybersecurity role ✓
- Chief Risk Officer - supervision relationship
- CIO - named role
- "over 50 years of combined experience" - quantified
- ISACA Certified Information Systems Auditor (CISA) certification - named certification

- Two team members with master's degrees in cybersecurity - quantified ✓
- Dedicated cybersecurity team - organizational structure

QV check:
- "over 50 years of combined experience" - quantified ✓
- CISA certification - named certification ✓
- "two team members" with master's degrees - quantified ✓

That's at least 2 hard verifiable facts → Quantified-Verifiable

fact: ISO (Information Security Officer) leads the program

fact: Chief Risk Officer supervises the ISO

fact: Chief Information Officer supervises IT cybersecurity team

fact: Over 50 years of combined experience


reasoning: The paragraph describes the Audit Committee's oversight mechanism — receiving quarterly management reports on cybersecurity topics. The Audit Committee is the entity being briefed, making board oversight the primary communicative purpose. 'VP of Internal Audit' is not a cybersecurity-specific title per the IS list, 'Audit Committee' is generic, and 'quarterly' is a generic cadence, leaving no specific facts.

thinking:
Let me classify this paragraph.

Content: Management reports quarterly to Audit Committee on information security, covering cyber threats and security initiatives.

Category: The grammatical subject is "Management (including our VP of Internal Audit)" - they report TO the Audit Committee. This is about the reporting relationship from management to the board committee. The primary actor is management reporting upward. But the frame is about board oversight - the Audit Committee receives these reports.

Per Rule 2: "Management role reports TO the board" → Management Role. But wait - "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). Here, "Management... reports quarterly to the Audit Committee" - management is the primary actor.

The subject is Management, and they're reporting to the Audit Committee on security matters. This fits the pattern of a management role reporting to the board for oversight purposes, so it should be classified as Management Role.

But wait—the paragraph's real focus is on the oversight mechanism itself: the Audit Committee receiving periodic briefings on cybersecurity risks. That's the Board Governance pattern. The "VP of Internal Audit" title isn't cybersecurity-specific, and the content emphasizes the board committee's oversight function rather than describing a particular role's qualifications or responsibilities.

I'm going with Board Governance here. The paragraph describes how the Audit Committee maintains oversight through regular reporting cadence, which is fundamentally about governance structure rather than a specific management position.


reasoning: The Board of Directors is the primary subject with oversight responsibility for cybersecurity risks; the second sentence describes how management (CISO, CTO, CLO) reports TO the board, which is a board oversight structure description. CISO and CTO are cybersecurity-specific titles on the IS list, making this Firm-Specific, but named roles don't count toward QV so it stays at level 3.

thinking:
Let me analyze this paragraph.

The paragraph has two sentences:
1. The Board of Directors has oversight responsibility for cybersecurity risks/incidents, along with the Audit Committee for financial reporting effects.
2. The CISO, CTO, and Chief Legal Officer regularly update the Board on cybersecurity risk profile, incidents, strategy, tabletop exercises, insurance coverages.

Primary actor: The Board is the subject of the first sentence. The second sentence describes how management reports TO the board. This is about board oversight - the management roles are mentioned in the context of updating the board.

Per Rule 2: "Board delegates responsibility to management" → Board Governance. The management roles reporting TO the board is part of the board's oversight structure.

Now I'm checking which details are firm-specific versus generic. The CISO and CTO are named cybersecurity-specific roles, while the Chief Legal Officer, Audit Committee, regular cadence, and tabletop exercises are all standard practices. This gives me CISO and CTO as the firm-specific facts, though these named roles don't contribute to quantitative value.

fact: Chief Information Security Officer (CISO)

fact: Chief Technology Officer (CTO)


reasoning: The paragraph leads with the CISO's reporting line (to CFO) and credentials (30+ years experience, 12 years as CISO), making the person's identity and qualifications the primary content. The second half describes team activities (policies, procedures, testing, training), which leans Risk Management Process, but the paragraph's framing under 'Management's Roles and Responsibilities' and the prominence of the CISO's background make Management Role the dominant category. Two QV-eligible hard facts: 'over thirty years' of experience and 'twelve years in a CISO role' as specific durations.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's reporting line, experience, and then describes what the information security team does (policies, procedures, testing, training).

Category: This is a mixed paragraph. It starts with Management Role content (CISO reporting line, experience) then shifts to Risk Management Process (policies, procedures, testing, training). The heading says "Management's Roles and Responsibilities." Let me apply the person-vs-function test.

The first half is about the person: CISO reports to CFO, 30+ years experience, 12 years as CISO. The second half is about what the team does: policies, procedures, testing, training.

The CISO's credentials and reporting structure dominate here, making this primarily a Management Role entry—the team's process activities are secondary details. I'm noting the specific facts: CISO is a named role, the thirty and twelve years are quantified numbers, and the CFO reporting line is generic C-suite information. The "over thirty years" phrase is what I'd flag for the quantified value check.

Both experience metrics—the thirty years overall and the twelve years specifically in a CISO role—are concrete, verifiable facts that qualify as Quantified-Verifiable.

fact: over thirty years of business and technical experience

fact: twelve years in a CISO role


reasoning: The paragraph references a past material incident but its primary communicative purpose is assessing the business and financial impact: it notes recorded expenses, cross-references financial notes, provides an explicit materiality assessment ('not aware of any other cybersecurity incidents that have had a material effect'), and includes forward-looking materiality disclaimers. Per the tiebreaker, a brief incident mention plus materiality conclusion as the main point yields Strategy Integration. One QV-eligible fact (Q3 FY2023) yields Firm-Specific; the attack vector details (zero-day, file transfer application) lack named vendors/products so don't count as additional hard verifiable facts.

thinking:
Let me analyze this paragraph.

It discusses past cybersecurity incidents, including a material one in Q3 fiscal 2023 involving a zero-day vulnerability in a third-party file transfer app. It mentions expenses, cross-references to notes, and includes a materiality assessment plus forward-looking risk language.

Category: This is primarily about incidents and their business impact. The paragraph describes what happened (unauthorized access via zero-day vulnerability in third-party file transfer app, Q3 FY2023), mentions expenses, and assesses materiality. The dominant purpose is Strategy Integration - it's assessing the material impact of incidents on the business, referencing costs, and making materiality conclusions. But wait - there's substantial incident narrative here too.

Looking at the tiebreakers more carefully, the incident details are present but the overall framing centers on materiality and financial impact rather than a comprehensive incident narrative. The arc moves from what happened to the cost implications and whether it was material, which suggests Strategy Integration is the primary category despite the incident description being fairly detailed. I'm settling on Strategy Integration as the primary purpose since the paragraph frames the incident within a materiality and financial impact assessment. The incident details are substantial, but they're ultimately in service of evaluating business consequences rather than describing the breach itself. Looking at specificity, I have one concrete date (Q3 FY2023) but the vendor and product remain unnamed, and the affected population is vaguely quantified, so this lands as Firm-Specific.

fact: third quarter of fiscal year 2023 — specific date of material incident


reasoning: The paragraph opens with the CISO's reporting line (to CFO) and dedicates significant space to the CISO's qualifications (30+ years experience, 13 years as CISO), making the person's credentials a primary focus. The second half describes team processes (policies, testing, training), which pulls toward Risk Management Process, but the paragraph's heading and lead content center on the management role holder. Two QV-eligible hard facts: 'over thirty years' and 'thirteen years' as specific durations of experience.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's reporting line, experience, and then describes what the information security team does (policies, procedures, testing, training).

Category: This is a mixed paragraph. It starts with Management Role content (CISO reporting line, experience) then shifts to Risk Management Process (policies, procedures, testing, training). The heading says "Management's Roles and Responsibilities." The CISO's credentials and reporting line take up about half, and the process description takes the other half. The person-vs-function test: the paragraph describes both the person (reporting line, 30 years experience, 13 years as CISO) and the function (policies, procedures, testing, training).

The CISO's qualifications and reporting structure dominate here—that's the Management Role piece. The specific credentials are quantified: over thirty years in business and technical experience, thirteen years specifically as CISO, reporting to the CFO. The CISO title itself is information security-specific, so that's what I'm capturing, while the CFO is a generic C-suite role. The "over thirty years" figure qualifies as quantified and verifiable.

fact: thirteen years in a CISO role


reasoning: The opening sentence describes management credentials (CIO, Senior Director, certifications), but the bulk of the paragraph describes what the team does: monitoring infrastructure, detecting suspicious behavior, conducting audits with third-party experts, coordinating with internal audit, and working on data privacy. Applying the person-vs-function test, the paragraph is primarily about the function — remove the role titles and it still reads as a process description. QV-eligible hard facts include 75 years collective experience plus three named certifications (CISM, CISSP, CISA), exceeding the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the information security team, led by CIO and Senior Director of IT Security and Compliance. It covers their credentials, experience, and then describes what the team does - monitoring, audits, tools, etc.

**Content Category Analysis:**
- The paragraph starts with management roles (CIO, Senior Director) and their qualifications (75 years collective experience, CISM, CISSP, CISA certifications)
- But then the bulk of the paragraph describes what the team DOES: monitoring, tools, audits, third-party experts, internal audit coordination, data privacy program work

Applying the person-vs-function test: If I remove the role titles and credentials, the paragraph still describes substantive cybersecurity activities.

The opening establishes the leadership team and their qualifications, but the real substance is in sentences 2 through 7, which detail the risk management processes and security operations the team executes. The dominant content here is actually about Risk Management Process rather than the people themselves.

**Specificity Analysis:**

IS-list facts:
- CIO (cybersecurity-specific title) → named_role
- Senior Director, IT Security and Compliance → named_role
- 75 years of collective experience → quantified
- CISM certification → named certification (QV-eligible)
- CISSP certification →

Here is the next thinking you need to rewrite:
 named certification (QV-eligible)
- CISA certification → named certification (QV-eligible)
- Executive Vice President, Chief Administrative Officer and General Counsel → this is generic C-suite, NOT list

QV-eligible facts:
1. 75 years collective experience (specific number)
2. CISM (named certification)
3. CISSP (named certification)
4. CISA (named certification)

That's 4 QV-eligible facts → Quantified-Verifiable

"third-party cybersecurity experts" - unnamed, NOT list
"VPN traffic" - generic technology term

I'm tallying up the verifiable credentials here. The team brings 75 years of combined experience plus three major certifications—CISM, CISSP, and CISA—which gives me four solid QV-eligible facts to work with. The generic references like "third-party cybersecurity experts" and "VPN traffic" don't add specificity, so they don't count toward the verifiable category.

fact: CIO leads information security team

fact: Over 75 years of collective cybersecurity experience

fact: CISM certification

fact: CISSP certification

fact: CISA certification


reasoning: The paragraph opens by identifying the VP Information Services & Technology as the leader of the information services team, describes their experience (25 years) and committee chairmanship, and then details the collective experience of named committee members. While the second half describes escalation processes (scorecard, IRP evaluation), the framing and primary subject is the management role holder and the committee structure they lead. Only one QV-eligible fact (25 years of experience) prevents Quantified-Verifiable; multiple firm-specific facts (named role, named committees, named internal programs) confirm Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

Content: Describes the VP of Information Services & Technology, their role chairing committees, experience, and then describes processes around security scorecards and incident escalation.

Category analysis:
- Starts with management role info (VP title, experience, committee chair)
- Then shifts to process description (monthly scorecard, incident evaluation, escalation procedures)

Person-vs-function test: The paragraph starts about the person (VP title, 25 years experience, chairs committee) but then shifts to describing processes. The dominant content seems split. Let me assess: roughly half is about the person/role structure, half about what happens procedurally.

The opening really emphasizes the person's credentials and committee memberships, but then the bulk of the content walks through what actually happens operationally—the scorecard reviews, incident response procedures, and escalation workflows. The person's qualifications frame the section, but the processes themselves take up most of the space, making this borderline between person-focused and function-focused.

Looking at it again, the paragraph opens with "is led by our VP" and establishes their background and committee roles first, which sets the framing around the individual. The process details that follow feel like they're there to explain what this person and their team actually do, so Management Role seems like the right fit.

For the specificity check: the VP title is clearly IT and security-focused, which matches the IS list, and the 25 years of experience is specific enough.

Now I'm going through the QV-eligibility of each fact. The experience figure is quantified, so that counts. The committee names are firm-specific but don't meet QV criteria. The monthly cadence is too generic. The scorecard and IRP program names are firm-specific but also not QV-eligible. So I'm only finding one QV-eligible fact here, which puts this in the Firm-Specific category.

fact: Vice President Information Services & Technology

fact: approximately 25 years of experience in information technology

fact: Infosec Oversight Committee

fact: Infosec Committee

fact: Executive Steering Committee

fact: Information Security Scorecard

fact: IRP (Incident Response Plan with unique abbreviation)


reasoning: The entire paragraph is about the CISO as a person — their experience (25+ years), education (master's degrees), certification (CISSP), and reporting line (to CIO). This passes the person-vs-function test decisively. Two or more hard verifiable facts (25 years of experience + CISSP certification) qualify for Quantified-Verifiable.

thinking:
Classify this paragraph.

This is about the CISO's qualifications, experience, credentials, reporting line. It's about the person, not the function.

Content category: Management Role

Specific facts:
- CISO (cybersecurity-specific title)
- 25 years of experience (quantified)
- Master's in computer engineering and business administration
- CISSP certification (named certification)
- CIO (reporting line)

QV check: 25 years of experience (quantified) + CISSP (named certification) = 2 hard verifiable facts → Quantified-Verifiable

fact: CISO (cybersecurity-specific leadership role)

fact: Over 25 years of experience

fact: CIO (reporting line)


reasoning: The paragraph's primary subject is the Board of Directors and its committee's oversight of cybersecurity risk, including the charter amendment and committee renaming — classic Board Governance. Contains one QV-eligible fact (May 2022 date) and one IS-list fact (non-generic committee name 'Audit and Risk Committee'), but only one QV-eligible fact, so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board and management oversight, Audit Committee charter amended in May 2022, renamed to "Audit and Risk Committee" - this is about board-level governance of cybersecurity.

Category: Board Governance - the Board and its committee are the primary actors.

Specific facts:
- "May 2022" - specific date
- "Audit and Risk Committee" - this is a renamed committee, could be considered firm-specific (non-generic committee name)

The committee was renamed from "Audit Committee" to "Audit and Risk Committee" - this is a firm-specific detail.

Specificity: "May 2022" is a specific date (one QV-eligible fact). "Audit and Risk Committee" - this is a named non-generic committee. That's firm-specific but not QV-eligible. So we have one QV-eligible fact (date) and one IS fact (named committee). Only one QV-eligible → Firm-Specific.

I'm counting the QV-eligible facts here: the May 2022 date qualifies, but there's nothing else—no named firms, dollar amounts, headcounts, or tools. That single QV-eligible fact puts this in the Firm-Specific category.

fact: May 2022 — date Board adopted amended charter

fact: Audit and Risk Committee — renamed non-generic committee


reasoning: The paragraph describes an actual ransomware incident — its date, operational impact (restaurant closures), and data scope (employee PII, no customer databases). Multiple hard verifiable facts (specific date, quantified restaurant closures, quantified duration) satisfy the QV threshold.

thinking:
Let me analyze this paragraph from YUM Brands' 10-K filing.

Content: Describes a specific ransomware attack on January 18, 2023, with details about impact (closure of fewer than 300 restaurants, one market, one day), affected data (employee personal information), and what wasn't affected (customer databases).

Category: Incident Disclosure - describes what happened in an actual cybersecurity incident.

Specificity: Let me count hard verifiable facts:
- "January 18, 2023" - specific date
- "fewer than 300 restaurants" - quantified
- "one market for one day" - quantified

- That's at least 2 hard verifiable facts, so this qualifies as Quantified-Verifiable.

fact: January 18, 2023 — date of ransomware attack announcement

fact: fewer than 300 restaurants closed

fact: one market for one day


reasoning: The paragraph's primary communicative purpose is a materiality assessment: AFG has not experienced material adverse events and has not paid penalties or settlements related to a breach. This is a strategic judgment about cyber risk impact, fitting Strategy Integration per Rule 6. 'Over the last three years' is a vague timeframe (not a specific date), and all other language is generic boilerplate.

thinking:
Let me analyze this paragraph.

Content: Discusses cyber-attacks experience generally, then states no material adverse events over last three years and no penalties/settlements paid.

Category: The paragraph makes a materiality assessment - "has not experienced any material adverse events" and "has not paid any penalties or settlements." This is a Strategy Integration paragraph per Rule 6 (materiality disclaimers).

Specificity: "Over the last three years" - this is a vague timeframe, not a specific date. No named entities, no dollar amounts, no specific facts from the IS list. This is Generic Boilerplate.


reasoning: The paragraph describes two activities: engaging external experts to assess the company's cybersecurity program (Risk Management Process per Rule 3 — external assessors serving the company) and purchasing cybersecurity insurance (Strategy Integration). The external assessment is the lead topic and occupies more text, making Risk Management Process the dominant category. No named firms, frameworks, dates, dollar amounts, or cybersecurity-specific roles are present — 'external cybersecurity experts' and 'cybersecurity risk insurance policy' are generic and unnamed.

thinking:
Let me analyze this paragraph.

Content: External experts assessing cybersecurity program + cybersecurity insurance policy.

Category: The paragraph has two parts - external experts assessing the program (could be Third-Party Risk or Risk Management Process) and cybersecurity insurance (Strategy Integration). The external experts are hired to serve the company (Rule 3: "External assessor hired to test the company → Risk Management Process"). The insurance is Strategy Integration. Which is dominant? Both sentences are roughly equal length. The first sentence is about using external experts to assess their program - this is Risk Management Process per Rule 3. The second is about insurance - Strategy Integration. It's a toss-up but I'd lean Risk Management Process since the external assessment is the first and slightly more substantive point, and insurance is mentioned briefly.

The external assessment of the company's own cybersecurity program is the primary activity here, making this Risk Management Process. The insurance component is secondary to the main focus on having external experts evaluate their internal processes.

Specificity: No named frameworks, no named firms ("external cybersecurity experts" is unnamed), no specific dates, no dollar amounts mentioned.


reasoning: The paragraph is predominantly an incident narrative: it describes the CDK cybersecurity event with a detailed timeline (four specific dates), names the third-party vendor (CDK), identifies affected systems (DMS, CRM), and chronicles the restoration sequence. While it closes with a materiality/strategy sentence and cross-reference, the dominant communicative purpose is describing what happened in the incident. Multiple hard verifiable facts (4+ specific dates, named firm, named systems) clearly place this at Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This describes the CDK cybersecurity incident in detail - dates, systems affected, timeline of restoration, and business impact.

Content Category: This is primarily an Incident Disclosure. It describes what happened (CDK incident), when (multiple specific dates), what was affected (DMS, CRM, other systems), and the response/restoration timeline. There's a Strategy Integration element at the end (business impact, materiality language), but the dominant content is the incident narrative.

Specificity: Let me count hard verifiable facts:
- June 19, 2024 (specific date)
- CDK (named third-party firm)

- June 26, 2024 (specific date)
- June 30, 2024 (specific date)
- July 31, 2024 (specific date)
- DMS, CRM (named systems)

Multiple hard verifiable facts → Quantified-Verifiable (4)

fact: June 19, 2024 — CDK notified of cybersecurity incident

fact: CDK — named third-party provider

fact: June 26, 2024 — CDK began restoring access

fact: June 30, 2024 — resumed processing transactions in DMS

fact: July 31, 2024 — regained access to all Affected Systems

fact: Dealer management system (DMS), customer relationship management system (CRM)


reasoning: The paragraph contains an explicit materiality assessment ('have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition'), which per Rule 6 makes it Strategy Integration even though it includes a cross-reference to Risk Factors. However, the language is entirely boilerplate with no firm-specific facts.


reasoning: The paragraph describes two internal oversight mechanisms — a cross-functional cybersecurity committee and an internal audit function providing independent assurance. Applying the person-vs-function test: the CISO is mentioned as committee chair (attribution), but the substantive content describes what the committee and internal audit team do (oversight of cybersecurity/DR/BC programs, independent assurance, quarterly audit reports). Removing the CISO reference, the paragraph still fully describes organizational processes. CISO is a cybersecurity-specific title on the IS list, yielding Firm-Specific; no second QV-eligible hard fact exists (Audit Committee and 'quarterly' are on the NOT list).

thinking:
Let me analyze this paragraph.

Content: Describes a cross-functional cybersecurity oversight committee led by CISO, and internal audit providing assurance on cybersecurity program with quarterly reports to Audit Committee.

Category: This is about organizational structure for cybersecurity oversight. The CISO is mentioned as chair, but the paragraph is about the committee and internal audit function - these are process/governance structures. The primary subject is the committee and the internal audit team, not the CISO as a person. This is about organizational processes for oversight.

The committee is a cross-functional cybersecurity oversight committee - this describes internal processes/structure. The CISO is mentioned as attribution (chair). The internal audit team provides assurance. This feels like Risk Management Process - it's about the company's internal oversight processes.

I'm trying to pin down whether this is about the management structure itself or the processes it enables. The committee's existence and reporting lines suggest a Management Role classification, but the focus is really on what the committee and internal audit actually do - the oversight and assurance functions. That points more toward Risk Management Process.

Let me apply the person-versus-function test more carefully: stripping away the CISO title and chair designation, the paragraph still describes the committee's responsibilities and internal audit's role. That's a strong signal this belongs in Risk Management Process.

For the specificity check, I see CISO mentioned, which is cybersecurity-specific and would qualify for the IS list. But the committee itself isn't a uniquely named entity - it's just described generically as a "cross-functional cybersecurity oversight committee." The Audit Committee reference doesn't appear to be on the list either, and the quarterly cadence is just a detail about frequency.

So I'm left with one IS-eligible fact: the CISO role. Since that's a named role and doesn't contribute to the QV threshold, this classifies as Firm-Specific overall.

fact: CISO serves as chair of cybersecurity oversight committee


reasoning: The paragraph's primary purpose is describing the management organizational structure for cybersecurity—which roles are involved and how committees (Incident Response Team, Management Disclosure Committee) are composed. While incident response process flow is mentioned, it is subordinate to identifying the management participants and committee structure, fitting the 'management committees responsible for cybersecurity' aspect of Management Role. VP of IT is a cybersecurity-specific title on the IS list, and the specific departmental composition of the Disclosure Committee (legal, finance, risk management, internal audit, communications) qualifies as a firm-specific team composition, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes management oversight structure - names several roles (COO, CFO, VP of IT, CPO, GC) and describes incident response flow and Disclosure Committee composition.

Category: This is about management roles and their function in cybersecurity. The paragraph describes who is involved and what they do. But let me apply the person-vs-function test. The paragraph names roles but doesn't describe anyone's background, credentials, or qualifications. It describes the process: how incidents flow through the organization. The roles are listed as participants in a process.

Actually, the heading is "Management Oversight" and the paragraph describes the management structure for cybersecurity. It lists roles involved but then describes the process - incidents come to IRT, IRT responds per IR plan, incidents reported to Disclosure Committee for materiality review. The composition of the Disclosure Committee is described.

The codebook clarifies this - Management Role includes management committees responsible for cybersecurity, and this paragraph specifically details the Incident Response Team and Disclosure Committee, their composition, and their responsibilities in the incident handling process. That fits squarely under Management Role. on the IS list explicitly. Chief Privacy Officer? Not clearly cybersecurity-specific.
- COO, CFO, GC: these are on the NOT list (generic C-suite)
- "Incident Response Team": generic program name
- "Disclosure Committee": not a cybersecurity-specific committee
- Specific team composition: "legal, finance, risk management, internal audit and communications" - this matches "Specific team/department compositions" on the IS list

So VP of IT is a firm-specific fact, and the specific departmental composition is another.

QV check: VP of IT is a named role (not QV-eligible), departmental composition is not QV-eligible. No dates, dollar amounts, headcounts, named firms, named tools, named certifications. So not QV.

Firm-Specific (3) based on VP of IT and specific team composition.

fact: VP of IT

fact: CPO (Chief Privacy Officer)

fact: Disclosure Committee composed of GC, VP of IT, CPO, CFO, COO, IRT members, and senior management from legal, finance, risk management, internal audit and communications


reasoning: The paragraph is entirely about the people filling cybersecurity leadership roles — their titles, years of experience, reporting lines, and credentials. Two QV-eligible hard facts: 14 years of experience and 11 years of experience (specific durations are independently verifiable).

thinking:
Classify this paragraph.

This is about the people - CTO and CISO credentials, experience, reporting lines. Management Role.

Specific facts:
- CTO (cybersecurity-specific role)
- CISO (cybersecurity-specific role)
- 14 years of experience (quantified)
- 11 years of experience (quantified)
- Reports directly to President and CEO (reporting line)
- Master of Science degree in Cybersecurity (credential)
- Federal law enforcement agency (prior employer context, though unnamed)

QV-eligible: 14 years, 11 years = two hard verifiable facts. → Quantified-Verifiable

fact: CTO

fact: CISO

fact: over 14 years of experience in information security

fact: over 11 years of experience in information security


reasoning: The paragraph describes TDS's internal cybersecurity processes — risk identification, monitoring, incident simulations, risk classification, and ERM integration — with third-party oversight as one component among many, making Risk Management Process the dominant category. Despite appearing detailed, it contains no named frameworks (NIST, ISO), no cybersecurity-specific titles (CISO, CIO), no named tools/firms, no specific dates or numbers — only generic practices ('regular assessment,' 'quarterly basis,' 'incident simulations'), company self-references, and generic cadences, all of which fall on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes TDS's risk identification, third-party risk assessment, contractual obligations, security operations monitoring, incident simulations, risk classification, and ERM integration.

Category: This covers internal processes (risk identification, monitoring, simulations, ERM integration) AND third-party risk (assessment process, contractual requirements, monitoring third-party environments). The dominant topic is the company's overall risk management process - third-party risk is one component among many. → Risk Management Process

Specificity: Let me check for specific facts.
- "TDS" - company self-reference, NOT list
- "third-party risk assessment process" - generic program name

- "TDS security operations program" - company self-reference + generic
- "TDS Enterprise Risk Management (ERM) program" - standard terminology, generic program name
- "quarterly basis" - generic cadence
- No named frameworks, tools, firms, dates, or headcounts
- "cyber incident simulations" - common practice
- "security leaders" - not a cybersecurity-specific title

No IS-list facts or named standards present.

Wait, "TDS security leaders" lacks specificity—no CISO or defined role mentioned.

This is generic boilerplate with minimal specificity.