reasoning: The entire paragraph describes the CIO as a person — years of experience, career history, prior roles, and educational credentials. This is squarely Management Role under the person-vs-function test. Multiple QV-eligible hard facts: specific years of experience (30+), specific date (2016), and three named universities (Pittsburgh, Youngstown State, Carnegie Mellon) — all independently verifiable.

thinking:
Classify this paragraph.

Content: About the CIO's background, experience, credentials, education. This is clearly about the person, not the function.

Category: Management Role

Specific facts:
- CIO (cybersecurity-specific title) → named_role
- 30 years of experience → quantified
- 2016 (assumed current role) → specific_date
- University of Pittsburgh → other_specific
- Youngstown State University → other_specific
- Carnegie Mellon University → other_specific

QV-eligible: 30 years experience, 2016 date, University of Pittsburgh, Youngstown State, Carnegie Mellon = well more than 2 → Quantified-Verifiable

fact: CIO (cybersecurity-specific title)

fact: More than 30 years of technology experience

fact: Assumed current role in 2016

fact: University of Pittsburgh (BS in Electrical Engineering)

fact: Youngstown State University (MS in Engineering)

fact: Carnegie Mellon University (MBA)


content_category: Strategy Integration

category_confidence: medium

specificity_confidence: medium

reasoning: The paragraph opens with an explicit materiality assessment for 2023 ('did not identify any cybersecurity threats that have materially affected...business strategy, results of operations, or financial condition'), which frames the paragraph's primary communicative purpose. The 2020 incident is referenced as previously-disclosed historical context supporting the current materiality conclusion, fitting the tiebreaker 'brief mention of a past incident + materiality conclusion as the main point → Strategy Integration.' Two year-level dates (2023, 2020) qualify as specific dates on the IS list for Firm-Specific, but neither reaches month+year precision required for QV-eligible counting, so specificity stays at Firm-Specific.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. A materiality assessment for 2023 - "did not identify any cybersecurity threats that have materially affected..."
2. A reference to a 2020 incident - "we experienced a previously-disclosed cybersecurity incident"
3. Response actions to that incident

This is a mixed paragraph. The first sentence is a materiality disclaimer (Strategy Integration). The rest describes a past incident and response actions (Incident Disclosure).

Which is dominant? The materiality assessment is one sentence. The incident description is two sentences covering the 2020 event and response. But the incident is described as "previously-disclosed" - it's a backward reference, not a fresh disclosure.

So the main point is the 2023 materiality conclusion, with the 2020 incident serving as supporting context. The paragraph is essentially saying: we had an incident in 2020, we handled it, and nothing has materially impacted us since. The tiebreaker here is that a brief reference to a past incident paired with a materiality conclusion points to Strategy Integration as the primary category. I'm weighing whether this is truly borderline or if the incident description tips it toward Incident Disclosure. The paragraph does include substantive details about what happened—unauthorized access, disruptions, forensic response—but the framing around materiality assessment and the 2020 incident serving as historical context suggests the primary purpose is the materiality conclusion. The dominant purpose test points to Strategy Integration. For specificity, I have two specific dates but no named firms or dollar amounts, so that's two QV-eligible facts.

Now I'm checking whether bare years like "In 2023" and "In 2020" actually qualify as specific dates under the QV standard. The calibration examples show "month+year or exact date," and the IS list includes "fiscal 2025" as a year-level reference, which suggests bare years might count. But I'm uncertain whether they're truly "hard verifiable facts" in the way the QV definition intends—the examples consistently show more granular dates. for QV purposes. So this fact qualifies as Firm-Specific but falls short of the Quantified-Verifiable threshold since neither date includes the month. My final classification is Strategy Integration with Firm-Specific characteristics.


content_category: Management Role

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the ISC management committee and its leadership, then devotes significant content to the CIO's qualifications, experience, and certifications — making the person the primary subject (Management Role). Multiple QV-eligible hard facts are present: specific years of experience (25+) and multiple named certifications (Certified CISO, CISSP, CCSP, CIPT), easily exceeding the two-fact QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security Council (ISC) - a named internal committee with a unique identifier. It's comprised of leadership representatives, meets periodically. Led by CIO and CISO. Then describes the CIO's qualifications - 25 years experience, multiple certifications.

Category: This is a mix of Management Role and Risk Management Process. The paragraph describes a management committee (ISC) and then focuses on the CIO's qualifications. The person-vs-function test: the latter half is clearly about the person (CIO's experience and certifications). The first half describes the ISC committee's function. But the dominant content seems to be about who leads cybersecurity and their qualifications - Management Role.

Actually, looking more carefully at the structure: the ISC's actual functions—discussing threats and supporting policy changes—take up the first part, but the real focus shifts to the management structure itself and the CIO's credentials. Since the paragraph emphasizes the ISC as a management committee and dedicates significant space to the CIO's qualifications and experience, Management Role is the dominant category here. The specificity note: "Information Security Council (ISC)" is a named internal committee.

Now examining the QV-eligible facts: the "over 25 years" is a specific duration, and the certifications—Certified CISO, CISSP, CCSP, CIPT—are all named credentials. That's clearly two or more QV-eligible facts, which makes this Quantified-Verifiable.

fact: Information Security Council (ISC) — named internal program with unique identifier

fact: Chief Information Officer (CIO)

fact: CISO

fact: over 25 years of IT experience

type: quantified

fact: Certified CISO certification

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Cloud Security Professional (CCSP)

fact: Certified Information Privacy Technologist (CIPT)


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal cybersecurity risk management approach, ERM integration, and framework alignment — all hallmarks of Risk Management Process. It names NIST and ISO as frameworks but provides no firm-specific facts beyond that, making it Sector-Adapted.

fact: NIST framework

type: framework

fact: ISO framework


content_category: Board Governance

reasoning: The Board is the grammatical subject throughout, describing its oversight of cybersecurity risks, receipt of reports, and annual policy reviews. No specific facts from the IS list are present — 'the Board,' 'management,' 'regular,' and 'annual' are all generic per the NOT list.

thinking: Board is the grammatical subject throughout. No specific facts from the IS list - "the Board" is generic, "management" is generic, "quarterly"/"annual" are generic cadences. No named frameworks, no specific roles like CISO.


reasoning: The paragraph describes external assessors hired to test and audit the company's own systems (vulnerability testing, SOC 2 audit, IT general controls audit), making this Risk Management Process per Rule 3 (external assessors serving the company). Named firm Grant Thornton LLP and specific years (2023 and 2024) provide two QV-eligible hard verifiable facts.

thinking:
Let me classify this paragraph.

Content: Discusses third-party engagements for cybersecurity - vulnerability/penetration testing, Grant Thornton SOC 2 audit, IT general controls audit.

Category: Third-Party Risk - the central topic is engaging external parties for cybersecurity assessments. Wait, actually - these third parties are being hired to assess/test the COMPANY's own systems. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." So this is Risk Management Process.

Specificity:
- "Grant Thornton LLP" = named third-party firm (QV-eligible)

- "2023 and 2024" = specific dates (QV-eligible)
- "SOC 2 audit" = named standard

I've got two QV-eligible facts here - the named firm and the specific years - so this qualifies as Quantified-Verifiable.

fact: Grant Thornton LLP

fact: SOC 2 audit


reasoning: The paragraph describes the company's internal Information Security Program, its ERM integration, incident response planning, and framework alignment — all hallmarks of Risk Management Process. It names NIST CSF as a recognized framework, triggering Sector-Adapted, but contains no firm-specific facts from the IS list (the program names are generic, no cybersecurity-specific roles, dates, tools, or numbers are mentioned).

thinking:
Let me analyze this paragraph.

Content: Describes the company's Information Security Program, its integration with ERM, its policies around prevention/detection/mitigation/recovery, incident response plan, and framework alignment (NIST CSF).

Category: Risk Management Process - describes internal cybersecurity processes, framework adoption, ERM integration.

Specificity:
- "Information Security Program" - generic program name, no unique identifier
- "Security Incident Response Policy and Plan" - generic program name
- "National Institute of Standards and Technology Cybersecurity Framework" = NIST CSF → named framework → Sector-Adapted
- "ERM framework" - generic

- No firm-specific facts from the IS list (no named roles, no specific dates, no named tools, no headcounts)

Decision test:
1. Two+ hard verifiable facts? No.
2. Any IS-list fact? No unique identifiers on the programs, no cybersecurity-specific titles, no named committees, no dates, no tools, no firms, no numbers.
3. Named standard? Yes - NIST CSF → Sector-Adapted

fact: National Institute of Standards and Technology Cybersecurity Framework (NIST CSF)


reasoning: The paragraph describes the company's cybersecurity risk management and privacy programs as central to protecting confidential information and business operations. This is a generic introductory statement about internal processes with no named frameworks, roles, dates, or firm-specific details — it could appear unchanged in any company's filing.

thinking:
Classify this paragraph.

Content: Generic statement about cybersecurity risk management and privacy programs being important. No specific details about processes, frameworks, roles, or anything firm-specific.

Category: Risk Management Process - it's about the company's cybersecurity risk management program, though very generically stated.

Specificity: Generic Boilerplate - no named frameworks, no specific facts, could apply to any company.


reasoning: The paragraph is framed by the Audit Committee's oversight role and describes an escalation process that culminates at the board level; the CEO and IT Director details are subordinate to this governance structure. All entities mentioned (Audit Committee, CEO, IT Director, Board of Directors) are on the NOT list — Audit Committee is standard at every public company, CEO is generic C-suite, and 'IT Director' is generic IT leadership (not a cybersecurity-specific title), yielding no firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Audit Committee oversight, CEO informed by IT Director, escalation process to CEO/senior management/Audit Committee/Board.

Category: The paragraph starts with Audit Committee oversight (Board Governance), then discusses CEO being informed by IT Director, and an escalation process. The primary frame is governance/oversight structure. The Audit Committee is the opening subject, but then CEO and IT Director are discussed. This is a mix of Board Governance and Management Role.

The grammatical subject of the first sentence is "Audit Committee" → Board Governance signal. The second sentence has CEO as subject but describes communication from IT Director.

The escalation pathway flows from IT Director to CEO to senior management and up to the Audit Committee and Board, which reinforces the Board Governance framing. The IT Director role here is generic IT leadership rather than a specialized cybersecurity position, so the focus remains on the oversight structure itself. Overall, this is Board Governance—the paragraph centers on how information moves through the organizational hierarchy to reach board-level oversight. The escalation chain runs from IT Director up through CEO, senior management, and the Audit Committee to the board—so this is fundamentally about board governance oversight, even though the middle sentences focus on management communication. All the entities mentioned are generic roles on the NOT list, so this is generic boilerplate.


reasoning: The paragraph describes the company's own internal procedures for identifying, assessing, managing, and escalating cybersecurity incidents — core incident response process content. The specific departmental composition of the cross-functional working group (security, privacy, and legal) is a firm-specific organizational detail, but no named frameworks, dates, tools, or other QV-eligible facts are present.

thinking:
Classify this paragraph.

Content: Describes internal incident management procedures - security teams, cross-functional working group, escalation process. This is about the company's own internal processes for handling cybersecurity incidents.

Category: Risk Management Process - describes internal IR procedures, escalation process.

Specificity check:
- "cross-functional working group of security, privacy, and legal personnel" - specific team composition? The codebook says "Legal, Compliance, and Finance" is firm-specific as a specific team/department composition. Here we have "security, privacy, and legal personnel" - this is a specific departmental composition.
- "outside counsel" - generic unnamed entity → NOT list

- "material" - boilerplate language
- No named frameworks, dates, tools, or external firms mentioned

The team composition "security, privacy, and legal personnel" mirrors the codebook's example of specific departmental groupings like "Legal, Compliance, and Finance," so this qualifies as firm-specific.

Since there's only one IS fact present and no quantifiable details, this is Firm-Specific.

fact: Cross-functional working group composed of security, privacy, and legal personnel


reasoning: The paragraph's primary communicative purpose is the materiality assessment: 'We do not believe these cybersecurity incidents have had a material adverse effect on our Company, including our business strategy, results of operations, or financial condition.' Per Rule 6, any explicit materiality conclusion is Strategy Integration. The listed incident types (malware, phishing, account takeover, DoS) are generic categories, not descriptions of specific events, and the cross-reference to Risk Factors is noise. No IS-list facts are present—attack type enumeration and boilerplate threat language do not qualify.

thinking:
Let me analyze this paragraph.

Content: Discusses past incidents (malware, phishing, etc.) but the key substantive claim is the materiality assessment - "We do not believe these cybersecurity incidents have had a material adverse effect on our Company, including our business strategy, results of operations, or financial condition." This is a materiality disclaimer → Strategy Integration per Rule 6.

The paragraph lists types of incidents experienced but doesn't describe any specific incident. The materiality assessment is the primary communicative purpose.

Specificity: No named frameworks, no firm-specific facts from the IS list. The types of attacks (malware, phishing, etc.) are common practices/generic. Cross-reference at end is noise. → Generic Boilerplate.


reasoning: The paragraph's primary communicative purpose is identifying who oversees cybersecurity — the CEO and CFO — making Management Role the dominant category. However, CEO and CFO are generic C-suite titles (on the ✗ NOT list), not cybersecurity-specific roles, and the program description in the second sentence is entirely generic (prevent, detect, analyze threats), yielding no specific facts and Generic Boilerplate specificity.

thinking:
Let me analyze this paragraph.

Content: CEO and CFO oversee cybersecurity policies/processes, then describes what the program includes (prevent, detect, analyze threats, plans for incidents).

Category: The grammatical subjects are CEO and CFO - these are generic C-suite titles (on the NOT list). The paragraph describes who oversees and what the program includes. The CEO/CFO are managing cybersecurity, so this could be Management Role. But the second sentence is about what the program does - generic process description.

Per the person-vs-function test: Remove the CEO/CFO attribution and the paragraph describes a generic program. But the primary framing is about who oversees. The grammatical subject is CEO and CFO performing oversight.

CEO and CFO are generic C-suite titles that don't qualify as cybersecurity-specific roles like CISO would. The paragraph splits between management oversight attribution and program description, with the dominant framing being about who oversees the cyber function. Even though the titles are generic, the focus on management's oversight role suggests this fits Management Role rather than Risk Management Process.


reasoning: The paragraph contains an explicit materiality assessment ('have not encountered cybersecurity challenges that have materially impaired our operations or financial standing'), which per Rule 6 qualifies as Strategy Integration. The remainder appears to be a truncated cross-reference/garbled text ('For additional information regarding risks from cybersecurity Governance One of') that adds no substantive content. No named standards, firm-specific facts, or verifiable details are present.

thinking:
Let me analyze this paragraph from SPFX's 10-K filing.

The paragraph says: "We have not encountered cybersecurity challenges that have materially impaired our operations or financial standing. For additional information regarding risks from cybersecurity Governance One of"

This appears to be a materiality assessment ("have not...materially impaired our operations or financial standing") followed by what looks like a truncated/garbled cross-reference ("For additional information regarding risks from cybersecurity Governance One of").

The materiality assessment is the substantive content here. Per Rule 6, any paragraph that explicitly assesses whether cybersecurity risks have "materially affected" the company is Strategy Integration.

Looking at the specificity though, there are no named standards or company-specific facts here—just generic boilerplate materiality language that could apply to any company.


content_category: None/Other

reasoning: This paragraph is a forward-looking disclaimer stating no system is immune to threats and the company remains vigilant. It contains no substantive cybersecurity disclosure — no processes, governance details, or specific facts. It reads as generic cautionary language applicable to any company.


reasoning: The CSO is the grammatical subject in most sentences, describing reporting lines and communication structure (CSO → Information Security Committee → Audit Committee → Board). Per Rule 2, 'CISO reports quarterly to the Board on...' → Management Role. The content is about who reports to whom, fitting 'reporting lines as primary content' under Management Role, though the paragraph straddles Board Governance since the Audit Committee Chair also reports to the board. Two IS-list facts (CSO title, Information Security Committee) make it Firm-Specific, but neither qualifies as QV-eligible.

thinking:
Let me analyze this paragraph.

Content: Describes CSO communication with senior leaders, Information Security Committee, Audit Committee, and board. The CSO is the primary actor in most sentences, but the paragraph describes reporting/communication patterns between management and board.

The paragraph has mixed signals - CSO reporting upward (Management Role) vs. Board/Committee oversight (Board Governance). The CSO is the grammatical subject in most sentences, but the content is about the reporting cadence and communication structure. The Audit Committee Chair reporting to the board is Board Governance.

Looking at the dominant content: the paragraph describes how cybersecurity information flows from CSO → Information Security Committee → Audit Committee → Board.

The CSO is the grammatical subject in most sentences, but the Audit Committee Chair appears as the subject in one sentence. The dominant actor is the CSO, though the paragraph is really about the oversight and reporting structure rather than the CSO's individual qualifications or actions. Given the rules about grammatical subjects, the CSO being the primary subject in most sentences points toward Management Role, but the content itself is fundamentally about governance and oversight mechanisms.

Looking at the specific rule about reporting lines and management committee structure—that's explicitly Management Role. The CSO is a named cybersecurity-specific role, and the Information Security Committee is a named non-generic committee, both of which belong on the IS list. The quarterly cadence is generic and doesn't qualify. Neither the CSO nor the committee are QV-eligible since they're named entities rather than quantifiable variables.

fact: CSO (Chief Security Officer)

fact: Information Security Committee


reasoning: The paragraph is entirely about the CISO's credentials, tenure, and experience — squarely about the person, not the function. QV-eligible hard facts: CISSP certification, tenure since 2020 (specific date), and over two decades of experience (specific duration) — at least two hard verifiable facts.

fact: since 2020

fact: over two decades of experience


reasoning: Management is the grammatical subject performing two actions: overseeing cybersecurity risk mitigation and reporting incidents to the board. Per Rule 2, when a management role is the primary actor, assign Management Role. However, confidence is moderate because the paragraph is extremely thin — it could also read as a high-level Risk Management Process description (ERM integration) or Board Governance (reporting to the board). No specific facts appear: 'management,' 'board of directors,' and 'ERM' are all generic terms on the NOT list, yielding Generic Boilerplate.

thinking:
Let me classify this paragraph.

Content: Describes governance as part of ERM, management oversees cyber risk and reports incidents to board.

Category: This is about governance structure. Management is the subject performing oversight and reporting. But it's quite brief and touches both management and board. The primary actor is "Management" who "oversees" and "reports to the board." Per Rule 2, when management is the grammatical subject → Management Role. But this is really about the governance structure broadly. The paragraph frames this as part of ERM approach and governance.

Actually, looking more carefully: "Management oversees cybersecurity risk mitigation and reports to the board of directors any cybersecurity incidents." Management is the grammatical subject. Per the rules, this points to Management Role. But it's extremely generic - no named roles, no qualifications, no specific people.

I'm torn between Risk Management Process and Management Role here. The opening frames this as describing the company's cybersecurity program structure within their ERM approach, which suggests Risk Management Process. But the actual content focuses on who oversees and reports to whom—that's governance structure. Since management is the grammatical subject performing the action, it leans toward Management Role, though the term is so generic it's hard to pin down definitively.

Looking at the specificity: there's no named framework, no specific facts from the IS list, and both "management" and "board of directors" are on the NOT list. This is clearly Generic Boilerplate. I'll categorize it as Management Role since that's what the sentence structure emphasizes, even though the language is entirely generic.


reasoning: The paragraph's primary communicative purpose is to explain that the company has not adopted any formal cybersecurity processes due to limited resources — the absence of a program is not a description of a program. While it contains an embedded materiality assessment and a perfunctory management mention (sole employee/president with no cybersecurity background), these are subordinate to the overarching message that there is nothing substantive to disclose. This closely mirrors the codebook's None/Other example: 'We do not consider that we face significant cybersecurity risk and have not adopted any formal processes for assessing cybersecurity risk.' The generic forward-looking risk language in the final sentences further confirms None/Other.

thinking:
This is a long, multi-topic paragraph from a very small company (sole director/employee). Let me analyze it.

Content: The paragraph covers multiple topics:
1. No formal cybersecurity processes adopted (due to limited resources)
2. No previous incidents, no material effect (materiality statement)
3. President (sole director/employee) oversees cyber risks, has no cyber background
4. Operations description (eBay sales, third-party hosted systems)
5. Generic forward-looking risk language

This is similar to the SPAC/no-operations case. The company explicitly states they have NOT adopted any processes. The president mention is perfunctory - sole employee with no cybersecurity background. The materiality statement is present but in context of a company with no program.

So they do have actual operations selling on eBay, which distinguishes them from a pure SPAC, but the core message is still "we have no cybersecurity program and don't think we need one." The codebook's SPAC rule applies to companies with no operations or no formal processes, and this company explicitly states they haven't adopted any special processes. Even though they're not technically a SPAC, the spirit of the rule seems to apply here.

But I'm noticing the paragraph actually contains more substantive content than just a bare "we have no program" statement - there's a materiality assessment, details about who oversees cybersecurity (the president, with no cyber background), and some operational context. The question is whether this additional substance pushes it beyond the SPAC exception, or if the lack of formal processes still makes it fall under None/Other regardless.

Looking at Rule 6, materiality statements about cybersecurity risks typically point toward Strategy Integration. This paragraph does explicitly state they don't believe cybersecurity risks have materially affected them. But when I look at what actually dominates the text, it's describing the absence of processes and the management structure, not explaining strategic implications. The materiality disclaimer feels more like a concluding sentence than the main point.

I think the key is the dominant purpose - this is fundamentally about explaining why they have no formal cybersecurity program and who's responsible for it, with the materiality statement serving as a disclaimer rather than a substantive strategic discussion. The materiality language does trigger Rule 6, which means Strategy Integration should apply regardless of the boilerplate nature. But the SPAC exception is compelling here—the company genuinely has no formal program, the oversight is perfunctory, and the materiality assessment feels incidental to the core message that there's nothing to disclose. I'm going with None/Other because the paragraph's primary purpose is explaining the absence of a program, not describing one. Specificity is 1. I see they also mention their infrastructure, but the codebook is clear—when a company says they don't face significant cybersecurity risk and haven't adopted formal processes, that's None/Other regardless of other details. This paragraph follows that exact pattern, just with more length, so None/Other with Specificity 1 is the right call.


reasoning: This paragraph's primary communicative purpose is describing the company's overall cybersecurity risk management approach — cross-departmental structure, layered strategy, NIST framework adoption, and information security team activities. The CISO's credentials (20+ years experience, CISSP) are presented in service of describing the program's leadership structure, not as standalone biographical content; the person-vs-function test favors Risk Management Process. Two QV-eligible hard facts (20+ years of experience + named CISSP certification) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

This is a long, multi-topic paragraph. Let me identify the dominant category.

Content:
1. Cross-departmental approach to managing cybersecurity risk - Risk Management Process
2. Resources devoted to cybersecurity - generic
3. Threat landscape assessment, layered strategy - Risk Management Process
4. Dedicated CISO, responsible for leading security strategy - Management Role
5. CISO's 20+ years experience, CISSP certification - Management Role
6. CISO briefs Audit Committee - Board Governance
7. NIST framework leveraged - Risk Management Process
8. Information security team assesses threats - Risk Management Process

9. The paragraph's core focus is the company's overall cybersecurity risk management program, with the CISO serving as a key structural element rather than the main subject. Risk Management Process dominates the content, covering the cross-departmental approach, threat assessment methodology, NIST framework adoption, and team composition. While the CISO's credentials and experience are mentioned, they're presented as supporting details about who leads the program rather than as the paragraph's primary focus.

Looking at the verifiable facts here, I can identify two quantified-verifiable elements: the CISSP certification as a named credential held by the individual, and the 20+ years of experience as a specific measurable timeframe. These concrete details anchor the CISO's qualifications within the broader risk management structure.

fact: Dedicated Chief Information Security Officer (CISO)

fact: 20+ years of information security and risk management experience

fact: CISSP certification held by CISO


reasoning: The paragraph describes the company's internal incident response process — objectives, classification parameters, escalation protocols, documentation requirements, and materiality determination procedures. This is squarely Risk Management Process (IR planning). The CSIRP abbreviation is a named internal program with a distinguishing identifier, pushing specificity to Firm-Specific, but there are no QV-eligible hard facts (no dates, amounts, named firms, or tools).

thinking:
Let me analyze this paragraph.

Content: Describes the Cybersecurity Incident Response Team and the objectives of the CSIRP (Cybersecurity Incident Response Plan). This is about internal processes - incident response planning, classification, escalation, documentation, etc.

Category: Risk Management Process - describes internal IR planning processes and methodology.

Specificity: Let me check for facts.
- "Cybersecurity Incident Response Team" - generic team name
- "Security Operations Center" - generic
- "CSIRP" - this is "Cyber Security Incident Response Plan" with an abbreviation. The codebook says named internal programs with unique identifiers like "Cyber Incident Response Plan (CIRP)" qualify. "CSIRP" is similar - it's an abbreviated internal program name.

- CSIRP qualifies as firm-specific since it's their named internal program with a unique identifier, so that's one fact.
- No QV-eligible facts present - there are no dates, dollar amounts, headcounts, named third-party firms, named tools, or named certifications in this content.

fact: CSIRP (Cybersecurity Incident Response Plan) — named internal program with unique abbreviation


reasoning: The paragraph's primary purpose is a materiality assessment: past incidents 'have not materially affected' business strategy/results/financial condition, and no current incidents are expected to have material effect. Per Rule 6, explicit materiality conclusions are Strategy Integration even when boilerplate. The brief mention of past incidents is subordinate to the materiality judgment. No specific facts (no dates, amounts, named entities, or IS-list items) appear — standard boilerplate language.

thinking:
Classify this paragraph.

Content: References past incidents briefly, then makes materiality assessment twice (past and forward-looking). The primary communicative purpose is the materiality assessment — "have not materially affected" and "not currently aware of any... that would have a material effect." This is Strategy Integration per Rule 6.

Specificity: No named frameworks, no specific facts from the IS list. Boilerplate materiality language.


reasoning: The paragraph's primary purpose is identifying who is responsible for day-to-day cybersecurity management (the management team, including CFO and CEO), making Management Role the dominant category. However, CFO and CEO are generic C-suite titles on the IS-NOT list, the third-party consultant is unnamed, no frameworks or tools are named, and the forward-looking language ('will be', 'will include') describes aspirational activities rather than firm-specific facts, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Management team (CFO, CEO) responsible for cybersecurity. Forward-looking language ("will be"), mentions third-party consultant (unnamed), generic activities.

Category: Management Role - the paragraph is about who is responsible for cybersecurity management. The grammatical subjects are management team members. But let me check - CFO and CEO are on the "IS NOT" list (generic C-suite). The paragraph describes what they will do, which is somewhat process-oriented, but the primary framing is about who is responsible.

Actually, the paragraph starts with "responsibility for day-to-day management... lies with our management team, including CFO and CEO." Then describes what they will do. The person-vs-function test: if I remove the role references, it becomes generic process description.

The core issue is that while the paragraph identifies who's responsible, those roles are generic C-suite titles without cybersecurity specificity, and the consultant mentioned is unnamed. There are no specific frameworks, dates, or tools referenced—just boilerplate language about management oversight. This falls squarely into Generic Boilerplate.


reasoning: The paragraph describes a mix of the company's own cybersecurity practices: collaborative policy development with partners, security assessments of partners before data sharing, and employee phishing/awareness training. Third-party assessment is one component of the broader internal program description, not the central topic, so Risk Management Process is dominant per Rule 3. No named frameworks, specific roles, dates, tools, or other IS-list facts are present—all language is generic and transferable to any company.

thinking:
Let me analyze this paragraph.

Content: Describes working with partners to address cyber threats, conducting security assessments of partners before sharing data, and requiring employee phishing/awareness training.

Category: This paragraph covers multiple things - working with partners on policies/standards, assessing partners before data sharing, and employee training. The partner assessment piece is about third-party risk, but the paragraph also covers internal practices (employee training) and collaborative policy development. The central topic seems split between third-party risk oversight and internal risk management processes. The partner assessment is clearly third-party risk, but employee training is internal. Let me apply the dominant category rule.

Looking more carefully: sentence 1 is about collaboration with partners on policies/standards (could be Third-Party Risk or RMP), sentence 2 is about assessing partners before sharing data (Third-Party Risk), sentence 3 is about employee training (Risk Management Process). Two of three sentences involve external parties, but sentence 1 is more about collaborative information sharing than vendor oversight per se. Sentence 2 is clearly Third-Party Risk.

Reconsidering Rule 3 - when third parties are just one component of a broader internal program versus when vendor oversight is the central focus. Here the paragraph weaves together partner collaboration, partner assessments, and employee training as part of the company's overall security practices. Since third-party oversight isn't the sole focus, Risk Management Process seems like the better fit.

Looking at the specificity now - there are no named frameworks, roles, dates, or tools mentioned. The language stays generic: "Government, customer, industry and/or supplier partners," "Phishing and other awareness training," "Information security assessments." This all points to Generic Boilerplate.


reasoning: The entire paragraph is about the CISO as a person — their reporting line, years of experience, career background (Armed Forces), and professional certifications. This is squarely the person-vs-function test: remove the person's credentials and nothing substantive remains. Two or more hard verifiable facts qualify for QV: '25 years experience' (specific number) and 'CISSP certified' (named certification).

thinking:
Let me analyze this paragraph.

Content: About the CISO - reporting line, experience, background, certifications. This is clearly about the person, not the function.

Category: Management Role

Specific facts:
- CISO (cybersecurity-specific title)
- Reports to CFO (reporting line)
- 25 years experience (specific number)
- CISSP certified (named certification)
- (ISC)2 member (named organization)
- Armed Forces background

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

fact: CISO (cybersecurity-specific title)

fact: Reports to the Chief Financial Officer

fact: Over 25 years experience in IT and security

fact: CISSP certified

fact: (ISC)2 member

fact: Prior Armed Forces background in IT, telecommunications and security


reasoning: The paragraph describes the company's internal cybersecurity risk assessment process and ERM integration. No named frameworks, cybersecurity-specific roles, or firm-specific facts are present — 'annual,' 'enterprise risk management function,' and 'improvement projects' are all generic descriptors that could apply to any company.


reasoning: The paragraph describes the company's use of external experts (assessors, consultants, auditors) to evaluate and test its own cybersecurity program — threat assessments, penetration testing, and a NIST CSF materiality assessment. Per Rule 3, external assessors hired to test the company are Risk Management Process. The brief vendor-evaluation mention at the end is subordinate and cross-references a later section. NIST CSF is the only named standard; all third parties are unnamed ('a third-party advisor', 'a third party'), so no firm-specific facts exist beyond the framework reference.

thinking:
Let me analyze this paragraph.

Content: Describes engagement with external experts for cybersecurity risk management - assessors, consultants, auditors. Describes what these partnerships do: threat assessments, security consultations, penetration testing, NIST CSF materiality assessment, vendor evaluation.

Category: This is about the company's own internal processes that happen to use third parties. The third parties here serve the company (external assessors, consultants). The last sentence mentions vendor cybersecurity evaluation but says "as described below" - it's a brief mention. The dominant topic is the company's use of external experts as part of its own risk management. Per Rule 3: "External assessor hired to test the company → Risk Management Process." → **Risk Management Process**

Now looking at specificity - the NIST CSF is a named framework that qualifies as sector-adapted, but everything else is generic. No specific firm names, no dates, no numbers, and the practices mentioned like threat assessments and penetration testing are standard industry approaches. Only the NIST reference rises to the level of a named standard. → **Sector-Adapted**

fact: NIST CSF framework


reasoning: The paragraph contains an explicit materiality assessment ('no cybersecurity incident or attack... has materially affected... our business strategy, results of operations, or financial condition'), which per Rule 6 makes it Strategy Integration. The language is boilerplate materiality disclaimer with no specific facts — no dates, amounts, named entities, or firm-specific details.


reasoning: The paragraph describes the company's own internal cybersecurity measures, processes, and policies — squarely Risk Management Process. However, every item listed (incident response plan, business continuity plans, encryption, access controls, penetration testing, employee training, vendor risk management, cybersecurity insurance, dedicated staff) is a common practice found on the ✗ NOT list or is otherwise generic. No named frameworks, no named tools, no specific roles, no dates, no quantified facts — this could be pasted into any company's filing unchanged.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity measures, processes, and policies. Lists various controls and practices.

Category: Risk Management Process - describes internal processes, tools, methodologies.

Specificity: Let me check for specific facts.
- No named frameworks (NIST, ISO, etc.)
- No named roles (CISO, CIO, etc.)
- No named tools or products
- No dates, dollar amounts, headcounts
- No named firms
- Lists generic practices: incident response plan, business continuity plans, encryption, network security controls, etc.
- "24/7 systems monitoring" - generic practice

- "dedicated cybersecurity staff" - generic, no headcount

Everything here is standard boilerplate language with no specific details, named standards, or concrete metrics. This falls squarely into generic content.


reasoning: Although the paragraph opens with generic policy language and closes with third-party service providers, the dominant content is the CISO's and CTO's credentials, career history, and qualifications — squarely about the persons, not the function. Multiple QV-eligible hard facts are present: 13 years of experience, 20 years of experience, named firms IBM and Axway, and the named OWASP Security Shepherd project.

thinking:
Let me analyze this paragraph carefully.

This is a long paragraph that covers multiple topics. Let me break it down:

1. Opening sentences about systematic approach, comprehensive policies, best practices based on industry standards - generic RMP language
2. Policies cover roles, responsibilities, awareness, education, training, compliance - generic RMP
3. "Primary responsibility... rests with our CISO within our GIS organization, who reports to our CTO" - Management Role (CISO title, reporting line)
4. CISO's background: 13 years experience, OWASP Security Shepherd founder/project lead, led IBM's ethical hacking team, principal security engineer at Axway, product security architect, director of product security - Management Role (extensive person details)

5. The CTO brings 20 years of telecom experience and serves as Chief Architect overseeing the GIS program, while the organization also engages external consultants and service providers for incident monitoring and response activities.

Category: Management Role

Specificity: I'm counting the verifiable facts here - the CISO has 13 years of experience, founded OWASP Security Shepherd, worked at IBM's ethical hacking team and as Principal Security Engineer at Axway, while the CTO has 20 years of experience. That's multiple named organizations and specific credentials that can be verified.

→ Quantified-Verifiable

fact: CISO title within GIS organization

fact: CISO reports to Chief Technology Officer

fact: CISO has over 13 years of experience

fact: Founder of OWASP Security Shepherd project

fact: Led IBM's ethical hacking team

fact: Principal security engineer at Axway

fact: CTO has over 20 years of experience in telecommunications

fact: CTO served as Chief Architect and Senior Software Engineer


reasoning: The paragraph's primary communicative purpose is about using incident experience to strengthen the information security program — a process improvement statement. The February 2024 incident is referenced but not described (no narrative of what happened, scope, or response), so it is not Incident Disclosure. The specific date (February 2024) is one firm-specific fact, reaching Firm-Specific but not QV.

thinking:
Classify this paragraph.

The paragraph references a past incident (February 2024) but the primary point is about using incident experience to improve the security program. Let me think about category.

The paragraph mentions a specific past incident but the main message is about learning from incidents to strengthen the program. This is about risk management process improvement informed by incidents. But it also references an actual incident.

Actually, the dominant purpose is about how they use incident experience to improve their program - that's Risk Management Process. The incident is referenced but not described (no details about what happened, scope, response).

Specificity: "February 2024" is a specific date → Firm-Specific (one fact, not two for QV).

fact: cybersecurity incident disclosed in February 2024


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of external vendors — tiering, annual evaluation, document requirements, and monitoring — making it Third-Party Risk. It names SSAE 18 (a recognized attestation standard, triggering at least Sector-Adapted) and describes a firm-specific tiering structure (tiers 1 and 2), which is unique to this company's program, pushing it to Firm-Specific. However, there are not two hard QV-eligible facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools), so it does not reach Quantified-Verifiable.

thinking: Third-Party Risk, firm-specific details about vendor tiering and evaluation.

fact: Vendors segmented into criticality tiers (tiers 1 and 2 as most critical)

fact: SSAE 18 attestation standard required from vendors


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any cybersecurity threats... that have materially affected or are reasonably likely to materially affect'), making it Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts are present — 'CTBI' is a company self-reference and the materiality language is boilerplate.

thinking:
Materiality assessment present → Strategy Integration per Rule 6. Cross-reference appended doesn't change it.

Specificity: No named standards, no firm-specific facts from the IS list. "CTBI" is a company self-reference (NOT list). Boilerplate materiality language.


reasoning: This paragraph is generic risk-factor language about hypothetical cybersecurity incidents — service interruptions, data loss, reputational harm, legal liability — with a cross-reference to Item 1A Risk Factors. It contains no substantive cybersecurity disclosure (no process, governance, incident, or materiality assessment). The phrase 'could materially harm' is hypothetical, not an explicit assessment of whether risks 'have materially affected' the business, so it does not qualify as Strategy Integration under Rule 6.

thinking:
Let me analyze this paragraph.

This is generic risk language about hypothetical cybersecurity incidents - what could happen, potential consequences. It includes a cross-reference to Risk Factors. The last sentence mentions "materially harm" but it's hypothetical ("could materially harm"), not an actual materiality assessment of whether risks "have materially affected" the business.

This is not a materiality assessment (Strategy Integration) - it's hypothetical risk language. It's not describing any actual incident, process, or governance structure. It's essentially risk factor language that ended up in Item 1C.

Category: None/Other - this is generic risk language, not substantive cybersecurity disclosure. It describes hypothetical consequences and includes a cross-reference.

The language here is completely boilerplate with no specific facts or named standards - just standard risk disclaimers.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual ransomware incident — its discovery, response actions (engaging forensics/counsel), outcome (no ransom paid, no data exfiltrated), and remediation. This is squarely Incident Disclosure. The specific date 'August 2020' is the only hard fact; 'third-party forensics experts' and 'outside counsel' are unnamed and do not qualify. One specific fact → Firm-Specific, not QV.

thinking:
Let me analyze this paragraph.

Content: Describes a ransomware incident from August 2020 - detection, response, outcome, and remediation. This is clearly an Incident Disclosure.

Specific facts:
- "August 2020" - specific date
- That's really the only hard verifiable fact. "third-party forensics experts" is unnamed, "outside counsel" is unnamed.

No named firms, no named tools, no dollar amounts, no headcounts beyond the date.

One specific date → Firm-Specific (one fact, not two for QV).

fact: August 2020


reasoning: The CISO is the grammatical subject performing the primary action — reporting to the CFO, CEO, and ultimately the Board. Per Rule 2, 'Management role reports TO the board → Management Role.' The paragraph's primary content is the reporting line structure (CISO → CFO/CEO → Compliance Committee → Board), not the board's oversight activities. The CISO title (IS list) and the Compliance Committee (named non-generic committee, IS list) make this Firm-Specific, but neither is QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

The paragraph describes reporting lines: CISO reports to CFO and CEO, and matters are escalated to Compliance Committee and Board. The primary actor is the CISO reporting upward, but the paragraph also discusses board oversight.

The grammatical subject starts with "The CISO" - describing reporting lines. But the purpose is about ensuring board/management oversight. The paragraph describes the flow of information from CISO → CFO/CEO → Compliance Committee → Board.

This is a borderline Board Governance vs Management Role case. Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). Here the CISO is the one reporting, making CISO the primary actor. But the paragraph's communicative purpose is about ensuring oversight at all levels.

Actually, looking more closely at the structure: the CISO actively informs the CFO and CEO, and significant matters flow upward to the Compliance Committee and Board. This is fundamentally about the reporting structure and chain of escalation, which makes it a Management Role classification based on the codebook's definition of reporting lines as primary content.

For the specificity check: CISO is a named cybersecurity role that qualifies for the IS list, and Compliance Committee is a named committee that also qualifies. The CFO and CEO are generic C-suite titles, so they don't meet the specificity threshold. No dates or QV-eligible content here.

So this falls into Firm-Specific with at least one IS fact. But reconsidering the paragraph's actual focus—it's titled "Reporting to Board of Directors" and emphasizes the board's comprehensive oversight, with the CISO reporting being the mechanism that enables that oversight. That aligns with Management Role per the categorization rule. I'll categorize this as Management Role, Firm-Specific.

fact: CISO (cybersecurity-specific title)

fact: Compliance Committee (non-generic named committee)


reasoning: The paragraph describes incident response process steps — stakeholder notification, law enforcement cooperation, and post-incident analysis — which are internal cybersecurity processes. All language is generic with no named frameworks, roles, dates, tools, or firm-specific details.

thinking:
Classify this paragraph.

This appears to be a list of incident response steps - notification, cooperation with law enforcement, post-incident analysis. These are internal cybersecurity processes describing what the company does as part of incident response planning.

No named frameworks, no specific facts, no dates, no names. All generic language.

Category: Risk Management Process (describes IR planning steps)
Specificity: Generic Boilerplate


reasoning: The paragraph describes the company's own policies and processes for protecting IT systems and responding to threats, which is core Risk Management Process content. The mention of 'outside consultants' is incidental attribution (unnamed entities on the NOT list), not central vendor oversight. No named frameworks, roles, tools, dates, or other specific facts are present — entirely generic language that could apply to any company.

thinking:
Classify this paragraph.

Content: Describes policies/processes for protecting IT systems, managed by outside consultants who resolve issues.

Category: Risk Management Process - describes internal processes for cybersecurity, managed by consultants. The consultants here serve the company's own processes, not vendor oversight as the central topic.

Specificity: No named frameworks, no named roles (just "outside consultants" which is on the NOT list), no specific facts. Generic Boilerplate.


reasoning: The paragraph opens with generic program description but the majority of its content (3 of 5 sentences) focuses on management structure: who leads the program (IT Support Associate Director), their qualifications (20+ years experience), committee composition (IT Steering Committee with named roles), and committee activities. The person/structure content dominates over the process content. Two QV-eligible hard facts: specific years of experience ('over twenty years') and specific headcount in committee composition ('two Associate IT Directors').

thinking:
Let me analyze this paragraph carefully.

Content: Describes the company's information security program, tools, framework, and then identifies specific roles and committee composition.

Category analysis:
- Describes the program and tools (Risk Management Process)
- Names specific roles: "IT Support Associate Director" and "IT Steering Committee"
- Describes the person's experience: "over twenty years of experience in technology management and cybersecurity"
- Describes committee composition: "two Associate IT Directors, the CEO, and CFO"
- Describes committee activities: "convenes quarterly to review IT control policies"

This is a mixed paragraph. The first two sentences describe the program generically.

The paragraph opens with program description but then pivots to organizational structure—specifically who oversees it and their qualifications. The second half focuses heavily on the IT Support Associate Director's background, the committee's makeup, and their oversight activities. It's roughly balanced between describing the program itself and describing the people and structure managing it, though the organizational details dominate the latter portion. Looking at the sentence breakdown, the first two sentences establish the program itself, but sentences three through five shift focus to who runs it—the IT Support Associate Director's background and the committee structure. By weight and substance, this is really about the management role and the person's qualifications, so I should categorize it as Management Role rather than Risk Management Process.

Now I'm checking what qualifies as firm-specific or quality-of-evidence eligible. The IT Steering Committee is a named, non-generic committee that appears on the IS list, so that's firm-specific. The "over twenty years of experience" is a concrete number that could support quality of evidence. The committee composition itself—two Associate IT Directors, the CEO, and CFO—is specific enough to be substantive.

fact: IT Support Associate Director (cybersecurity leadership title)

fact: IT Steering Committee (named non-generic committee)

fact: Committee comprised of two Associate IT Directors, CEO, and CFO


reasoning: The paragraph is primarily a cross-reference to Item 1A Risk Factors ('As referenced in...') combined with generic forward-looking risk language ('may be materially affected'). Unlike Strategy Integration materiality assessments that conclude whether risks 'have materially affected' the business, this merely acknowledges the possibility of future impact — a truism for any company. It makes no substantive backward-looking materiality conclusion and contains no cybersecurity disclosure content beyond the cross-reference.

thinking:
Let me analyze this paragraph.

Content: References Item 1A Risk Factors, mentions the organization "may be materially affected" by cybersecurity threats targeting internal IT or vendor systems.

Category: This is a cross-reference to Risk Factors combined with a forward-looking materiality statement. The key phrase is "may be materially affected" — but this is hypothetical/forward-looking risk language, not an explicit materiality assessment of whether risks "have materially affected" the company. It's saying threats *could* affect them, not assessing whether they *have*. This reads more like generic risk language with a cross-reference.

Actually, let me re-read: "our organization may be materially affected by cybersecurity threats" — this is forward-looking risk acknowledgment, not a materiality assessment.

Comparing this to actual materiality assessments like "have not materially affected" or "are not reasonably likely to materially affect," this is just generic risk language saying "we might be affected." The codebook is clear: a pure cross-reference with no substantive materiality conclusion falls into None/Other. Since this paragraph only acknowledges potential risk without making an actual assessment of impact, it's not really a Strategy Integration claim—it's just a risk reference.


reasoning: The paragraph is entirely about the person filling the CISO role — his name, years of experience, and background. This is the person, not the function. Two QV-eligible hard facts: named individual (Chadd Pence) and specific years of experience (over 25 years).

fact: CISO

fact: Mr. Chadd Pence (named individual)

fact: over 25 years of experience


reasoning: The paragraph primarily describes an actual cybersecurity incident — detection of unauthorized activity, activation of the IR plan, and containment/remediation steps — spanning two of three sentences. The final sentence is a materiality assessment, but the dominant communicative purpose is the incident narrative. Only one hard verifiable fact (specific date July 19, 2024); remaining details ('incident response plan,' 'third-party' absent, company self-reference) are on the NOT list, so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. Description of an actual incident (date, detection, response actions)
2. A materiality assessment

For content category, I need to determine the dominant purpose. The first two sentences describe what happened - an incident on July 19, 2024, detection, activation of IR plan, containment. The third sentence is a materiality disclaimer.

By the tiebreaker rules: "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure" vs "Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration"

The incident narrative dominates with two of three sentences focused on what actually occurred. Looking at specificity, I have one concrete verifiable fact—the July 19, 2024 date—while the company self-reference and incident response plan are generic. That makes this Firm-Specific.


reasoning: The paragraph is primarily a narrative of a specific cybersecurity incident — ransomware attack, unauthorized encryption, malware deployment, temporary manual processes, and timeline. The closing materiality sentence ('no material impact') is subordinate to the incident description. Only one hard verifiable fact (specific date June 28, 2023) is present; no named firms, tools, or additional quantified details, so it reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Incident description with specific date, ransomware details, and response actions.

Content category: Incident Disclosure - describes what happened, when, scope, response.

The last sentence mentions "no material impact" which touches Strategy Integration, but the dominant content is the incident narrative.

Specific facts:
- "June 28, 2023" - specific date
- ransomware attack, unauthorized encryption, malware deployment - these are incident details but not named tools/firms

QV check: Only one hard verifiable fact (the specific date). No named firms, no named tools, no dollar amounts, no headcounts.

So: Firm-Specific (one specific date).

fact: On or about June 28, 2023


reasoning: The paragraph includes a cross-reference to Risk Factors (which alone would be None/Other) but also contains an explicit materiality assessment: 'we did not experience any material cybersecurity incidents or threats.' Per Rule 6, any paragraph that assesses whether cybersecurity risks/incidents have materially affected the company is Strategy Integration, even when brief. No specific dates, named entities, or firm-specific facts are present—'last reporting year' is a generic timeframe—so specificity is Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A cross-reference to Risk Factors
2. A statement that they didn't experience material incidents/threats

The second sentence is a materiality assessment - "we did not experience any material cybersecurity incidents or threats." This is assessing whether cybersecurity incidents have materially affected the company. Per Rule 6 and the codebook, materiality disclaimers → Strategy Integration.

Specificity: No named standards, no firm-specific facts from the IS list. "Last reporting year" is a vague timeframe, not a specific date. → Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected... business strategy, results of operations, or financial condition'), making it Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No specific facts from the IS list are present — all language is boilerplate materiality disclaimer.

thinking:
Materiality assessment present → Strategy Integration per Rule 6. Cross-reference appended doesn't change it.

Specific facts: None from the IS list. Generic boilerplate language throughout.


reasoning: The CIO is the grammatical subject performing actions throughout — coordinating with legal counsel/third parties and monitoring incident prevention/remediation. While it touches on processes (incident response, risk assessment), the paragraph's primary purpose is describing the CIO's responsibilities and role, making it Management Role. However, the person-vs-function test is borderline: removing the CIO reference leaves process descriptions intact, which could support Risk Management Process. The CIO title is a cybersecurity-specific role on the IS list, giving Firm-Specific; no second QV-eligible fact exists.

fact: CIO (Chief Information Officer)


reasoning: The paragraph is primarily about organizational structure — who comprises the cybersecurity team, which roles (CTO, CIO) oversee cybersecurity, and what management-level committees exist (Cybersecurity Disclosure Steering Committee, Rapid Response Team). While it describes what these groups do, the dominant communicative purpose is identifying the people and structures responsible for cybersecurity management. Multiple firm-specific facts (CTO/CIO oversight, named non-generic committees with specific compositions) place it at Firm-Specific, but no two hard verifiable facts (no specific numbers, dates, named third-party firms, or named tools) are present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Newmont Corp's 10-K filing.

Content: Describes the cybersecurity team's experience, certifications, the CTO and CIO oversight, and several management-level committees (Cybersecurity Disclosure Steering Committee, Rapid Response Team, head of privacy).

Category: This paragraph covers multiple things - the cybersecurity team composition, management roles (CTO, CIO), and various committees/teams. The primary content is about organizational structure - who does what. It describes the people and teams rather than specific processes. But it also describes what these teams do (processes).

Let me apply the person-vs-function test: If I remove the role titles and team names, there's still substantial process description (assess and manage cybersecurity risk, tabletop exercises, incident response, privacy risk identification). But the paragraph is fundamentally about organizational structure - who the people are, what committees exist, how they're composed.

The core of this is organizational structure - the teams, committees, and oversight roles. While the paragraph mentions what these groups do, the framing is primarily about who exists and how they're arranged, which points to Management Role.

Looking at the specifics: CTO and CIO oversight, named committees like the Cybersecurity Disclosure Steering Committee and Rapid Response Team, and the team composition across IT, cybersecurity, operations, risk, finance, legal and compliance. There aren't hard numbers or named third-party vendors though, so this doesn't meet the QV threshold.

fact: Chief Technology Officer has direct oversight of cybersecurity

fact: Chief Information Officer has direct oversight of cybersecurity

fact: Cybersecurity Disclosure Steering Committee comprised of IT, cybersecurity, operations, risk, finance, legal and compliance

fact: Rapid Response Team includes senior executives across global operations

fact: Team composition includes Legal, Compliance, and other function leads for privacy risk


reasoning: The paragraph describes general employee training, policy distribution, and disciplinary procedures related to safeguarding information — internal security practices that fall under Risk Management Process. However, the content is borderline with None/Other as it reads more like generic corporate policy language than substantive cybersecurity disclosure. No frameworks, named roles, dates, or firm-specific facts are present.

thinking:
Classify this paragraph.

Content: General language about protecting client assets, safeguarding information, employee training on policies, disciplinary actions for violations. No cybersecurity-specific content - this is general compliance/HR language.

Category: Risk Management Process - it does touch on employee training and policies related to information protection. But it's very generic and reads more like general corporate policy language. Let me reconsider... It mentions protecting assets, safeguarding information, employee training, policy adherence, disciplinary actions. This is about internal security practices broadly.

Actually, this is describing security awareness training and policy enforcement, which falls under Risk Management Process.

Specificity: No frameworks, no named roles, no specific facts.

This is just generic boilerplate language without any substantive detail.


reasoning: The paragraph's primary communicative purpose is a materiality assessment ('not aware of any risks from cybersecurity threats... that have materially affected or are reasonably likely to materially affect Commvault, including its business strategy, results of operations or financial condition'), which is the hallmark of Strategy Integration per Rule 6. The incident involving the Azure environment and nation-state threat actor is introduced as a supporting example ('For example...') within the materiality framing, rather than as a standalone incident narrative. Three QV-eligible hard facts (specific dates, named firm Microsoft, named system Azure) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains multiple elements:
1. Generic cyber resilience language
2. A materiality assessment ("not aware of any risks... that have materially affected...")
3. Generic risk language about potential impacts
4. A specific incident description (February and April 2025, Microsoft notified, Azure environment, nation-state threat actor)
5. Incident response actions

The key question is: what is the dominant category?

The paragraph has a materiality disclaimer (Strategy Integration) AND a specific incident narrative (Incident Disclosure). Let me apply the tiebreaker rules.

The materiality assessment takes up the middle portion. But then there's a substantial incident description with specific dates, named companies (Microsoft), named environment (Azure), and specific response actions. The incident narrative is detailed and specific.

Looking at the tiebreakers, the paragraph describes what happened with specific dates, threat actor type, systems involved, and response actions—that's a full incident narrative, not just a brief mention. The structure opens with generic language and a materiality conclusion, but then uses "For example..." to introduce a detailed incident account. The question is whether the materiality assessment is the main point or just framing for the incident disclosure. Strategy Integration since the materiality assessment frames the entire paragraph and the incident serves as illustration. Though the incident details are substantial with specific dates and response actions, the tiebreaker here is that the paragraph's main point is the materiality conclusion, not the incident narrative itself.

For specificity, I'm identifying three quantified-verifiable facts: the February and April 2025 dates, Microsoft as the named third party, and Azure environment as the specific system involved.

fact: February and April 2025

fact: Microsoft

fact: Azure environment


reasoning: The paragraph is about the persons filling cybersecurity leadership roles — the CTO's experience, background, and qualifications, plus the VP of Infrastructure and Security. This is squarely about who the people are, not what the program does. Specificity: CTO and VP of Infrastructure and Security are cybersecurity-specific titles (IS list), and '25 years of experience' is a specific number, but named roles don't count toward QV, leaving only one QV-eligible fact, so Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: About the CTO and VP of Infrastructure and Security - their responsibility, the CTO's experience (25 years), background. This is about the person, not the function.

Category: Management Role - the paragraph is about the CTO's qualifications, experience, and background.

Specific facts:
- CTO (cybersecurity-specific title) → named_role
- Vice President of Infrastructure and Security → named_role
- 25 years of experience → quantified

QV check: "over 25 years" (specific number) + CTO + VP of Infrastructure and Security. QV-eligible: 25 years of experience is a specific number. Named roles don't count toward QV. So only one QV-eligible fact → Firm-Specific.

The VP of Infrastructure and Security is a cybersecurity-specific title, but since named roles don't count for QV purposes, the only qualifying fact here is the 25 years of experience, making this Firm-Specific.

fact: CTO


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected 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 named frameworks, roles, dates, or other specific facts from the IS list are present — all language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: Mixed - mentions cybersecurity risks, a materiality assessment ("have not materially affected us, including our business strategy, results of operations or financial condition"), brief mention of past threats/breaches, and a cross-reference to Risk Factors.

Category: The materiality assessment is explicit - "have not materially affected us, including our business strategy, results of operations or financial condition." Per Rule 6, this is Strategy Integration. The cross-reference doesn't change that.

Specificity: No named frameworks, no specific dates, no named roles, no specific facts from the IS list. The materiality language is boilerplate. → Generic Boilerplate.


reasoning: The Board of Directors is the grammatical subject performing oversight of cybersecurity risks, receiving briefings, and retaining oversight over management's efforts — all hallmarks of Board Governance. No specific facts from the IS list are present: no cybersecurity-specific titles (only generic 'senior management' and 'senior executives'), no named frameworks, no named committees beyond the generic full Board, and 'at least annually' is a generic cadence.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity program's purpose, Board oversight of cyber risk, and briefing cadence. The Board is the primary actor for oversight, and management is described in relation to the Board's oversight structure.

Category: Board Governance - The Board is the grammatical subject for oversight, briefing cadence is described. Management is mentioned but subordinate to the board's oversight framing.

Specificity: Let me check for specific facts:
- "Board of Directors" - generic, NOT list
- "senior management" - generic
- "At least annually" - generic cadence
- No named roles (no CISO/CTO/CIO), no named frameworks, no specific dates, no named committees beyond the full Board

- No references to industry standards or information security frameworks, so this is generic boilerplate.


reasoning: The paragraph makes an explicit materiality assessment ('have not materially affected... business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration. The language is boilerplate with no firm-specific facts.


reasoning: The paragraph is entirely about the person filling the VP of MIS role — their expertise, committee memberships, tenure, and career history. This is the person, not the function. Two QV-eligible hard facts: specific date (since 2014) and specific duration (32-year tenure).

thinking:
Let me analyze this paragraph.

Content: Describes the VP of MIS - expertise, committee memberships, tenure, experience, responsibilities. This is about the person - their background, qualifications, tenure. Clear Management Role.

Specific facts:
- "VP of MIS" - cybersecurity-specific title? It's VP of Management Information Systems - this is an IT leadership role. Let me check... "VP of IT/Security" is on the IS list. VP of MIS is similar to VP of IT. I'll count it as a cybersecurity-specific title.
- "Risk Committee" - named non-generic committee ✓

- "Cybersecurity Committee" - named non-generic committee ✓
- "since 2014" - specific date ✓
- "32-year tenure" - specific number/duration ✓

So I've got two quantified-verifiable facts here: the 2014 start date and the 32-year tenure. That's enough to mark this as QV-eligible.

fact: VP of MIS

fact: Risk Committee

fact: Cybersecurity Committee

fact: since 2014

fact: 32-year tenure


reasoning: This sentence describes generic consequences of cybersecurity risks (system failures, supply threats, data compromise) without any substantive disclosure of processes, governance, incidents, or strategy. It is general risk language that could apply to any utility company.


reasoning: The paragraph describes internal cybersecurity processes—monitoring, security measures, system audits, and an incident response plan. The 'Director of Information Technology' is mentioned as attribution but the substantive content is about what the program does (person-vs-function test: remove the title and the paragraph still describes processes). 'Director of Information Technology' falls under the generic IT leadership NOT list ('Director of IT'), and all other content (monitoring, audits, incident response plan) consists of common practices with no named frameworks, tools, dates, or firm-specific details.

thinking:
Let me analyze this paragraph.

The paragraph is about monitoring cybersecurity incidents. The Director of Information Technology is mentioned as the subject performing actions - staying informed, implementing processes, overseeing monitoring. Then it describes the IT team's incident response plan.

Category: The paragraph mentions "Director of Information Technology" as the person doing things, but the content is primarily about processes - monitoring, security measures, audits, incident response plan. The Director of IT title is attribution, and the rest describes what the program does. Using the person-vs-function test: remove the Director of IT reference and it still describes processes. → Risk Management Process.

Wait - "Director of Information Technology" - is this a cybersecurity-specific title? Looking at the IS list: "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security, HSE Director overseeing cybersecurity." "Director of Information Technology" is close to "Director of IT Security" but not exactly. The NOT list says "Head of IT", "IT Manager", "Director of IT" are generic IT titles.

So "Director of Information Technology" maps to the generic "Director of IT" on the NOT list, meaning this isn't a specialized cybersecurity role. The paragraph contains no specific frameworks, tools, dates, or numbers—just standard practices like monitoring, audits, and incident response planning. This is generic boilerplate content.


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any risks from cybersecurity threats that have materially affected the Company, including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration. The cross-reference to Risk Factors and forward-looking caveat are noise. No specific facts remain after filtering — boilerplate materiality language.


reasoning: This is a standard materiality disclaimer assessing whether cybersecurity risks have materially affected the company's business strategy, results of operations, or financial condition — which per Rule 6 is Strategy Integration. The language is boilerplate with no firm-specific details.


reasoning: The board of directors is the grammatical subject throughout, describing its oversight of cybersecurity risk, planned delegation to the Audit Committee, and review cadence — all classic Board Governance content. The paragraph references the CIO (a cybersecurity-specific title on the IS list) and 'ACT' (a named internal team with a distinguishing abbreviation), yielding Firm-Specific. Neither fact is QV-eligible (no dates, dollar amounts, headcounts, named third-party firms, or named tools), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The board of directors oversees risk management including cybersecurity. Mentions CIO reports, key performance indicators, plans to delegate to Audit Committee, and ACT team.

Category: Board Governance - the board is the grammatical subject throughout, describing board oversight of cyber risk.

Specificity: Let me check for specific facts:
- CIO is mentioned (cybersecurity-specific title? CIO is on the IS list)
- "ACT" - this appears to be a named internal team/program with a unique identifier
- "Audit Committee" - generic, on the NOT list
- "annual basis", "periodic basis" - generic cadences

- Key performance indicators - generic concept

IS facts: CIO (cybersecurity-specific title), ACT (named team/program with abbreviation). That's two IS facts, but neither qualifies as QV-eligible since CIO is a named role and ACT is a named internal program. So this lands as Firm-Specific with at least one IS fact.

fact: CIO reports on enterprise risk profile

fact: ACT (named internal team acronym)


reasoning: The paragraph describes an actual cybersecurity incident — unauthorized data extraction discovered in December 2022, response actions (containment, investigation), and a no-material-damage conclusion. The incident narrative is dominant over the brief materiality statement. Only one hard verifiable fact (December 2022); all third parties are unnamed, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity incident from December 2022 - unauthorized data extraction, response actions taken, and materiality assessment.

Category: This describes what happened in an actual incident - detection, investigation, containment, engagement of experts. The last sentence is a materiality assessment, but the dominant content is the incident narrative. → Incident Disclosure

Specificity:
- "December 2022" = specific date (month+year) → 1 hard fact
- "third-party information technology cyber security and forensics experts" → unnamed, NOT list
- "special legal counsel" → unnamed
- No named firms, no named tools, no dollar amounts, no headcounts

- December 2022 is the only verifiable fact, which meets the threshold for Firm-Specific classification, so this doesn't qualify as QV.

fact: December 2022


reasoning: The paragraph's central topic is oversight of third-party providers' cybersecurity posture, including due diligence and periodic reassessments, making Third-Party Risk the dominant category. No named frameworks, specific roles, dates, tools, or firm-specific facts are present—'third-party risk management program,' 'due diligence,' and 'periodic re-assessments' are all generic terms that could apply to any company.

thinking:
Classify this paragraph.

Content: Describes a third-party risk management program - due diligence, assessment of providers' cybersecurity posture, periodic re-assessments. Central topic is oversight of external parties.

Category: Third-Party Risk - vendor oversight is the central topic.

Specificity: No named frameworks, no named roles, no specific dates, no named firms/tools. "third-party risk management program" is generic. "due diligence", "periodic re-assessments" are generic practices. → Generic Boilerplate.


reasoning: The board of directors and Audit Committee are the grammatical subjects performing oversight of cybersecurity risk, making this Board Governance. The paragraph includes a firm-specific fact — a named certification (CERT Certificate in Cybersecurity Oversight) held by a board member — which elevates it beyond generic boilerplate. However, only one hard verifiable fact is present (the named certification), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content category: The board and Audit Committee are the grammatical subjects performing oversight actions. This is about board/committee oversight of cybersecurity risks, briefing structure, and board member expertise (CERT Certificate). → Board Governance

Specificity analysis:
- "Audit Committee" — on the NOT list (generic governance)
- "CERT Certificate in Cybersecurity Oversight" — this is a named certification held by a board member, which is a specific fact
- "all of the board's independent directors" — this is a firm-specific compositional detail about the committee
- "independent auditor" — generic, unnamed

- The CERT Certificate is the only hard verifiable fact here; I don't see specific dates, dollar amounts, headcounts, named firms, or other tools mentioned, so this doesn't meet the QV threshold. With just one named certification, this falls into Firm-Specific (3).

fact: CERT Certificate in Cybersecurity Oversight held by one board member


reasoning: Management is the grammatical subject throughout, describing its responsibilities for overseeing cybersecurity risks, evaluating posture, reporting to the board, and coordinating with external parties. This mirrors the codebook example 'Management is responsible for assessing and managing cybersecurity risks' → Management Role. No cybersecurity-specific titles (CISO, CIO, etc.), no named frameworks, no firm-specific facts — 'management,' 'board of directors,' 'vendors,' and 'CROs' are all generic. Generic Boilerplate applies.

thinking:
Let me analyze this paragraph.

Content: Management oversees cybersecurity risks, reports to board, coordinates with CROs/vendors/partners.

Category: The grammatical subject is "management" throughout. It describes what management does - oversees risks, evaluates posture, reports to board, coordinates with third parties. This is about management's role and responsibilities. But applying the person-vs-function test: there's no specific person, no credentials, no background. It describes functions/activities management performs. However, the grammatical subject is management and it's describing their role/responsibilities.

Actually, looking more carefully - this describes what management does (oversees, evaluates, reports, coordinates).

The issue is that "management" is too generic per the exclusion list - there's no named CISO or specific cybersecurity role. The paragraph focuses on oversight activities and mentions CROs, which could be Chief Risk Officers or Contract Research Organizations, but the context is still unclear.

The real question is whether this is about management's functional responsibilities or the management role itself. The content describes processes like evaluating cybersecurity posture, reporting to the board, and coordinating with vendors. When I apply the person-versus-function test, removing the role holder still leaves coherent processes, which suggests this leans toward Risk Management Process rather than Management Role. Since there's no specific person and the emphasis is on what gets done rather than who does it, I'm leaning toward categorizing this as a process rather than a role.

Looking at the specificity markers: "management" and "board of directors" are both generic terms, "CROs" is ambiguous (likely Chief Risk Officers, which isn't a cybersecurity-specific title), and "vendors, partners, and other third parties" are vague references. There are no named frameworks, specific dates, or concrete facts. This points to generic boilerplate language without substantive detail.


reasoning: The paragraph describes an actual cybersecurity incident: what happened (zero-day exploit of Fortra's GoAnywhere system), when (fiscal year 2023), what data was affected (PHI and PII), and response actions (engaged outside experts, provided notifications to State AGs). This is a detailed incident narrative. Specificity is Quantified-Verifiable with three QV-eligible hard facts: a specific date (fiscal year 2023), a named third-party firm (Fortra, LLC), and a named product/system (GoAnywhere MFTaaS).

thinking:
Let me analyze this paragraph from PFHO's 10-K filing.

Content: Describes a specific cybersecurity incident involving third-party vendor Fortra, LLC and their GoAnywhere MFTaaS system. Details the nature of the breach (zero-day vulnerability), scope (PHI and PII affected), and response actions.

Category: This is describing what happened in a cybersecurity incident - the timeline, the vendor involved, the vulnerability exploited, the data affected, and the response. This is Incident Disclosure.

Specificity: Let me count hard verifiable facts:
- "fiscal year 2023" - specific date

- "Fortra, LLC" - named third-party firm
- "GoAnywhere" - named product/system
- "zero-day vulnerability" - standard incident language
- "HIPAA" - named standard (but not the primary purpose)
- "State Attorneys General" - generic

I've got three concrete, verifiable facts here: the fiscal year 2023 date, the named vendor Fortra LLC, and the specific product GoAnywhere. That meets the threshold for QV-eligible.

fact: fiscal year 2023

fact: Fortra, LLC

fact: GoAnywhere managed file transfer as a service system (MFTaaS)

fact: HIPAA (Health Insurance Portability and Accountability Act)

fact: zero-day vulnerability exploit


reasoning: The paragraph describes the company's internal IT infrastructure, security controls (firewall, 2FA), backup procedures, and monitoring of third-party providers — all internal risk management processes. The third-party monitoring at the end is a component of the internal program, not the central topic. Two hard verifiable facts: the named ERP product (Great Plains) and a specific data quantity (~1 TB).

thinking:
Let me analyze this paragraph from IVFH's 10-K Item 1C filing.

Content: Describes their IT infrastructure - cloud solutions, standalone servers, ERP system (Great Plains), servers for specific subsidiaries, firewall/2FA protection, backup procedures, and monitoring of third-party providers.

Category: This is primarily about the company's own internal IT infrastructure and security processes. It describes their servers, protection measures (firewall, 2FA), backup procedures, and monitoring. There's a third-party component at the end but it's subordinate to the overall description of internal processes. → Risk Management Process

Specific facts:
- Named system: "Great Plains" (ERP program) - named product ✓

- Named subsidiaries mentioned are self-references, not verifiable external facts ✗
- Data volume of approximately one terabyte is quantified ✓
- Two-factor authentication and firewall are standard practices without specificity

So I'm identifying two hard verifiable facts here: Great Plains as a named product and the one terabyte data volume, which puts this in the Quantified-Verifiable category.

fact: Great Plains ERP program

fact: approximately one terabyte of data on file server


reasoning: The paragraph describes internal cybersecurity safeguards — multi-tiered backup protocols, immutable backups, encryption, and access controls. While the Advisor engages vendors to implement these, the central topic is the safeguards and data protection processes themselves, not vendor oversight. No named frameworks, tools, firms, dates, or other IS-list facts are present; the descriptions are generic practices applicable to any company.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity safeguards including multi-tiered backup protocols, immutable backups, encryption, access controls. This is about internal processes and tools for data protection.

The "Advisor and its affiliates" engaging vendors could suggest Third-Party Risk, but the paragraph quickly pivots to describing the safeguards themselves (backup protocols, immutable backups, encryption). The vendor engagement is just how these are procured - the central topic is the cybersecurity processes/safeguards.

Category: Risk Management Process - describes internal cybersecurity safeguards, backup protocols, encryption measures.

Specificity: No named frameworks, no named tools/products, no specific dates, no named firms, no specific numbers. "Multi-tiered backup protocols," "immutable backups," "encryption measures" are common practices. No IS-list items present.

This looks like generic boilerplate language around data protection practices.


reasoning: The paragraph identifies who manages cybersecurity (IT Lead) and describes their qualifications (5 years of experience) and support structure (external agency with ~15 years expertise). The primary content is about the person and their credentials, not the processes they run, making this Management Role. Two specific numeric durations (5 years, ~15 years) meet the QV threshold, though the second is approximate and attached to an unnamed entity, reducing confidence.

thinking:
Let me analyze this paragraph.

Content: Describes the IT Lead role, their experience, and an external agency assisting them. The paragraph is about who manages cybersecurity - the person and their qualifications.

Category: This is about the person (IT Lead) - their experience (5 years), and the external agency. But let me apply the person-vs-function test. The first sentence mentions "risk assessment and management processes are implemented and maintained by" - this is attribution. Then the next sentences describe the IT Lead's experience and the external agency's expertise. The primary content is about WHO manages cybersecurity and their qualifications, not WHAT processes they use.

This is a Management Role. The IT Lead title isn't on the cybersecurity-specific list, so it's more of a generic IT management position, though the 5 years of experience is a specific qualifier. The external agency is unnamed but brings about 15 years of expertise to the arrangement.

Both experience durations are quantified facts—the 5 years is exact and the 15 years is approximate but still a specific number—so this qualifies as Quantified-Verifiable overall.

But I'm second-guessing whether years of experience tied to an unnamed entity really counts as independently verifiable. The codebook lists specific dates, dollar amounts, headcounts, and percentages as QV-eligible, but I'm not sure if years of experience for an unnamed external agency meets that bar. I'm going back and forth on this. The 5 years is definitely a specific number, but the "about 15 years" for an unnamed agency feels harder to independently verify. Still, the codebook doesn't require the entity to be named, just that there are specific numbers present. I think I should stick with Quantified-Verifiable since I have two numerical facts, though I'm also noticing "IT Lead" isn't even a cybersecurity-specific title, which makes me wonder if it qualifies as firm-specific at all.

fact: IT Lead has 5 years of experience

fact: External agency with about 15 years of expertise in cybersecurity


reasoning: The paragraph's primary content is about management roles — the CISO's responsibilities, reporting line (CISO → CIO → executive management → Audit Committee), and the CISO's background in pharmaceutical and defense industries. While the opening clause mentions program activities ('identification, monitoring and management'), these are generic and subordinate to the management structure description. Applying the person-vs-function test: the paragraph is organized around who the people are and how they interact, not what the program does. Two cybersecurity-specific roles (CISO, CIO) qualify as IS-list facts for Firm-Specific, but no QV-eligible hard facts (no specific dates, headcounts, named firms, or certifications) are present.

thinking:
Let me analyze this paragraph.

The paragraph describes the CISO's role, reporting structure, and experience. Let me apply the person-vs-function test.

Content: CISO leads the program, reports to CIO, has experience in pharma and defense industries, meets with CIO, CIO updates executive management, CISO and CIO brief Audit Committee.

Person-vs-function test: The paragraph mentions the CISO's experience ("significant experience... pharmaceutical and defense industries") and reporting lines (CISO → CIO → executive management → Audit Committee). But it also describes what the program does ("day-to-day identification, monitoring and management").

The dominant content here is really about the management structure and who reports to whom, with only a generic description of what the program actually does. The specificity check shows the CISO and CIO titles are concrete, but the industry experience lacks named firms, and the meeting cadences are vague. This is primarily a Management Role classification.

Looking at the verifiable facts, I don't have the hard data needed for QV status—no dates, dollar amounts, headcounts, or named organizations. The CISO and CIO are just role titles, not quantifiable facts. But since there are IS facts present (the specific roles themselves), this falls into Firm-Specific rather than QV.

fact: Global Chief Information Security Officer (CISO)

fact: Global Chief Information Officer (CIO)