reasoning: Although the CISO is the grammatical subject for most sentences, the paragraph's communicative purpose is describing the board/committee oversight reporting chain — briefing cadence (annual meetings, quarterly reports), information flow from CISO → Audit Committee → full Board, and the Compliance Committee's involvement. The final sentence recenters the Audit Committee Chair reporting to the full Board, confirming the governance framing. CISO (cybersecurity-specific role) and Compliance Committee (non-generic committee) are firm-specific facts, but neither qualifies for QV, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes how the CISO interacts with board committees - meeting with Compliance Committee and Audit Committee, providing reports. The primary frame is about the reporting/briefing structure between CISO and board committees.

Who is the primary actor? The CISO is the grammatical subject throughout. But the content is about briefing cadence and oversight structure - which is governance. Let me think about this more carefully.

Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). But wait - the paragraph is really about the oversight structure and briefing cadence, which is Board Governance territory.

The CISO is clearly the grammatical subject performing the actions - meeting with committees, providing reports - which points to Management Role. But there's a shift at the end where the Audit Committee Chair reports to the Board, introducing a governance element. The real substance here isn't about the CISO's qualifications or background, it's about how information flows through the organization - from CISO to committees to board. The CISO is grammatically doing the reporting, which points toward Management Role, but the real substance here is about oversight structure and how the board stays informed—the briefing cadence, the committees involved, all of it centers on board governance. The final sentence clinches it by highlighting the Audit Committee Chair reporting back to the Board. I'm going with Board Governance because the paragraph's communicative purpose is describing the information flow for oversight, not defining the CISO's role itself.

Now I'm checking what qualifies as firm-specific: CISO is a named cybersecurity role and the Compliance Committee is a named non-generic committee, so those count. The cadences like "quarterly" and "at least annually" are generic timing markers, not firm-specific. There are no dates, dollar amounts, headcounts, named firms, or tools mentioned. This lands as Firm-Specific with a count of 3.

fact: CISO (cybersecurity-specific title)

fact: Compliance Committee (non-generic named committee)


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal process for escalating and evaluating cybersecurity incidents for SEC disclosure materiality — this is an incident evaluation workflow, not a materiality conclusion itself. The CIO (cybersecurity-specific title) and the specific departmental composition of the Disclosure Committee (executive officers, CIO, Chief Ethics and Compliance Officer, finance and legal) provide firm-specific detail, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) reach the two-fact threshold.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes the Disclosure Committee's role in evaluating cybersecurity incidents for SEC disclosure materiality. The committee composition is detailed, and the CIO's role in presenting incidents is described.

Category analysis:
- This is about the process of evaluating incidents for materiality/disclosure - not about an actual incident
- The Disclosure Committee is the primary actor - but this isn't a board committee, it's a management-level committee
- It describes a process for materiality determination
- The CIO is mentioned as collaborating and presenting

This feels like it could be Risk Management Process (incident escalation process) or Management Role or Strategy Integration.

The paragraph is really focused on the mechanism for how incidents get escalated and evaluated for materiality by this management-level committee. While materiality evaluation is mentioned, the core topic is the escalation and evaluation process itself rather than any specific materiality conclusion. This points to Risk Management Process as the right category.

Looking at the specificity markers, the CIO is a cybersecurity-specific title that appears on the IS list, which makes this Firm-Specific. The team composition is also quite detailed—executive officers, the CIO, Chief Ethics and Compliance Officer, and specific departments from finance and legal. There are no quantitative values like dates, dollar amounts, or headcounts mentioned, so this doesn't qualify for QV.

This lands at Level 3: Firm-Specific.

fact: CIO collaborates on materiality evaluation and presents incidents to Disclosure Committee

fact: Disclosure Committee comprised of executive officers, CIO, Chief Ethics and Compliance Officer, and business leaders from finance and legal departments


content_category: Strategy Integration

reasoning: The paragraph is a materiality assessment of a cybersecurity incident's financial impact — it discusses EPS shortfall, direct costs, insurance retention, and a forward-looking materiality conclusion. It does not describe the incident itself (nature, scope, attack vector, response actions) but rather its business/financial consequences. Multiple hard verifiable dollar amounts and specific dates easily exceed the QV threshold.

thinking:
Let me analyze this paragraph carefully.

This paragraph discusses the financial/business impact of a cybersecurity incident. It includes a materiality assessment and detailed financial impact figures.

Content Category: Strategy Integration - This paragraph is primarily about the business/financial impact of a cybersecurity incident. It discusses materiality, earnings impact, dollar amounts, insurance. While it references an incident, it doesn't describe what happened (the nature of the attack, how it was detected, what systems were affected) — it focuses on the financial consequences.

Specificity: Let me count hard verifiable facts:
- "fourth quarter of 2023" - specific date
- "December 22" - specific date

- "December 29, 2023" - specific date
- "January 12, 2024" - specific date
- Multiple specific dollar amounts tied to EPS impact, direct expenses, insurance retention, and the shortfall between expected and actual earnings

Clearly this has well over 2 quantified-verifiable facts, so it qualifies as QV.

fact: fourth quarter of 2023 incident

fact: Form 8-K filed December 22, amended December 29, 2023 and January 12, 2024

fact: internal forecast of $1.00 adjusted EPS

type: quantified

fact: actual adjusted EPS of 69 cents

fact: 5 cent tax benefit

fact: 36 cent shortfall

fact: $11 million direct expenses

fact: $5 million insurance retention


category_confidence: medium

reasoning: The paragraph opens with board/CISO reporting relationships but the dominant content describes the Security Program itself — NIST framework alignment, layered controls, endpoint detection, malware protection, and a Security Operations Center. The CISO is mentioned as attribution ('responsible for the design and execution of the Security Program') with no credentials or background, making this a process description per the person-vs-function test. The Risk Committee (a non-generic committee on the IS list) and CISO title provide firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me break it down:

1. "The Risk Committee of the Board of Directors receives regular reports on cybersecurity from the CISO." - Board governance + CISO mention
2. "The CISO is responsible for the design and execution of the Security Program..." - Management role attribution leading into program description
3. "The CISO reports as necessary to executive management, the Risk Committee of the Board and the Board of Directors..." - Reporting lines
4. "The Risk Committee of the Board and the Board of Directors receive the results of the Company's annual cybersecurity risk assessment." - Board governance

5. The Security Program aligns with leading industry standards like NIST CSF, built on policies, standards and procedures - this establishes the framework foundation
6. The program implements layered controls including network and endpoint intrusion detection, malware protection, threat monitoring, and a Security Operations Center - these are the concrete technical mechanisms

The paragraph spans Board Governance, Management Role, and Risk Management Process. What's the dominant category?

Looking at the text volume: The first few sentences discuss the Risk Committee and CISO reporting relationships. Then the bulk of the paragraph shifts to describing the Security Program - framework alignment, policies, and the specific technical controls and monitoring infrastructure that make up the program.

The person-vs-function test: The early part focuses on people and their roles (Risk Committee, CISO), but the latter half emphasizes what the Security Program actually does and how it's structured.

I'm checking the specificity of the named entities here. The Risk Committee is a named non-generic committee that qualifies as a firm-level governance body. The CISO is a cybersecurity-specific title. NIST Cybersecurity Framework is a named standard. The Security Operations Center is a generic functional term, not a named product.

Given that the bulk of the paragraph describes the program's framework alignment, controls, and operational capabilities rather than governance structure or individual roles, the dominant category is Risk Management Process.

For the QV check, I don't have two hard verifiable facts—no dates, dollar amounts, headcounts, named third-party firms, or named products. The CISO and Risk Committee are firm-specific but not QV-eligible. So this lands at Firm-Specific (Level 3) based on the IS fact alone.

fact: CISO

fact: NIST Cybersecurity Framework

type: framework


reasoning: The CISO is the grammatical subject but the paragraph's dominant content describes the team's processes and methods — monitoring, scans, intelligence feeds, red/blue team testing, tabletop exercises. Applying the person-vs-function test: removing the role attributions, the paragraph still fully describes risk assessment methodology, so this is Risk Management Process. Specificity is Firm-Specific due to cybersecurity-specific titles (CISO, CTO) and the named team composition, but no two QV-eligible hard facts (no dates, dollar amounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: The CISO, in coordination with CTO, CFO, CAO, legal team, and third-party providers (named as "Cybersecurity Risk Management Team"), is responsible for identifying/assessing/managing cyber threats. Then describes methods: manual/automated tools, scans, external intelligence feeds, threat assessments, reports/services, red/blue team testing, tabletop exercises.

Category: The CISO is the grammatical subject, but the paragraph quickly pivots to describing what the team does - the processes, methods, tools. The person-vs-function test: remove the CISO attribution and the paragraph still describes processes. This is Risk Management Process.

Now I'm checking which roles are cybersecurity-specific versus generic C-suite positions. The CISO and CTO are clearly cybersecurity-focused, so they'd qualify for the list. But the CFO and CAO are general corporate roles, which wouldn't meet that threshold. The "Cybersecurity Risk Management Team" itself is a named internal program, which is worth noting.

Looking at verifiability, I don't see concrete facts like dates, dollar amounts, headcounts, or named external firms—just role titles. That means this doesn't meet the QV standard. But the firm-specific roles (CISO and CTO) do push this toward being Firm-Specific overall.

fact: Chief Information Security Officer (CISO)

fact: Chief Technology Officer (CTO)

fact: Named team composition: CISO, CTO, CFO, CAO, legal team, third-party providers as 'Cybersecurity Risk Management Team'


reasoning: Although the paragraph opens by naming the CFO as responsible for the cybersecurity program, the vast majority of the content describes internal processes: safeguards, third-party IT assessments, ISO 27001 alignment, incident response plan, ISMS oversight, and security awareness training. Applying the person-vs-function test, removing the CFO attribution leaves a fully coherent process description, so this is Risk Management Process. CFO is on the NOT list (generic C-suite), and no other IS-list facts are present; ISO 27001 is named as a standard (alignment, not certification held), yielding Sector-Adapted.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics. Let me identify the dominant one:

1. It starts with "Disclosure of Management's Responsibility" and names the CFO as primarily responsible for overseeing the Cybersecurity Risk Management Program.
2. Then it describes protocols, policies, tools, safeguards.
3. Third-party annual assessment of IT controls.
4. ISO 27001 alignment.
5. Incident response plan.
6. External consultant for ISMS.
7. Security awareness training.

The bulk of the paragraph is about the company's internal cybersecurity processes - risk mitigation tools, safeguards, third-party assessments, ISO 27001 alignment, incident response plan, ISMS, training. The CFO mention is attribution at the start. Using the person-vs-function test: remove the CFO mention and the paragraph still describes substantive processes. So this is **Risk Management Process**.

Now I'm checking the specificity of the facts mentioned. The CFO is generic C-suite, so that doesn't count. ISO 27001 is named as a framework they're aligning with rather than claiming certification. The ISMS process, third-party annual reviews, and incident response plan are all generic program names without specific details. There's a cross-reference to Item 10 but that's not a concrete fact about their actual practices. So this lands as Sector-Adapted due to the ISO 27001 reference, but otherwise lacks the specificity that would push it higher.

fact: ISO 27001 alignment


reasoning: The paragraph describes the company's internal cybersecurity assessment processes — risk assessments, audits, penetration testing, a risk register, risk scoring, and remediation planning. Vendors are mentioned as one component serving the company's own program, not as a central topic. No named frameworks, tools, firms, roles, dates, or quantified facts appear; all practices described (penetration testing, risk register, remediation plans) are common/generic.

thinking:
Classify this paragraph.

Content: Describes internal assessment processes - penetration testing, risk assessments, audits, risk register, risk scoring, remediation plans. Vendors mentioned as part of internal assessment process.

Category: Risk Management Process - describes the company's own internal processes for assessment and risk management.

Specificity: Let me check for specific facts:
- No named frameworks
- No named roles (CISO, etc.)
- No named tools/products
- No named firms
- No specific dates
- No numbers
- "security and technology vendors" - unnamed, generic
- "penetration testing" - common practice, NOT list

- "risk register" - generic program name
- "risk assessments and audits" - common practices

No IS-list facts. No named standards. → Generic Boilerplate (1)


reasoning: The paragraph describes the post-incident reporting process: SIRT prepares reports for the Information Security Governance Committee, and the Information Security Team provides updates to the Audit Committee and Board. The grammatical subjects are operational teams (SIRT, Information Security Team), not the Board, and the content describes process flows rather than board oversight activities. The named Information Security Governance Committee is a non-generic committee unique to this company, triggering Firm-Specific, but there are not two hard verifiable facts (no dates, amounts, named firms, or tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes SIRT preparing reports for Information Security Governance Committee, and Information Security Team providing updates to Audit Committee and Board.

Category: This describes internal processes (incident reporting, post-incident review) and also touches on board governance. The first part is about the SIRT's reporting process (Risk Management Process). The second part describes updates to Audit Committee and Board (Board Governance). The dominant content seems to be about the process - the SIRT report preparation and the reporting flow. But the second sentence describes board-level reporting.

Actually, let me re-read. The paragraph describes: (1) SIRT prepares a report for Information Security Governance Committee after investigations, (2) what the report includes, (3) Information Security Team provides Audit Committee and Board with updates.

The core here is the incident response reporting process - SIRT and the Information Security Team are the ones driving the action, with the Board and Audit Committee in a receiving role. Even though board updates are mentioned, the grammatical focus is on what the operational teams are doing, which makes this primarily about Risk Management Process rather than Board Governance.

Looking at the specificity markers: the Information Security Governance Committee is a named, non-generic committee that's firm-specific. SIRT and Information Security Team are also named internal teams. There are no dates, dollar amounts, headcounts, or third-party references - just the organizational structure itself. That puts this at Firm-Specific (3) for specificity, and it's not QV since there's only one type of hard fact.

fact: SIRT (Security Incident Response Team)

fact: Information Security Team


reasoning: The paragraph describes how the company's Cybersecurity Team engages third-party vendors to deliver security services (endpoint security, SOC, threat detection) as components of its own internal program. Per Rule 3, third parties serving the company's internal processes are Risk Management Process, not Third-Party Risk—no requirements are imposed ON vendors; rather, vendors provide services TO the company. Membership in the named Oil and Natural Gas Information and Analysis Center is a firm-specific fact (named external organization), yielding Firm-Specific. Only one QV-eligible fact (named firm/organization), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes third-party vendor engagements for cybersecurity services and membership in an industry information sharing center.

Category: The central topic is oversight/use of external parties for cybersecurity. But is this Third-Party Risk or Risk Management Process? The paragraph describes how the company uses third-party vendors as part of its own security program - endpoint security, SOC management, threat detection. These third parties are serving the company's internal processes. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." But also, the vendors here are providing ongoing services, not just assessments.

Actually, looking at Rule 3 again, the distinction is clearer: when third parties are one component of the company's internal program, that's Risk Management Process. When vendor oversight itself is the central focus, that's Third-Party Risk. Here, the paragraph is really about the company's security program that happens to leverage external vendors for services like endpoint protection and SOC management. The emphasis is on what the company receives, not on how it manages vendor compliance or security posture. There are no requirements being imposed on the vendors themselves - they're just providing services to the company.

→ Risk Management Process

Specificity: "Cybersecurity Team" is a named team but generic enough.

Now looking at the next part: "Oil and Natural Gas Information and Analysis Center" is a specific named organization (ONG-ISAC), which counts as a firm-specific fact. There are no named frameworks like NIST or ISO, no specific dates, dollar amounts, headcounts, or named third-party firms or tools. Since ONG-ISAC membership is just one firm-specific fact and I need two for QV eligibility, this falls under Firm-Specific.

fact: Member of the Oil and Natural Gas Information and Analysis Center


content_category: Board Governance

reasoning: The paragraph's primary content is about the Audit Committee receiving cybersecurity briefings and its composition linking to the Cybersecurity Executive Committee — board-level oversight structure is the frame. The CISO is mentioned as the person delivering briefings (attribution), not as the primary subject. The Cybersecurity Executive Committee is a named non-generic committee (IS list), and CISO is a cybersecurity-specific title, yielding Firm-Specific. No QV-eligible hard facts reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

The paragraph discusses the CISO briefing the Audit Committee on cybersecurity matters, and notes the committee composition. The primary actor shifts - first sentence has CISO as subject briefing the Audit Committee, second sentence describes committee composition.

Category: The paragraph is about board-level oversight - the Audit Committee receiving briefings. The CISO is mentioned as the person doing the briefing, but the focus is on the committee receiving information. The second sentence is about committee composition. This is Board Governance - the Audit Committee's oversight role is the frame.

Wait - let me reconsider. "CISO annually briefs the Company's Audit Committee" - the CISO is the grammatical subject. But the content is about the committee receiving briefings.

Looking at this more carefully, the CISO serves as the primary actor delivering information to the Audit Committee, while the second sentence establishes the committee's structure and its connection to the Cybersecurity Executive Committee. The tiebreaker here is that the CISO's reporting function is the main focus, even though board oversight is present - this points toward Management Role rather than Board Governance.

Wait, I need to reconsider. The substantive content really centers on the Audit Committee's composition and how it relates to the Cybersecurity Executive Committee, not on what the CISO does. The board committee structure itself is what's being described. This is Board Governance.

For specificity: CISO is cybersecurity-specific, and the Cybersecurity Executive Committee is a named committee - both qualify. The Audit Committee is generic, so it doesn't. No quantifiable facts present, so this isn't QV-eligible. This is firm-specific content given the named committees and role.

fact: CISO annually briefs the Audit Committee

fact: Cybersecurity Executive Committee


reasoning: The Board and Audit Committee are the primary grammatical subjects throughout, describing their oversight of cybersecurity risk and the briefings they receive. The CISO and CIIO are mentioned as reporting to the committee, making this Board Governance rather than Management Role. Two cybersecurity-specific titles (CISO, CIIO) place this at Firm-Specific, but these named roles do not count toward QV; no dates, dollar amounts, headcounts, or named third-party firms are present.

thinking:
Let me analyze this paragraph.

Content: Board of Directors monitors risks, Audit Committee has principal responsibility for cybersecurity oversight, CISO and CIIO provide reports to Audit Committee, briefing topics listed.

Category: The grammatical subject is the Board and Audit Committee throughout. The CISO/CIIO are mentioned as reporting TO the committee. This is Board Governance.

Specificity:
- CISO = cybersecurity-specific title ✓ (IS list)
- CIIO = "Chief Information and Innovation Officer" - this is a specific title, similar to CIO ✓
- Audit Committee = NOT list (generic)

- "regular reports" = generic cadence, NOT list
- The briefing topics are described but are general practices

So the IS facts here are the named cybersecurity-specific titles—CISO and CIIO—but there's no quantifiable data like dates, dollar amounts, or headcounts, so this doesn't meet QV criteria. The firm-specific element is really just those two specialized roles.

fact: Chief Information and Innovation Officer (CIIO)


content_category: Management Role

reasoning: The paragraph describes the TRCC, a management-level governance committee (sub-committee of the ERC), including its composition, chair appointment process, membership (including CISO), and oversight responsibilities. The codebook explicitly includes 'management committees responsible for cybersecurity' under Management Role. The primary content is organizational structure — who sits on the committee, how the chair is appointed, and the committee's governance mandate — rather than specific risk management processes or tools. Multiple named non-generic committees (TRCC, ERC) and a cybersecurity-specific role (CISO) qualify as IS-list facts for Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms) are present.

thinking:
Let me analyze this paragraph.

Content: Describes TRCC (a management risk governance committee), its composition, chair appointment, members including CISO, responsibilities for oversight of tech/cyber risk management practices.

Category: This is about a management committee structure. The TRCC is a management-level committee (sub-committee of ERC), not a board committee. It describes the committee's composition and responsibilities. This is Management Role - it's about the organizational structure of who manages cybersecurity at the management level, including reporting lines and committee structure.

Wait - let me reconsider. The paragraph describes a management committee's oversight role. It's about the TRCC committee structure and what it does.

I'm weighing whether this is primarily about the committee's structure and composition versus its oversight functions. The codebook defines Management Role as covering management committees responsible for cybersecurity, and this paragraph clearly fits that - it's describing TRCC's governance role, membership, and oversight responsibilities for technology and cybersecurity risk management. The dominant content here is the organizational structure and governance responsibilities at the management level.

Looking at the specific facts: TRCC and ERC are named non-generic committees, CISO is a cybersecurity-specific title, and there's a Head of Enterprise Risk Management role mentioned. These are all firm-specific details but don't meet the quantifiable verification threshold since they're organizational roles rather than measurable metrics. So this classifies as Firm-Specific without qualifying for QV.

fact: TRCC (Technology and cybersecurity risk governance committee)

fact: ERC (Enterprise Risk Committee)

fact: CISO is a member of the TRCC

fact: Chair appointed by head of Enterprise Risk Management


reasoning: The CISO and TRCC members are the grammatical subjects, and the paragraph describes their management responsibilities—monitoring prevention, detection, mitigation, and remediation of incidents through their participation in processes. While it references processes, the primary communicative purpose is defining what these management roles do (their scope of responsibility), not detailing the processes themselves. The TRCC is a named non-generic committee and CISO is a cybersecurity-specific title, both on the IS list, yielding Firm-Specific. Neither qualifies as QV-eligible.

thinking:
Let me analyze this paragraph.

The paragraph describes what the CISO and TRCC members do - they monitor prevention, detection, mitigation, and remediation through management of cybersecurity risk management processes including incident response plan.

Category: This is about what the CISO and TRCC do in terms of monitoring and managing processes. The grammatical subjects are "The CISO and members of the TRCC." But the content is about their participation in processes - it's describing the function, not the person. However, the CISO is the grammatical subject performing actions. Let me apply the person-vs-function test: if I remove "The CISO and members of the TRCC," the paragraph describes monitoring prevention, detection, mitigation, remediation through cybersecurity risk management processes and incident response plan.

So the core is really about the processes themselves. But the paragraph frames it as what the CISO and TRCC actively do - they're overseeing and participating in these risk management activities. It's borderline between describing the role's responsibilities versus the processes, but since it emphasizes the management team's monitoring and participation, I'm leaning toward this being about the management function rather than just process description. I'm checking the specificity of each item: CISO is a cybersecurity-specific role, and TRCC is a named committee—both are firm-specific facts but neither qualifies as a quantifiable value. This falls under Firm-Specific category.

fact: TRCC (Technology Risk and Cyber Committee)


reasoning: The paragraph describes how cybersecurity risk is integrated into the enterprise-wide risk management process, including annual reviews, a named committee, and its operating cadence — all internal process descriptions. The VP of IT & Digitization is mentioned as attribution for who leads the committee, but the substantive content is about the function, not the person. The Cybersecurity Strategy Committee is a named non-generic committee (Firm-Specific), but there is only one IS-list fact, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes ERM integration, annual review, a named committee (Cybersecurity Strategy Committee), led by VP of IT & Digitization, cross-functional team, regular meetings, updates to management.

Category: This is about internal cybersecurity processes - risk management integration, strategy committee, how they operate. The VP of IT & Digitization is mentioned as attribution for who leads it. The paragraph is about the function/process, not the person. → Risk Management Process

Specific facts:
- "Cybersecurity Strategy Committee" — named non-generic committee ✓
- "Vice President of IT & Digitization" — this is more of an IT title... but it's specific enough. Actually, is "VP of IT & Digitization" a cybersecurity-specific title? The IS list says "VP of IT/Security". "VP of IT & Digitization" is close but not exactly cybersecurity-specific. Hmm, it's a VP of IT role. The NOT list says "Head of IT", "IT Manager", "Director of IT" are generic IT leadership, not cybersecurity-specific. "VP of IT & Digitization" seems more like general IT leadership than cybersecurity-specific, so I'll treat it as NOT specific.

The named committee itself is firm-specific though. For the QV check, I've got one hard fact here — the committee name — but no dates, dollar amounts, headcounts, named firms, or tools.

So this doesn't meet QV standards. The specificity level is Firm-Specific at a 3.

fact: Cybersecurity Strategy Committee


reasoning: The paragraph opens with a brief board/Audit Committee attribution but its primary communicative purpose is describing the company's cybersecurity risk management program — policies, standards, processes, and resource investment. No named frameworks, cybersecurity-specific roles, dates, tools, or other specific facts appear; all language is generic and interchangeable across filings.

thinking:
Let me analyze this paragraph.

Content: This is an introductory/overview paragraph that touches on board oversight, risk management program, and resource investment. The dominant purpose is introducing the company's overall cybersecurity posture - it mentions board/Audit Committee oversight, policies and processes, and financial investment.

Category: This spans multiple categories. The first sentence mentions board oversight (Board Governance), then describes policies/processes (Risk Management Process), then mentions financial investment (Strategy Integration). The dominant theme is an overview/introduction to the cybersecurity program. The board mention is brief attribution. The bulk describes the program's existence and resources devoted to it. I'd say Risk Management Process is dominant - describing their program, policies, standards, processes for managing cyber risks.

Now I'm checking the specificity. The paragraph uses generic terms like "Board" and "Audit Committee" without naming individuals, references general cybersecurity terminology like TTPs, and contains no frameworks, specific roles, dates, numbers, or named tools. This is clearly generic boilerplate language.


reasoning: The entire paragraph describes multiple management personnel — their titles, years of experience, educational backgrounds, and career histories. This is squarely about the people (person-vs-function test), not about processes or programs. Multiple specific years of experience (20, 20, 25+, 20+) constitute two or more QV-eligible hard facts, pushing specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes multiple management roles and their qualifications/experience. SVP, VP of Information Technology, Director of Information Security & Infrastructure, General Counsel - all with their backgrounds, years of experience, and degrees.

Category: Management Role - the paragraph is entirely about the people, their credentials, experience, and backgrounds.

Specificity analysis:
- "SVP" - generic title, not cybersecurity-specific
- "VP of Information Technology" - this is "Head of IT" type, on the NOT list as generic IT leadership
- "Director of Information Security & Infrastructure" - this is a cybersecurity-specific title (Director of IT Security equivalent)

- "General Counsel" - on the NOT list as generic C-suite
- Years of experience are specific numbers, but degrees without named universities fall into the NOT list category

So the only cybersecurity-specific credential here is the Director of Information Security & Infrastructure role, while the VP of IT and General Counsel are too generic to count as meaningful IS facts. of experience as a specific number ('17 years', 'over 20 years')" — yes, these count.

So we have multiple QV-eligible facts (specific years of experience for multiple people). That's easily 2+.

Also "Director of Information Security & Infrastructure" is a named role (IS fact).

Specificity: Quantified-Verifiable (multiple specific years of experience counts as 2+ hard facts).

fact: VP of Information Technology

fact: SVP with over 20 years in engineering, operations, and IT

fact: VP of IT with 20 years in IT and information security

fact: Director of IS&I with over 25 years in IT

fact: General Counsel with over 20 years managing risks


reasoning: The paragraph describes the company's managed security services arrangement with a retained outside firm — this is a component of the company's own risk management program (per Rule 3: external parties hired to serve the company → Risk Management Process, not Third-Party Risk). The firm's qualifications, certifications, and framework expertise describe the capabilities supporting the company's security posture. Multiple QV-eligible hard facts are present: 'more than 20 years of experience' (quantified duration) plus named certifications (CRISC, GSEC, GCIA) — well exceeding the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes an outside cybersecurity firm retained for managed security services, reporting to VP of IT. Describes the firm's professionals' experience, certifications, and framework knowledge.

Category: This is about a third-party firm providing managed security services. But it's describing the qualifications of the external firm's professionals. The central topic is the external party providing cybersecurity services. However, per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." This firm is providing managed security services to the company - they serve the company's internal security function.

Actually, re-reading Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." This is a managed security service provider - they're part of the company's internal security operations.

The paragraph focuses on the firm's qualifications and credentials rather than the company's own processes, but since the company has engaged this external firm as part of its security program, this describes the capabilities supporting the company's security function—similar to how an external assessor hired to test the company would fall under Risk Management Process. Actually, wait. Let me reconsider. The paragraph describes:
1. Retained an outside cybersecurity firm for managed security services (reporting to VP of IT)
2. The firm's professionals' experience and certifications
3. The firm's framework expertise

This is describing a component of the company's risk management - they use a managed security service. The third-party firm is serving the company's internal security needs. Per Rule 3, this fits Risk Management Process.

But there's also a Management Role angle - "reports to our VP of IT." VP of IT is mentioned. But that's incidental.

I'll go with Risk Management Process - the paragraph describes how the company manages cybersecurity through a retained external firm.

Now I'm identifying the QV-eligible facts: the firm's professionals have more than 20 years of experience, plus they hold CRISC, GSEC, and GCIA certifications. These are all verifiable facts about the third-party firm, even though they're not the company's own employees. The frameworks mentioned - ISO 27000, NIST, HITRUST, ISC2, ITIL, COBIT - are named and verifiable. The "outside cybersecurity firm" itself is unnamed so it doesn't count. So I'm looking at multiple QV-eligible facts here: the quantified experience, the three named certifications, and the frameworks.

fact: VP of IT (reporting line for the cybersecurity firm)

fact: More than 20 years of experience (firm's professionals)

fact: CRISC certification

fact: GSEC certification

fact: GCIA certification

fact: ISO 27000, NIST, HITRUST, ISC2, ITIL, COBIT frameworks


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of third-party service providers — due diligence assessments and contractual obligations imposed on vendors — making Third-Party Risk the dominant category. No named standards, frameworks, specific roles, dates, or firm-specific details are present; the language is entirely generic and could apply to any company.

thinking:
Classify this paragraph.

Content: About oversight of third-party service providers - due diligence, contractual obligations. Central topic is vendor oversight.

Category: Third-Party Risk

Specificity: No named standards, no firm-specific facts. "due diligence assessments" and "contractual obligations" are generic. → Generic Boilerplate


content_category: Incident Disclosure

reasoning: The paragraph primarily describes an actual cybersecurity incident — the February 2022 targeted cyber-attack, its operational impact (shutdown of systems for approximately three weeks), and response actions. While it includes a materiality conclusion and post-incident improvements (including adding a CISO), the dominant content is the incident narrative. Only one QV-eligible hard fact (February 2022 date); 'approximately three weeks' is a soft/approximate figure, and CISO/CSRM are IS-list facts but not QV-eligible, so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes a February 2022 cyber-attack, its operational impact (three weeks shutdown), response actions, materiality assessment, and post-incident improvements including adding a CISO.

Category: This is primarily about an actual cybersecurity incident - what happened, when, the impact, and response. The paragraph describes the event (targeted cyber-attack), operational impact (shut down systems, limited operations for ~3 weeks), and post-incident actions. There's a materiality statement ("do not expect to have a further material adverse impact") and post-incident improvements, but the dominant content is the incident narrative.

→ Incident Disclosure

Now I'm checking what facts here would qualify for verification. The February 2022 date is specific and verifiable, but most other details are either approximate or internal references like the CISO role and CSRM program that don't meet the hard fact threshold. So really just one concrete data point that would be QV-eligible.

Since there are multiple IS-list facts present—the date, the role, and the program name—this falls into the Firm-Specific category, even though it doesn't have enough hard verifiable facts to be Quantified-Verifiable.

fact: February 2022 (specific date of cyber-attack)

fact: CISO (Chief Information Security Officer) added to IS leadership

fact: CSRM program (named internal program with unique identifier)


reasoning: The paragraph contains an explicit materiality assessment ('has not detected a significant compromise... significant data loss or any material financial losses related to cybersecurity attacks'), which per Rule 6 makes it Strategy Integration even though it includes a cross-reference to Risk Factors and forward-looking risk language. No firm-specific facts from the IS list are present — 'TEC' is a company self-reference and the rest is boilerplate.

thinking:
Materiality assessment + cross-reference. The paragraph says "has not detected a significant compromise... significant data loss or any material financial losses related to cybersecurity attacks" — this is a materiality assessment. Per Rule 6, this is Strategy Integration.

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


reasoning: The Audit Committee is the organizational frame — cybersecurity is a recurring topic at its meetings, and the CTO/CISO report TO the committee. This is board-level oversight of cyber risk via briefing cadence. CISO and CTO are cybersecurity-specific titles on the IS list, making this Firm-Specific, but there are no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

The paragraph describes the Audit Committee receiving updates from the CTO and CISO about cybersecurity. The Audit Committee is the primary subject/frame - cybersecurity is a recurring topic at its meetings, and the CTO/CISO provide updates TO the committee.

Category: Board Governance - the Audit Committee's oversight is the frame, with CTO/CISO reporting to it.

Specific facts:
- CTO (cybersecurity-specific title) ✓
- CISO (cybersecurity-specific title) ✓
- "Executive Vice President and Chief Technology Officer" - named role

- These meetings occur multiple times annually, though the exact frequency isn't specified with precision

The CTO and CISO roles are firm-specific and appear on the IS list, making this Firm-Specific. There are no quantifiable metrics like dates, dollar amounts, headcounts, named external firms, tools, or certifications, so this doesn't qualify as QV.

fact: Chief Technology Officer (CTO)

fact: Chief Information Security Officer (CISO)


reasoning: The paragraph describes the company's internal approach to identifying, preventing, and mitigating cybersecurity threats, along with escalation controls — all internal process descriptions. No named frameworks, roles, tools, or firm-specific details are present; 'cross-functional approach' and 'controls and processes' are generic language applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity program elements — risk assessments, security team, external providers, training, incident response plan, SOC, and third-party risk management. All elements are generic common practices with no named frameworks, no cybersecurity-specific role titles, no named tools/firms, and no specific dates or numbers. 'Security Operations Center (SOC)' is a common industry term, not a firm-specific fact.

thinking:
Let me analyze this paragraph.

Content: Describes key elements of the cybersecurity risk management program - risk assessments, team, external providers, training, incident response plan, SOC, third-party risk management.

Category: This is clearly Risk Management Process - it describes the company's internal cybersecurity processes and program elements.

Specificity: Let me check for specific facts:
- "risk assessments" - common practice
- "a team comprised of IT personnel" - generic
- "external cybersecurity service providers" - unnamed
- "cybersecurity awareness training" - common practice
- "cybersecurity incident response plan" - generic program name

- "Security Operations Center (SOC)" - this is a generic term, not a named product/tool
- "third-party risk management process" - generic

No named frameworks, no named roles from the IS list, no specific dates, no named tools, no named firms. Everything here is standard industry terminology without any firm-specific details, so this falls into Generic Boilerplate.


reasoning: The Board and Audit Committee are the grammatical subjects performing cybersecurity oversight actions (delegates, oversees), making this clearly Board Governance. No specific facts from the IS list are present — 'Board' and 'Audit Committee' are both on the NOT list as generic governance terms.

thinking:
Classify this paragraph.

Board/committee oversight is the primary topic. The Board delegates to Audit Committee, and the Audit Committee oversees the program.

Content category: Board Governance - the board and audit committee are the grammatical subjects performing oversight.

Specificity: "Board" and "Audit Committee" are both on the NOT list (generic governance). No cybersecurity-specific roles, no named frameworks, no dates, no specific facts. → Generic Boilerplate.


reasoning: The paragraph describes consequences of an actual ransomware incident — potential exfiltration of personal information and notification actions taken — making it Incident Disclosure. However, it contains no specific dates, named firms, headcounts, or other facts from the IS list; 'ransomware actors,' 'personal information,' and 'notifications to individuals and regulators' are all standard incident language, yielding Generic Boilerplate.

thinking:
Classify this paragraph about MKS Inc's cybersecurity disclosure.

This describes aftermath of a ransomware incident - data exfiltration, notifications to individuals and regulators. This is about what happened in an incident (scope, response actions).

Content category: Incident Disclosure - describes exfiltration of personal information and notification actions taken in response to an actual incident.

Specific facts: Let me check. "ransomware actors" - standard incident language. "personal information" - vague. "notifications to individuals and to regulators" - standard response. No dates, no named firms, no specific numbers.

Specificity: Generic Boilerplate - no named entities, dates, tools, or firm-specific facts.


reasoning: The paragraph contains an explicit materiality assessment ('no cybersecurity events have occurred that have materially affected the Company or its business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. It also mentions continued investment in cybersecurity but with no specific amounts, frameworks, or firm-specific facts — all language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: Materiality assessment ("no cybersecurity events have materially affected"), investment mention, cross-reference to Risk Factors.

Category: Strategy Integration - contains explicit materiality assessment per Rule 6.

Specificity: No named standards, no firm-specific facts from the IS list. The materiality language is boilerplate. → Generic Boilerplate.


reasoning: The paragraph describes generic incident response process steps (containment, remediation, recovery) as part of the company's cybersecurity program, not an actual incident. These are internal IR planning activities with no named frameworks, tools, roles, dates, or firm-specific details.

thinking:
Classify this paragraph from TTM Technologies' 10-K Item 1C filing.

This describes incident response steps: containment, implementing solutions, recovery. These are internal cybersecurity processes - specifically incident response planning steps. No actual incident is described; these are process descriptions.

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


reasoning: The paragraph is framed by the board and audit committee as the primary actors overseeing cybersecurity risk, with the audit committee's charter, meeting cadence, and oversight structure as the central topic. The contracted CTO and Head of Internal Audit credentials are subordinate details supporting how the board discharges its oversight. Multiple QV-eligible hard facts exist: specific years of experience for two individuals (15 years, 9 years, 30 years, 20 years).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Board/audit committee oversight of cybersecurity
2. Management roles (contracted CTO, Head of Internal Audit)
3. Third-party information security service provider
4. Credentials/experience of the contracted CTO and Head of Internal Audit

Let me determine the dominant category. The paragraph starts with board oversight, moves to audit committee meetings, then discusses the management team and third-party provider, and ends with credentials of two individuals.

The board/audit committee is the subject for the first few sentences. Then it shifts to describing the management structure and third-party reliance, and finally the qualifications of two people.

Looking at the distribution, the audit committee's oversight role frames the opening, but the paragraph dedicates substantial space to detailing the contracted CTO and Head of Internal Audit's qualifications. I'm weighing whether the governance structure or the personnel credentials carry more weight here—the management team's experience seems to be presented as evidence supporting the board's oversight approach.

I'm identifying the specific facts that qualify: the CTO title appears on the cybersecurity-specific list, and I've got concrete numbers for experience—15 years in IT, 9 years in finance and real estate for one role, 30 years in audit, and 20 years in financial services and real estate for another. These quantified credentials are the substantive details that distinguish this paragraph.

fact: contracted Chief Technology Officer

fact: Head of Internal Audit

fact: approximately 15 years of information technology experience

fact: nine years in the finance and real estate sectors

fact: approximately 30 years of audit experience

fact: 20 years in the real estate and financial services sectors


reasoning: The paragraph frames around 'risk assessment and management processes' but its substantive content is about the persons: the VP of IT's 25 years of experience, DoD Research background, and reporting line to the CFO with 20+ years of experience. This is about who these people are and what qualifies them, making it Management Role per the person-vs-function test. Two or more QV-eligible hard facts (25 years of experience, Department of Defense Research as a named organization) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes management roles - VP of IT with 25 years experience, DoD background, reporting to CFO with 20+ years experience. But it also mentions "cybersecurity risk assessment and management processes."

Person-vs-function test: The paragraph starts with "processes are implemented and maintained by" then pivots entirely to describing WHO these people are - their titles, years of experience, backgrounds, reporting lines. Remove the opening clause about processes and the paragraph is entirely about the people. The process mention is incidental framing; the substantive content is about the persons' qualifications.

Category: **Management Role**

Specific facts:

- VP of IT overseeing cybersecurity counts as a qualified role
- 25 years of experience is a specific, quantifiable credential
- Named Department of Defense Research background qualifies as a specific organization
- CFO is too generic to count, and the 20 years in that role doesn't change that
- So I'm looking at 2 qualifying facts: the VP of IT's 25 years plus the DoD Research background

, which counts as a named government organization. That gives me the Quantified-Verifiable classification.

fact: VP of IT

fact: 25 years of experience in information technology

fact: IT leadership in Department of Defense Research

fact: over 20 years of experience as a CFO


reasoning: The paragraph describes the company's own internal information security program components — risk assessments, a security team, security tests, awareness training, an incident response plan, and third-party risk assessment procedures. All are generic practices with no named frameworks, no named tools/firms, no specific titles (CISO etc.), no dates, and no quantified details. Third-party risk is mentioned as one component of the internal program, not the central topic, so Risk Management Process applies.

thinking:
Let me analyze this paragraph.

Content: Describes the company's information security program components - risk assessments, security team, security tests, training, incident response plan, third-party risk assessment. This is clearly about internal processes.

Category: Risk Management Process - describes the company's own internal cybersecurity processes and program components.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No cybersecurity-specific titles (just "information security team" - generic)
- No named tools, firms, dates, numbers
- "information security team" - not a specific title like CISO

- References to external auditors and incident response procedures are all unnamed and generic

Everything here is generic practices without any named standards or firm-specific details → Generic Boilerplate.


specificity_confidence: medium

reasoning: The VP of Technology is the grammatical subject performing the primary action — regularly informing executive leadership and escalating to the Board. This is about management's reporting lines and communication structure, making it Management Role per Rule 2. The VP of Technology is analogous to 'VP of IT/Security' on the IS list, serving as a cybersecurity-specific title unique to this company's structure, yielding Firm-Specific. Only one IS-list fact prevents Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes how the VP of Technology reports to executive leadership and the Board about cybersecurity matters. Let me determine the category and specificity.

Category: The primary subject is the VP of Technology's reporting structure - reporting to Executive Chairman, CEO, President, CFO, and escalation to the Board. This is about the management role's reporting lines and communication patterns. The Board is mentioned as a recipient of escalations, but the VP of Technology is the grammatical subject performing the primary action (informing, reporting). This fits Management Role.

Wait - let me reconsider. The paragraph title is "Reporting to Board" and discusses how information flows upward. The VP of Technology is the subject reporting upward.

So the VP of Technology is the management figure doing the reporting to leadership and the Board, which makes this a Management Role category. Now for specificity - "VP of Technology" is close to the IS list's "VP of IT/Security" but I need to determine if it's specific enough to count as a cybersecurity-specific title.

Looking at the context, this person is handling cybersecurity responsibilities, so I'd classify it as a firm-specific cybersecurity role. The other actors mentioned - Executive Chairman, CEO, President, CFO, and Board - are all generic C-suite positions not on the IS list. Since only the VP of Technology qualifies as cybersecurity-specific, this falls under Firm-Specific classification.

fact: VP of Technology


reasoning: The paragraph's primary content is the management-level organizational structure for cybersecurity: the IS Steering Committee's composition, scope, meeting cadence, reporting lines, and the CIO's appointed responsibility for IT risk. The grammatical subjects are the IS Steering Committee and the CIO — management actors — making this Management Role rather than Board Governance (the Board ERM Committee is only a reporting destination). Multiple firm-specific facts (named committees: IS Steering Committee, Management Risk Committee, Board ERM Committee; CIO role) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the IS Steering Committee, chaired by the CIO, its advisory role, meeting cadence, reporting to Management Risk Committee and Board ERM Committee, and CIO's responsibility for IT risk.

Category: This is about management structure and committees. The IS Steering Committee is chaired by the CIO, reports to committees. The primary subject is the IS Steering Committee and the CIO's role. This is about organizational structure for cybersecurity management - Management Role seems right since it's about management committees and the CIO's responsibilities.

Wait - the IS Steering Committee is a management-level committee, not a board committee.

The focus here is on the IS Steering Committee's composition and reporting lines, with the CIO as chair overseeing IT risk management. The committee reports upward to both the Management Risk Committee and Board ERM Committee, making this clearly a Management Role classification. I'm verifying the specificity of the named entities—CIO is cybersecurity-specific, and all three committees mentioned are properly named rather than generic.

For quantitative verification purposes, I don't see any QV-eligible facts like dates, financial figures, headcounts, or third-party vendors that would push this into a higher classification. The multiple IS-list facts support a Firm-Specific (3) rating, but without two or more QV-eligible facts, it stays below the QV threshold.

fact: IS Steering Committee (named internal committee with unique identifier)

fact: Chief Information Officer chairs the IS Steering Committee

fact: Management Risk Committee (reporting destination)

fact: Board ERM Committee (reporting destination)


reasoning: The paragraph describes the company's internal risk assessment processes—ERM integration, threat monitoring, risk scenarios, and risk quantification—all squarely within Risk Management Process. Despite the structured bullet points, every element is generic (no named frameworks, tools, dates, roles, or firm-specific facts), making it boilerplate that could appear in any company's filing.

thinking:
Let me analyze this paragraph.

Content: Describes internal risk assessment processes - ERM integration, threat monitoring, risk scenarios, risk quantification. All internal processes.

Category: Risk Management Process - describes the company's own internal cybersecurity processes.

Specificity: No named frameworks, no named tools, no specific dates, no named roles beyond generic. The bullet points describe generic practices (ERM, threat monitoring, risk scenarios, risk quantification). No IS-list facts. No named standards.

→ Generic Boilerplate (1)


content_category: None/Other

reasoning: This is a pure cross-reference to Risk Factors with no materiality conclusion. While it mentions risks that 'may materially affect,' it does not make an explicit assessment of whether risks have or have not materially affected the company — it merely directs the reader elsewhere.


reasoning: While the paragraph includes notable Management Role content (CISO credentials, CIO mention, CISSP, 20+ years experience), the dominant communicative purpose is describing the company's cybersecurity program: defense-in-depth methodology, use of internal and external resources, penetration testing, incident response, ERM integration. Applying the person-vs-function test, removing the CISO credentials leaves a complete process description. Specificity reaches Quantified-Verifiable with two QV-eligible hard facts: CISSP certification and 'over 20 years' of experience.

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

The paragraph covers multiple topics:
1. Dedicated team of technology professionals monitoring cyber risks
2. CVP/CIO and CISO responsible for IT security program
3. CISO credentials: CISSP, Master's in Computer Information Systems, 20+ years experience
4. Teams lead enterprise-wide cyber resilience strategy
5. Defense-in-depth methodology
6. Internal resources + external consultants for pen testing, IR, third-party assessments
7. Proprietary and commercial solutions, integrated into ERM

Person-vs-function test: The paragraph mentions the CISO's credentials (CISSP, Master's degree, 20+ years), but then shifts to describing what the program does — defense-in-depth, consultants, solutions, ERM integration.

Looking at the balance here, the CISO credentials take up maybe two sentences while the rest focuses on the actual cybersecurity processes and activities. Even if I strip out the credentials, the paragraph still conveys the company's substantive risk management approach. This is fundamentally about the Risk Management Process, with the CISO's qualifications serving as supporting detail rather than the main point. The CISSP certification and over 20 years of experience are both quantified and verifiable facts, so this qualifies as Quantified-Verifiable information.

fact: Chief Information Officer (CIO)

fact: CISSP certification

fact: Over 20 years of relevant expertise

fact: Masters Degree in Computer Information Systems


reasoning: This paragraph spans multiple categories (board governance, management role, risk management process, strategy integration), but its primary communicative purpose is describing the company's overall cybersecurity risk management approach — incident response strategy, monitoring/testing processes, and how risks are identified and reported. The CIO credentials and board oversight are subordinate to the process description. Specificity is Firm-Specific: multiple IS-list facts (CIO, Senior Director of Information Security, Cybersecurity Infrastructure Committee, 15 years of experience) but only one QV-eligible hard fact (15 years), falling short of the two needed for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me identify the dominant category.

Content covered:
- Audit and Risk Committee oversight (Board Governance)
- CIO, Senior Director of Information Security roles (Management Role)
- CIO's 15 years experience and degree (Management Role)
- Cybersecurity Infrastructure Committee meets monthly (Risk Management Process / governance)
- Incident response strategy and plan (Risk Management Process)
- Past adverse IT events with no material impact (Strategy Integration)
- Cybersecurity insurance (Strategy Integration)
- Monitoring, testing, response processes (Risk Management Process)

- CIO reports to Audit and Risk Committee (Board Governance / Management Role)

The paragraph weaves together governance structure with risk management processes. The Audit and Risk Committee provides oversight, the CIO and security leadership manage the actual risk mitigation efforts, and the Cybersecurity Infrastructure Committee handles the operational processes like incident response and monitoring. This is primarily about how the organization structures its risk management oversight and execution. Looking at the specific qualifications now—the 15 years of experience is a concrete number that counts toward QV eligibility, while the CIO and Senior Director titles are firm-specific roles rather than independently verifiable credentials. The Cybersecurity Infrastructure Committee is a named internal committee, and the management information systems degree lacks institutional specificity, so it doesn't strengthen the case. This reinforces that Risk Management Process is the right categorization, since the paragraph emphasizes the structured oversight and experience driving the company's approach.

fact: Senior Director of Information Security

fact: CIO has 15 years of experience in cybersecurity

fact: Cybersecurity Infrastructure Committee


reasoning: The audit committee is the grammatical subject receiving cybersecurity reports, making this Board Governance. The CTO is a cybersecurity-specific title on the IS list, elevating specificity to Firm-Specific; however, 'audit committee' and 'quarterly' are both on the NOT list and do not count toward further elevation.

thinking:
Classify this paragraph.

The paragraph is about the Audit Committee receiving reports from the CTO. The grammatical subject is "the audit committee" - board governance. The CTO reports to them.

Content: Board Governance (Audit Committee is the subject, receiving reports - this is about board oversight)

Specific facts:
- CTO (cybersecurity-specific title per IS list) → named_role
- "quarterly reports" - generic cadence, NOT list
- "audit committee" - generic, NOT list

So one IS fact: CTO. That gives Firm-Specific.

QV check: Only one hard fact (CTO is a named role, not QV-eligible).

There are no dates, amounts, named firms, or tools mentioned, so this doesn't qualify as QV. The classification is Firm-Specific at level 3.

fact: CTO provides reports to the audit committee


reasoning: The paragraph describes how cybersecurity risks are integrated into the company's internal enterprise risk management process, including risk universe evaluation, risk owner assignment, and mitigation tracking — all internal processes. The named internal program 'Organization Risk Management (ORM)' with its unique abbreviation qualifies as a firm-specific identifier.

fact: Organization Risk Management (ORM) program


reasoning: The entire paragraph is about the person holding the CISO role — their years of experience, prior positions, tenure, and reporting line. This passes the person-vs-function test as Management Role. Two hard verifiable facts (30+ years of experience as a specific number, and 2021 as a specific date of joining) meet the QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's experience, background, prior roles, reporting line. This is about the person.

Category: Management Role - the paragraph is about the person's qualifications, experience, and reporting structure.

Specific facts:
- "Chief Information & Security Officer" - cybersecurity-specific title (named_role)
- "over 30 years of experience" - specific number (quantified)
- "joining Alight in 2021" - specific date (specific_date)
- "SVP, Chief Information Security Officer" at prior company - prior role
- "Chief Technology and Delivery Officer" - reporting line (named_role)

- I'm flagging this as Quantified-Verifiable since there are two hard facts: the "over 30 years" experience metric and the "2021" joining date.

fact: Chief Information & Security Officer

fact: over 30 years of experience in cybersecurity

fact: joined Alight in 2021

fact: Chief Technology and Delivery Officer (reporting line)


reasoning: The Information Security Officer is mentioned as attribution, but the paragraph's substantive content describes what the department does: risk assessments, alert monitoring, incident response, vulnerability assessment, threat intelligence, identity access governance, and third-party risk management. Removing the ISO reference, the paragraph still functions as a process description. The ISO title is a cybersecurity-specific role (IS list), yielding Firm-Specific, but no second hard verifiable fact exists for QV.

thinking:
Let me analyze this paragraph carefully.

The paragraph starts with "Our Information Security Officer" - a cybersecurity-specific role. Then it describes what the department does (risk assessments, monitoring, incident response, etc.).

Person vs. function test: The ISO is mentioned as attribution, then the paragraph describes what the department/program does. Remove "Our Information Security Officer is accountable for managing the information security department and executing the information security program" and the rest still describes processes. But the first sentence IS about the role. Let me look more carefully.

The paragraph covers:
1. ISO is accountable for managing the department and program (attribution)
2. What the department does (processes)

3. The team structure with staff at different levels
4. How they work with the IT department and external security vendors

This is fundamentally about the department's function and responsibilities. The ISO gets mentioned as the person leading it, but the focus is on what the security program actually does. Looking at the specific facts: "Information Security Officer" is a cybersecurity-specific title that belongs on the list, while the third-party vendor is unnamed and generic, so that doesn't count. The IT department reference is also too generic.

So I'm left with one concrete fact: the Information Security Officer role itself.

That's firm-specific, which means I can stop here.

fact: Information Security Officer


reasoning: The paragraph describes an actual cybersecurity incident — detection, investigation, law enforcement engagement, and remediation actions. It contains one specific date (early April 2023) but no named firms, tools, or other hard verifiable facts, so it reaches Firm-Specific but not Quantified-Verifiable.

fact: early April 2023


reasoning: The paragraph describes the scope and aftermath of a cybersecurity incident — data exfiltration, types of data affected (PII, bank account info), regulatory cooperation, and notification actions. Two hard verifiable facts: a specific count of regulators (three) and a specific timeframe (fourth quarter of 2023).

thinking:
Incident disclosure - describes what happened, scope, data affected, response actions.

Specific facts: "fourth quarter of 2023" (specific date), "three state consumer and financial service regulators" (quantified), "dark web" (not specific), "back-office activities" (not specific).

QV check: "fourth quarter of 2023" = specific date, "three state...regulators" = specific number. That's two hard verifiable facts → Quantified-Verifiable.

fact: fourth quarter of 2023


reasoning: The paragraph's primary communicative purpose is describing how the board and audit committee maintain oversight of cybersecurity through a structured briefing cadence (quarterly to audit committee, periodic updates to full board, annual briefings to board). While the Head of Information Security is the grammatical subject in two sentences, the content is about the governance oversight mechanism — briefing frequency is explicitly a Board Governance marker. The Head of Information Security is a cybersecurity-specific title on the IS list, yielding Firm-Specific, but no second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes briefing cadence between the Head of Information Security and the audit committee/board. The primary actors are the Head of Information Security (providing briefings) and the audit committee (providing updates to board).

Category: This is a mix. The Head of Information Security is the grammatical subject in sentences 1 and 3, providing briefings. The audit committee is the subject in sentence 2. But the content is about oversight/briefing structure - who briefs whom and how often.

The "Head of Information Security" is the primary actor in 2 of 3 sentences. But the content isn't about the person's qualifications - it's about the briefing/oversight structure. This is really about governance oversight flow.

I'm wrestling with whether this is fundamentally about the management role or the governance structure. The Head of Information Security is grammatically central, but they're being described through their reporting obligations rather than their responsibilities. The real focus seems to be on how oversight flows from management up to the board, which points toward Board Governance as the category. The Head of Information Security is the primary actor across most of the paragraph, reporting quarterly to the audit committee and annually to the board, which points toward Management Role rather than Board Governance. Even though the audit committee's intermediary role appears in one sentence, the overall focus is on the reporting structure and cadence driven by the security leader. I keep flip-flopping on this. Let me actually settle it by looking at the three sentences and who's doing what. The Head of Information Security appears as the main actor in two of them, and Rule 2 says when the CISO reports to the Board, that's Management Role. So I'm going with Management Role here—the focus is on who holds the position and their reporting responsibilities, not the broader governance structure.

Wait, but the codebook specifically calls out "briefing frequency" as Board Governance content. And that's really what this paragraph is about—the cadence of briefings across different levels. That's the core substance, not just who reports to whom. I think this actually belongs in Board Governance.

Looking at the dual-category example confirms it: when the focus is on the oversight structure and reporting cadence rather than the individual's credentials, it's Board Governance. So I'm going with that.

For specificity, "Head of Information Security" is a role-specific title that should be flagged as Firm-Specific, but "audit committee," "quarterly," and "annual" are all generic governance terms that don't need flagging.

fact: Head of Information Security (cybersecurity-specific title)


reasoning: The paragraph's central topic is the company's reliance on and management of third-party cybersecurity partners — outsourced SOC, vendor-led penetration testing, and developing third-party risk oversight processes. While these third parties serve the company's security program, the dominant communicative purpose is describing the third-party relationships themselves and the intent to formalize vendor cyber-risk oversight, making Third-Party Risk the best fit over Risk Management Process. No named firms, frameworks, dates, roles, or specific details are present — all entities are unnamed ('cybersecurity companies,' 'certain vendors,' 'partners') and cadences are vague ('from time to time,' 'periodic').

thinking:
Let me analyze this paragraph.

Content: Discusses third-party service providers and cybersecurity partners. The central topic is the company's use of external parties for cybersecurity. It mentions outsourced SOC, penetration testing, vulnerability assessments, and developing third-party risk oversight processes.

Category: This is about third-party relationships being central to their cybersecurity approach. The paragraph discusses partnering with external cybersecurity companies, outsourced SOC, engaging vendors. The central topic is oversight/use of external parties. This fits Third-Party Risk.

Wait - let me reconsider. Rule 3 says "External assessor hired to test the company → Risk Management Process (they serve the company)." The penetration testing and vulnerability assessments by partners serve the company. The outsourced SOC also serves the company.

These third parties are components of the company's own cybersecurity infrastructure. The paragraph is really about how the company leverages external partners as part of its security program - they're tools the company uses. Per Rule 3, when external assessors serve the company as part of its processes, that's Risk Management Process. But the last sentence about "developing processes for third-party service provider cyber-risk oversight and management" pulls this toward Third-Party Risk management. This is genuinely borderline - the paragraph mixes the company's use of third parties for security services with the company's oversight of third-party risks.

Looking at the specific elements: cybersecurity partners as infrastructure, outsourced SOC, penetration testing by partners - these are all third parties serving the company. But the focus on developing oversight and management processes for these vendors tips the balance toward Third-Party Risk, since vendor oversight becomes the central topic. The rules are clear that when vendor oversight is central, or when requirements are imposed on vendors, that's Third-Party Risk. I think Third-Party Risk is the right call here.

Now checking for specificity - there are no named frameworks, firms, dates, roles, or numbers. Everything stays generic: "cybersecurity companies," "certain vendors," "partners," "from time to time." This is clearly Generic Boilerplate.


reasoning: The paragraph opens with an explicit materiality assessment ('have not materially affected... business strategy, results of operations, or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Item 1A and generic hedging language. No named entities, frameworks, dates, or firm-specific facts are present.

thinking: Materiality assessment + cross-reference. Rule 6 says materiality disclaimers → Strategy Integration.


reasoning: The paragraph describes internal cybersecurity processes (prevent, detect, mitigate, remediate) including threat intelligence, security tools, and external consultants. Although 'management team' is the grammatical subject, the substantive content is about the processes and information sources used — removing the management attribution, the paragraph still describes risk management activities. No named frameworks, specific roles (CISO/CIO/CTO), named tools, named firms, or other specific facts are present; all entities are generic ('internal IT personnel', 'external consultants', 'security tools').


reasoning: The Head of IT is the grammatical subject throughout, and the paragraph describes management coordination structures and reporting lines — who meets with whom and who reports to the audit committee. While process-adjacent, the primary content is organizational: the Head of IT's working relationship with the CLO, meetings with the MSSP, and reporting chain to the audit committee. No IS-list facts remain after filtering: 'Head of IT' is generic IT leadership (NOT list), 'Chief Legal Officer' is generic C-suite, 'audit committee' is standard governance, cadences are vague ('periodically', 'regular'), and third-party providers are unnamed.

thinking:
Let me analyze this paragraph.

Content: Describes the Head of IT meeting with Chief Legal Officer to discuss cybersecurity risk management, meetings with managed security service provider, and reporting to audit committee.

Category: This is about management's role and processes. The Head of IT is the grammatical subject throughout. But "Head of IT" - is this a cybersecurity-specific title? Per the IS NOT list, "Head of IT", "IT Manager", "Director of IT" are generic IT leadership titles, NOT cybersecurity-specific.

The paragraph describes meetings, reporting structures, and processes. The primary actors are management figures (Head of IT, Chief Legal Officer). But what's the primary content? It's about how management handles cybersecurity - meetings, discussions, reporting to audit committee.

This is really about the organizational processes and governance structure rather than the individual's qualifications or background. The Head of IT is the focal point, but the substance is about what functions they perform—coordinating with legal, engaging external security providers, and communicating risk to the audit committee. This looks like it's describing the risk management process and reporting chain more than anything else. I'm caught between two categories here. The Head of IT is definitely the grammatical subject and their reporting lines are described, which points toward Management Role. But the actual content focuses on what they *do* — the coordination meetings, third-party engagement, and reporting processes — rather than who they are or their qualifications. The process itself seems to be the main point, so Risk Management Process feels like the better fit.

Actually, looking at the specificity issue: "Head of IT" is too generic to count as a specific management role per the guidelines, and while the Chief Legal Officer is mentioned, the paragraph still centers on functional activities rather than role identification. I think the process-focused nature of the content tips this toward Risk Management Process rather than Management Role. Wait, I need to reconsider this. The paragraph is really about organizational structure and reporting relationships—who meets with whom, what gets reported where. That's management roles and coordination, not risk assessment methodology or technical processes. So this falls under Management Role, and it's generic boilerplate since there are no specific facts or named standards backing it up.


reasoning: The paragraph opens with an explicit materiality assessment ('not aware of any cybersecurity incidents that have materially affected...business strategy, results of operations, or financial condition'), which per Rule 6 makes this Strategy Integration regardless of the appended cross-reference. The mention of 'an event that occurred in March 2023' is a specific date constituting one firm-specific fact, but only one hard verifiable fact, so it stays at Firm-Specific rather than Quantified-Verifiable.

thinking:
Materiality assessment + cross-reference to risk factors + mention of a March 2023 event.

The paragraph contains an explicit materiality assessment ("not aware of any cybersecurity incidents that have materially affected...business strategy, results of operations, or financial condition"). Per Rule 6, this is Strategy Integration.

Specificity: The materiality language is boilerplate. There's a reference to "an event that occurred in March 2023" — that's a specific date. But the paragraph doesn't describe the event, just cross-references it. The materiality assessment itself is boilerplate.

The mention of "March 2023" is a specific date reference. That's one fact from the IS list → Firm-Specific.

fact: Reference to an event that occurred in March 2023


reasoning: The paragraph describes the mechanism by which the Audit Committee maintains oversight of cybersecurity incidents through management updates. While 'Management' is the grammatical subject, the communicative purpose is to describe the board committee's oversight channel — how the Audit Committee stays informed. No firm-specific facts are present: 'Audit Committee' is standard governance, 'management' is generic, and 'as necessary' is a vague cadence.

thinking:
Classify this paragraph.

The paragraph describes management updating the Audit Committee about incidents. The primary actor is "Management" but the content is about reporting to the Audit Committee. Let me think about Board vs Management.

"Management updates the Audit Committee" - Management is the grammatical subject, but the action is about reporting TO the board committee. This is about the communication flow between management and the board committee regarding incidents.

Per Rule 2: "Management role reports TO the board" → Management Role. But wait, "CISO reports quarterly to the Board on..." → Management Role. However, this is about the Audit Committee receiving updates, which is board oversight.

Actually, I'm reconsidering whether this is really about the management function or the board's oversight mechanism. The Audit Committee is receiving updates about incidents, which describes how the board maintains oversight. Looking at the tiebreaker rules, "Management role reports TO the board" points to Management Role, but I need to check if that's actually what's being described here or if it's more about the board's governance structure.

The key distinction is whether the paragraph focuses on management's responsibility to report or on the Audit Committee's oversight process. Since "Management" is mentioned generically rather than as a specific cybersecurity role, and the emphasis is on how the Audit Committee stays informed about incidents, this feels like Board Governance—describing the oversight mechanism itself rather than defining a management function.

Looking at the specificity markers: "Audit Committee" is generic governance language, "Management" is vague, "as necessary" lacks precision, and "material cybersecurity incidents" reads like standard boilerplate. There are no named standards or company-specific details here, so this lands as Generic Boilerplate.


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


reasoning: The paragraph describes the company's own internal information security processes for identifying, assessing, and managing cybersecurity risks — squarely Risk Management Process. Despite listing protected asset types (intellectual property, clinical trial data), it names no recognized frameworks, no cybersecurity-specific roles, no tools, and no firm-specific facts from the IS list. The defined term 'Information Systems and Data' is a generic internal label, not a uniquely named program. This is boilerplate that could apply to any biotech company.

thinking:
Classify this paragraph.

Content: Describes the company's information security processes designed to identify, assess, and manage material risks from cybersecurity threats. Lists what's protected (networks, services, hardware, software, data types).

Category: Risk Management Process - describes internal processes for risk management.

Specificity: No named frameworks, no named roles, no specific dates, no named tools. The listing of data types (intellectual property, clinical trial data) is somewhat specific to a biotech but doesn't hit the IS list. "Information Systems and Data" is a defined term but not a named program with unique identifier per the codebook.

This is Generic Boilerplate.


reasoning: The paragraph contains a cross-reference to Risk Factors (no materiality conclusion, just a pointer) and a single generic sentence about board oversight. The board sentence ('Our board of directors addresses our cybersecurity risk management as part of its general oversight function') is the only substantive disclosure, making Board Governance the dominant category, though barely. All elements are generic — 'Board of Directors' and 'general oversight function' appear on the NOT list, no named frameworks, roles, or specific facts.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A cross-reference to Risk Factors with a specific risk factor caption
2. A generic statement about board oversight

The cross-reference points elsewhere for cybersecurity risk description. The board statement is extremely generic ("addresses... as part of its general oversight function").

There's no materiality assessment here - it says "risks... that may materially affect us" but this is directing the reader to see risk factors, not making a materiality conclusion. It's not saying "have not materially affected" - it's saying "for a description of risks that may affect us, see..."

The board mention is perfunctory - "as part of its general oversight function" - not substantive governance disclosure.

The cross-reference dominates the paragraph, with just one minimal board governance sentence tacked on. That sentence about cybersecurity oversight is so generic—"addresses cybersecurity risk management as part of its general oversight function"—that it barely qualifies as substantive disclosure. I'm leaning toward this being borderline, but the board statement does technically mention cybersecurity oversight, even if it's the thinnest possible version of that.

The cross-reference itself isn't making a materiality assessment—it's just pointing readers to the risk factors section and describing what's there, not concluding whether risks have actually materially affected the company. So the real disclosure here is that board governance statement, however generic it may be. I think this lands as Board Governance, but just barely.


reasoning: The grammatical subject is 'certain members of our management team' and the paragraph enumerates their cybersecurity responsibilities (hiring consultants, approving budgets, reviewing assessments). However, no specific roles (CISO, CIO, etc.), named individuals, credentials, or reporting lines are provided — it is entirely generic management responsibility language that could apply to any company.

thinking:
Let me analyze this paragraph.

Content: "Certain members of our management team" are responsible for various cybersecurity activities. No named roles, no specific people, no credentials. The paragraph describes what management does - hiring consultants, integrating cyber into ERM, communicating priorities, approving budgets, preparing for incidents, approving processes, reviewing assessments.

Category: Management Role vs Risk Management Process. The subject is "certain members of our management team" - very generic. No named roles, no credentials, no reporting lines. It's describing management responsibilities but in a completely generic way. The paragraph is about what management does (function) not who they are (person). But the primary subject IS management and their responsibilities... However, applying the person-vs-function test: remove "certain members of our management team" and replace with "the Company" - it reads as process description. But the whole paragraph is structured as listing management's responsibilities.

The grammatical subject is clearly management, and since the paragraph centers on their cybersecurity responsibilities, this falls under Management Role. The language is entirely generic though—just "certain members of our management team" with no specific titles, frameworks, or dates—so this is Generic Boilerplate.


reasoning: The entire paragraph describes the qualifications, experience, education, and certifications of the CISO and CIO — it is entirely about the persons, not the function. QV-eligible hard facts include 15 years experience, 30 years experience, and CISSP certification (three QV-eligible facts).

thinking:
Classify this paragraph about CISO and CIO qualifications.

This is clearly about the persons - their credentials, experience, education, certifications. Management Role.

Specific facts:
- CISO (cybersecurity-specific role)
- CIO (cybersecurity-specific role)
- 15 years experience (quantified)
- CISSP certification (named certification)
- graduate degree in Cybersecurity
- 30 years experience (quantified)
- undergraduate degree in Information Networking and Telecommunications

QV-eligible: 15 years, CISSP, 30 years - that's at least 2 hard verifiable facts → Quantified-Verifiable

fact: CISO role

fact: CIO role

fact: over 15 years of experience in IT and information security

fact: over 30 years of experience in IT

fact: Certified Information Systems Security Professional (CISSP)

fact: graduate degree in Cybersecurity


reasoning: The paragraph primarily describes the company's own internal cybersecurity processes — third-party assessments (penetration testing, vulnerability scanning, threat hunting), internal audits, and adjusting policies based on results. Third-party risk oversight is mentioned as one component but is not the central topic; the external assessors serve the company's program (Rule 3). Board/Audit Committee reporting is subordinate. No named frameworks, no cybersecurity-specific roles, no named firms or tools, no specific dates or numbers — all items fall on the NOT list (common practices, generic governance terms, generic cadences).

thinking:
Let me analyze this paragraph.

Content: Describes third-party assessments (pen testing, vuln scanning, threat hunting), reporting results to Board, risk-based approach to third-party risks, internal audit department reporting to Audit Committee.

Category: This is mixed. It describes internal processes (assessments, penetration testing, vulnerability scanning) and third-party risk management, plus some board reporting. The dominant content is about the company's own internal cybersecurity processes - the third-party assessors serve the company, and the vendor oversight is one component. This is Risk Management Process.

Specificity: Let me check facts:
- "penetration testing, vulnerability scanning, proactive threat hunting" - common practices, NOT list

- "Board" - generic, NOT list
- "Audit Committee" - generic, NOT list
- "internal audit department" - generic
- "quarterly report" - generic cadence
- No named frameworks, no named firms, no named roles, no specific dates, no numbers

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


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any risks from cybersecurity threats that have materially affected or are reasonably likely to materially affect our business strategy, results of operation or financial condition'), making it Strategy Integration per Rule 6. The cross-reference to Risk Factors and generic threat language are noise. No firm-specific facts remain after filtering — '2023' is a generic fiscal year reference in boilerplate context, not a specific date triggering Firm-Specific.


reasoning: The paragraph splits between describing the CSIRP (process) and describing management roles/reporting lines (CIO reports to CEO, Director of Information Security reports to Risk Committee, Director of IT). The latter half is dominant by sentence count and is the paragraph's culminating point — it identifies specific cybersecurity leadership roles, their reporting structures, and responsibilities, making Management Role the primary communicative purpose. Multiple IS-list facts (CIO, Director of Information Security, Risk Committee, named CSIRP) yield Firm-Specific, but no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph carefully.

Content: Describes the CSIRP plan, its framework, roles and responsibilities. Then describes management roles - CIO, Director of IT, Director of Information Security, their reporting lines.

Category: This is a mixed paragraph. First half describes the incident response plan (Risk Management Process). Second half describes management roles and reporting lines (Management Role). The person-vs-function test: the second half is about reporting structures and who leads what - that's about the people/roles. But the first half is about the CSIRP process.

Looking at dominant category - roughly equal split. The first half describes the plan, the second half describes the people. The paragraph transitions from process to people. Let me count sentences:

The CSIRP establishment and its framework make up the first part, while the management structure with the CIO, Director of IT, and Director of Information Security—including their reporting lines to the CEO and Risk Committee—dominates the second half. The person-vs-function test suggests this leans toward management roles since the focus is on organizational structure and who oversees what, even though the paragraph starts with process description.

Looking at the specificity, I'm checking which details are actually verifiable facts: the CSIRP itself is a named internal program, the Director of Information Security is a cybersecurity-specific role, and the Risk Committee is a named entity. But I need to verify whether I have enough hard facts beyond just titles and organizational positions—dates, numbers, or concrete outcomes would strengthen this, and I'm not seeing those here.

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

fact: CIO — cybersecurity-specific leadership title

fact: Director of Information Security — cybersecurity-specific title

fact: Risk Committee — named non-generic committee