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New Cybersecurity Rule: Disclosure Trends

By Randi Morrison posted 02-15-2024 07:27 PM

  

DLA Piper’s “Updates to Form 10-K for fiscal year 2023: Early filer cybersecurity disclosure trends” reports on the prevalence of various aspects of cybersecurity disclosure based on a review of Russell 3000 Form 10-K Item 1C disclosures as of February 8.

A majority of filings disclosed / discussed the following:

  • A Chief Information Security Officer (CISO) or other role responsible for information security (85%), with 62% disclosing a CISO or similar role focused solely on information security. Another 23% reportedly disclosed a Chief Technology Officer or other employee with responsibility for information security and other technology-related matters.
  • Conducting employee training regarding cybersecurity, as well as conducting internal tests or simulations (69%)
  • Past breaches generally (69%)
  • Past threats generally (62%)

Early filer risk factor disclosure trends (cybersecurity and other) are reported below.

Access additional resources on our Cybersecurity/Data Privacy page.

    This post first appeared in the weekly Society Alert!

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