Upstart Holdings, Inc. 10-K Cybersecurity GRC - 2024-02-15

Page last updated on July 16, 2024

Upstart Holdings, Inc. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-02-15 16:16:15 EST.

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10-K filed on 2024-02-15

Upstart Holdings, Inc. filed a 10-K at 2024-02-15 16:16:15 EST
Accession Number: 0001647639-24-000009

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Item 1C. Cybersecurity.

ITEM 1C. CYBERSECURITY Risk Management and Strategy We have established policies and processes for identifying, assessing, and managing material risk from cybersecurity threats, and have integrated these processes into our overall risk management systems and processes. We routinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein. We conduct risk assessments to identify cybersecurity threats annually as well as in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats. These risk assessments include identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks. Following these risk assessments, we re-design, implement, and maintain reasonable safeguards to mitigate identified risks; reasonably address any identified gaps in existing safeguards; and monitor the effectiveness of our safeguards. We devote resources and designate high-level personnel, including our Chief Information Security Officer who reports to our Chief Risk Officer, to manage the risk assessment and mitigation process. Our Chief Information Security Officer works closely with a team of cybersecurity professionals with extensive experience and expertise in cybersecurity threat assessments and detection, incident response and mitigation. As part of our overall risk management system, we assess our safeguards in collaboration with various functional teams, including Information Security, Information Technology, Risk and Legal, and train our employees on these safeguards. Personnel at all levels and teams are required to receive periodic security awareness training to ensure that they understand our cybersecurity policies and their roles in protecting our information systems or any information residing therein. We have a set of company-wide policies and procedures concerning cybersecurity matters that include security risk assessment, identity and access control, vendor security and network security. There are other policies related to cybersecurity involving employees’ use of company equipment and resources, generative AI, remote work and workplace security and safety. These policies are reviewed periodically and approved by appropriate members of management. We engage assessors, consultants, auditors, or other third parties in connection with our risk assessment processes. These service providers assist us to design and implement our cybersecurity policies and procedures, as well as to monitor and test our safeguards. These services include Web Application Penetration Testing, Infrastructure security testing, NIST assessments, third party partner due diligence audits, consultant engagements, incident response preparedness, and vendor security review. We require each third-party service provider to certify that it has the ability to implement and maintain appropriate security measures, consistent with all applicable laws, in connection with the services they provide to us, and to promptly report any suspected breach of its security measures that may affect us. For additional information regarding whether any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect our company, including our business strategy, results of operations, or financial condition, please see Item 1.A. " Risk Factors " of this Annual Report on Form 10-K, including the risk factors titled " -Security breaches and incidents compromising borrowers’ confidential information that we store may harm our reputation, adversely affect our results of operations and expose us to liability “. Governance One of the key functions of our Board of Directors is informed oversight of our risk management process, including risks from cybersecurity threats. Our Board of Directors is responsible for oversight of our risk management framework, which is designed to monitor and manage strategic and operational risks. Management is responsible for the day-to-day identification, assessment and management of risks in our operations, including cybersecurity risks. Our Board of Directors administers its cybersecurity risk oversight function directly as a whole, as well as through the audit committee. Our Chief Information Security Officer has more than 20 years of information security expertise and is primarily responsible to identify, assess and manage our material risks from cybersecurity threats. Our Chief Information Security Officer started his career as a security engineer and has held various leadership positions in the security function at Microsoft, Netflix, Bridgewater Associates and, most recently, Robinhood. He received a bachelor degree in management information systems and holds an industry certification. Our Chief Information Security Officer oversees our cybersecurity policies and processes, including those described in " Risk Management and Strategy " above. The processes by which our Chief Information Security Officer is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents include the following: tabletop exercises, vulnerability management programs, internal & external security risk assessments, threat modeling processes of new services, third party security risk functions, incident response processes, phishing awareness programs, and additional control validation services. Our Chief Risk Officer reports to our CEO, and our Chief Risk Officer and/or Chief Information Security Officer provide quarterly briefings to the audit committee regarding our company’s cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing and activities of third parties. Our audit committee provides updates to the Board of Directors on such reports. We also have an established incident response plan led by our Chief Information Security Officer that lays out the process for the assessment, response and notifications internally and externally upon the occurrence of a cybersecurity incident. Depending on the nature and severity of an incident, our process, including those set forth in the incident response plan, provides for escalation and notification to management, the audit committee and the Board of Directors and/or external parties, as appropriate.

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