ENCORE CAPITAL GROUP INC 10-K Cybersecurity GRC - 2024-02-21

Page last updated on July 16, 2024

ENCORE CAPITAL GROUP INC reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-02-21 17:23:59 EST.

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10-K filed on 2024-02-21

ENCORE CAPITAL GROUP INC filed a 10-K at 2024-02-21 17:23:59 EST
Accession Number: 0001084961-24-000008

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Item 1C. Cybersecurity.

Item 1C-Cybersecurity Cybersecurity Risk Management and Strategy We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information. We design and assess our program based on the National Institute of Standards and Technology Cybersecurity Framework (“NIST CSF”). This does not imply that we meet any particular technical standards, specifications, or requirements, only that we use the NIST CSF as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business. Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, operational, and financial risk areas. Our cybersecurity risk management program includes: - risk assessments designed to help identify material cybersecurity risks to our critical systems and our broader enterprise IT environment; - a security team principally responsible for implementing and managing (1) our cybersecurity risk assessment processes, (2) our security controls, (3) technical security tools and safeguards and (4) our response to cybersecurity incidents; - reviews and audits by our internal audit department; - the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security controls; - cybersecurity awareness training of our employees, incident response personnel, and senior management; - a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents; and - a third-party risk management and oversight process for service providers, suppliers, and vendors. We have experienced, and will continue to experience, cybersecurity incidents from time to time in the normal course of business. However, based on our assessments, these incidents have not had a material impact, and we do not believe the incidents have materially affected or will materially affect us, including our operations, business strategy, results of operations or financial condition. For more information regarding risks we face from cybersecurity threats, please see Item 1A- Risk Factors. Cybersecurity Governance Our Board considers cybersecurity risk as part of its risk oversight function and has delegated the oversight of cybersecurity and other information technology risks to the Risk Committee. The Risk Committee oversees management’s implementation of our cybersecurity risk management program. The Risk Committee receives regular reports from management on our cybersecurity risks. In addition, management updates the Risk Committee, as necessary, regarding significant cybersecurity incidents. The Risk Committee regularly reports to the full Board regarding its activities, including those related to cybersecurity. The full Board also receives briefings from management on our risk management program. Board members receive presentations on cybersecurity topics from management, internal security staff or external experts as part of the Board’s continuing education on topics that impact public companies. Our Chief Information Officer, Chief Risk, Strategy and Compliance Officer and General Counsel, are primarily responsible for assessing and managing our material risks from cybersecurity threats. Our Chief Information Officer has primary responsibility for our overall cybersecurity program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants. Our Chief Risk, Strategy and Compliance Officer has primary responsibility for our enterprise risk management program, including oversight of our cybersecurity risk management program. Our general counsel has primary responsibility for legal assessments, including assessments related to cybersecurity matters. Such individuals have an average of over 15 years of prior work experience in various roles involving information technology (including information security), risk and compliance or legal and risk analysis. This team supervises efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us; and alerts and reports produced by security tools deployed in the IT environment.

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