ACELYRIN, Inc. - (SLRN)
10-K Filing Date: March 28, 2024
Item 1C. Cybersecurity
Risk management and strategy
We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third party hosted services, communications
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systems, hardware and software, and our critical data, including intellectual property, data related to our clinical trials and other confidential information that is proprietary, strategic or competitive in nature (“Information Systems and Data”).
Our information security function, which is led by our IT department, helps to identify, assess and manage the Company’s cybersecurity threats and risks. Our IT team identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment and the Company’s risk profile using various methods including, for example, manual and automated tools, analyzing reports of threats and threat actors, conducting internal and external scans of our environment, periodic penetration tests conducted by third parties, utilization of a 24x7 security operations center (SOC) that provides monitoring and alert services, evaluating threats reported to us, and coordinating cross-functionally, with Company management and externally (e.g., with law enforcement) concerning threats.
Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example: a Cybersecurity Incident Response Policy; various other policies, plans, and frameworks in regards to (without limitations) access, acceptable use, password security and software system development; physical and administrative access and network security controls; data segregation; encryption of certain data; leveraging of certain SOC II-certified vendors; management, tracking and disposal of certain assets; systems monitoring; participating in information sharing and analysis centers (ISACs) to share and receive threat intelligence specifically related to biopharma and healthcare companies; and maintaining cyber insurance.
Our assessment and management of material risks from cybersecurity threats are integrated into the Company’s overall risk management processes. The Company has an IT Steering Committee made up of cross-disciplinary senior management, including (among others) the Chief Legal and Administrative Officer, Chief Financial Officer and Chief Operating Officer, along with IT leadership and representatives from several additional departments. For example, the IT department works with the IT Steering Committee and other senior management personnel to prioritize certain risk management processes and mitigate cybersecurity threats that are more likely to lead to a material impact to our business.
We use third-party service providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example, outside consultants, third party penetration testing providers, and threat intelligence and forensic providers.
We use third-party service providers to perform a variety of functions throughout our business, such as email and hosting providers, contract research organizations (CROs) and contract manufacturing organizations (CMOs). We have certain vendor management processes that we may use as appropriate to manage cybersecurity risks associated with our use of these providers. These processes may include the imposition of information security contractual obligations on vendors, as well as quality control elements for certain vendors. Depending on the nature of the services provided, the sensitivity of the information systems and data at issue, and the identity of the provider, our vendor management processes may involve different levels of assessment designed to help identify cybersecurity risks associated with a provider and impose contractual obligations related to cybersecurity on the provider.
For a description of the risks from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors under Part 1. Item 1A. Risk Factors in this Annual Report on Form 10-K, including "If our internal information technology systems, or those used by our CROs, CMOs, clinical sites or other contractors or consultants upon which we rely, or our data are or were compromised, become unavailable or suffer security breaches, loss or leakage of data or other disruptions, we could suffer material adverse consequences resulting from such compromise, including but not limited to, operational or service interruption, harm to our reputation, litigation, fines, penalties and liability, compromise of sensitive information related our business, and other adverse consequences."
Governance
Our board of directors addresses the Company’s cybersecurity risk management as part of its general oversight function. The board of directors’ audit committee is responsible for overseeing the Company’s cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats.
Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, led by our Executive Director of IT & Cybersecurity, who has over 20 years' of work experience in IT and cybersecurity.
The Executive Director of IT & Cybersecurity is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s overall risk management strategy, and communicating key priorities to relevant personnel. The Executive Director of IT & Cybersecurity, together with certain other senior management personnel, is responsible for approving functional budgets, implementing approved, phase-appropriate policies, plans and
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guidelines, helping prepare for potential cybersecurity incidents, reviewing security assessments and other security-related reports and overseeing cybersecurity processes.
Our Cybersecurity Incident Response Policy is designed to escalate certain cybersecurity incidents to members of senior management depending on the circumstances, including our Disclosure Committee, as appropriate. Senior management works with the Company’s cybersecurity incident management team to help the Company mitigate and remediate notified cybersecurity incidents, comply with applicable laws, regulations and contractual provisions and engage advisors as appropriate. In addition, such policy includes reporting to the audit committee of the board of directors for certain cybersecurity incidents.
The audit committee receives periodic reports from the Executive Director of IT & Cybersecurity concerning the Company’s significant cybersecurity threats and risk and the processes the Company has implemented to address them. The audit committee also has access to advisors, and various other reports, and presentation materials related to cybersecurity threats, risk and mitigation.