scPharmaceuticals Inc. - (SCPH)

10-K Filing Date: March 13, 2024
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. Our cybersecurity risk management program includes a cybersecurity incident response plan.

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.

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At this time, our cybersecurity risk management program is undergoing an effort to expand and mature our security controls and documentation. Our ongoing efforts include:

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A security risk assessment conducted by an external supplier to help identify material cybersecurity risks to our critical systems, information, products, services, and our broader enterprise IT environment. This assessment is ongoing and will be completed in the third quarter of 2024.
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The implementation of revised information security program documentation and policies in the first quarter of 2024, including:
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revision and implementation of a revised information security policy;
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implementation of a revised incident response plan and policy;
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implementation of a third-party risk management program that includes update procedures for third party vendor due diligence;
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implementation of additional periodic cybersecurity and awareness training for all of our employees.

These efforts complement our current cybersecurity risk management program, which include a security team that is principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents. We also conduct employee cybersecurity awareness training upon onboarding to the company. However, there can be no assurance that our cybersecurity risk management program and processes, including our policies, controls or procedures, will be fully implemented, complied with or effective in protecting our systems and information.

We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition. For more information, see the section titled “Risk Factor— Our business and operations may suffer in the event of information technology system failures, cyberattacks or deficiencies in our cybersecurity.”

Cybersecurity Governance

Our Board considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee, or the Committee, oversight of cybersecurity and other information technology risks. The Committee oversees management’s implementation of our cybersecurity risk management program.

The Committee receives periodic reports from management on our cybersecurity risks. In addition, management updates the Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.

The Committee reports to the full Board regarding its activities, including those related to cybersecurity. The full Board also receives briefings from management on our cyber risk management program. Board members receive presentations on cybersecurity topics from our Vice President Legal Affairs and Chief Compliance Officer, our Chief Financial Officer and internal information technology staff or external experts as part of the Board’s continuing education on topics that impact public companies.


Our management team, including our Director of Information Technology, is responsible for assessing and managing our material risks from cybersecurity threats. The team has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants. Our management team’s experience includes security program development and review, implementation of security tools and software, security risk identification and remediation, incident identification and remediation, as well as managing enterprise risk. In addition, we rely on third party cyber security consultants and legal counsel to supplement our expertise.

Our management 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

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engaged by us; and alerts and reports produced by security tools deployed in the information technology environment.

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