EQUITY LIFESTYLE PROPERTIES INC 10-K Cybersecurity GRC - 2024-02-21

Page last updated on April 11, 2024

EQUITY LIFESTYLE PROPERTIES INC reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-02-21 18:35:45 EST.

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10-K filed on 2024-02-21

EQUITY LIFESTYLE PROPERTIES INC filed an 10-K at 2024-02-21 18:35:45 EST
Accession Number: 0000895417-24-000036

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity Cybersecurity represents an important component of the Company s overall approach to risk management. The Company s cybersecurity policies, standards and practices are fully integrated into the Company s enterprise risk management ( ERM ) approach, and cybersecurity risks are subject to oversight by the Company s Board of Directors. The Company generally approaches cybersecurity threats through a cross-functional, multilayered approach, with the goals of: (i) identifying, preventing and mitigating cybersecurity threats to the Company; (ii) preserving the confidentiality, security and availability of the information that we collect and store to use in our business; (iii) protecting the Company s intellectual property; and (iv) maintaining the confidence of our customers, clients and business partners. Risk Management and Strategy Consistent with overall ERM policies and practices, the Company s cybersecurity program focuses on the following areas: Vigilance: The Company maintains a primarily domestic presence, with our cybersecurity threat operations designed with the specific goal of identifying, preventing and mitigating cybersecurity threats and responding to cybersecurity incidents in accordance with our established incident response and recovery plans. Systems Safeguards: The Company deploys systems safeguards that are designed to protect the Company s information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, software updates and patches, anti-malware functionality and access controls, which are evaluated and improved through ongoing vulnerability assessments and cybersecurity threat intelligence. Collaboration: The Company utilizes collaboration mechanisms established with public and private entities, including intelligence and enforcement agencies, industry groups and third-party service providers, to identify, assess and respond to cybersecurity risks. Third-Party Risk Management: The Company maintains a comprehensive, risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users of the Company s systems, as well as the systems of third parties that could adversely impact our business in the event of a cybersecurity incident affecting those third-party systems. Training: The Company provides periodic mandatory training for personnel regarding cybersecurity threats, which reinforces the Company s information security policies, standards and practices, and such training is scaled to reflect the roles, responsibilities and information systems access of such personnel. 26 Incident Response and Recovery Planning: The Company has established and maintains incident response and recovery plans that address the Company s response to a cybersecurity incident and the recovery from a cybersecurity incident, and such plans are tested and evaluated periodically. Communication and Coordination: The Company utilizes a cross-functional approach to address the risk from cybersecurity threats, involving management personnel from the Company s technology, operations, legal, risk management, internal audit and other key business functions, as well as the members of the Board of Directors and the Audit Committee in an ongoing dialogue regarding cybersecurity threats and incidents. A key part of the Company s strategy for managing risks from cybersecurity threats is the ongoing assessment and testing of the Company s processes and practices through auditing, assessments, tabletop exercises, threat modeling, vulnerability testing and other exercises focused on evaluating the effectiveness of our cybersecurity measures. The Company regularly engages third parties to perform assessments on our cybersecurity measures, including information security maturity assessments, audits and independent reviews of our information security control environment and operating effectiveness. The results of such assessments, audits and reviews are reported to the Audit Committee and the Board of Directors, and the Company considers adjustments to its cybersecurity policies, standards, processes and practices as necessary based on the information provided by the assessments, audits and reviews. The Company is not aware of any cybersecurity incidents in the last three years that have materially affected or are reasonably likely to materially affect the business strategy, results of operations, or financial condition of the Company. For more information regarding how cybersecurity threats could materially affect the Company, see " We Face Risks Relating to Cybersecurity Incidents and Privacy Laws." in Item 1A. Risk Factors. Governance The Board of Directors, in coordination with the Audit Committee, oversees the management of risks from cybersecurity threats, including the policies, standards, processes and practices that the Company s management implements to address risks from cybersecurity threats. The Board of Directors and the Audit Committee each receive regular presentations and reports on cybersecurity risks, which address a wide range of topics including, for example, recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations arising with respect to the Company s peers and third parties. The Board of Directors and the Audit Committee receive prompt and timely information regarding any cybersecurity incident that meets established reporting guidelines. Decisions regarding the disclosure and reporting of such incidents are made by management in a timely manner. The Board of Directors and Audit Committee receive ongoing updates regarding any such incidents until they have been addressed. The Audit Committee regularly interacts with the Company’s ERM function, the Company’s Vice President of Information Technology, other members of management and relevant management committees, including the Company’s Security Advisory Board and Cybersecurity Incident Response Team. On a quarterly basis each year, the Audit Committee discusses the Company s approach to cybersecurity risk management with the Company s Vice President of Information Technology. The Company s Vice President of Information Technology is the member of the Company s management that is principally responsible for overseeing the Company s cybersecurity risk management program, in partnership with other business leaders across the Company. The Vice President of Information Technology works in coordination with the other members of the Security Advisory Board, which includes our President and Chief Executive Officer, Executive Vice President and Chief Financial Officer and Executive Vice President and Chief Legal Officer. The Company s Vice President of Information Technology has over 25 years in Information Technology leadership including 15 years overseeing security and compliance operations. The Director of Information Security has over 15 years in various security roles in private and public sectors and has attained the professional certification of Certified Information Systems Security Professional (CISSP). The Company s Vice President of Information Technology and Director of Information Security, in coordination with the Security Advisory Board and Cybersecurity Incident Response Team, work collaboratively across the Company to implement a program designed to protect the Company s information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents. To facilitate the success of this program, multidisciplinary teams throughout the Company are deployed to address cybersecurity threats and to respond to cybersecurity incidents in accordance with the Company s incident response and recovery plans. Through the ongoing communications from these teams, the Vice President of Information Technology and Director of Information Security, in coordination with the Security Advisory Board and Cybersecurity Incident Response Team monitor the prevention, detection, mitigation and remediation of cybersecurity incidents in real time, and report such incidents to the Audit Committee when appropriate. 27

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