Vacasa, Inc. 10-K Cybersecurity GRC - 2024-03-01

Page last updated on April 11, 2024

Vacasa, Inc. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-03-01 17:19:15 EST.

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10-K filed on 2024-03-01

Vacasa, Inc. filed an 10-K at 2024-03-01 17:19:15 EST
Accession Number: 0001874944-24-000011

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity Cybersecurity Risk Management and Strategy Vacasa has developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information. Vacasa has designed its cybersecurity risk management program based upon 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, other than those required by regulation and/or contractual obligation, only that we use the NIST CSF as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business. Vacasa s 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. Key elements of our cybersecurity risk management program include, but are not limited to, the following: a. risk assessments designed to help identify material cybersecurity risks to our critical systems, information, products, services, and our broader enterprise IT environment; b. a dedicated security team principally responsible for managing (1) cybersecurity risk assessment processes, (2) security controls, and (3) response to cybersecurity incidents; c. the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security controls; d. systems, including technical, administrative, and physical controls, for protecting IT systems and monitoring for cybersecurity risks and incidents; e. cybersecurity education and awareness training of our employees, incident response personnel, and senior management; f. a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents; and g. a third-party risk management process for service providers, suppliers, and vendors. Vacasa has not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected, including our operations, business strategy, results of operations, or financial condition. We face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition. Cybersecurity Governance Vacasa s Board of Directors (the “Board”) considers cybersecurity risk as part of its risk oversight function and has delegated to its Audit Committee oversight of cybersecurity and other information technology risks. The Audit Committee oversees management s implementation of our cybersecurity risk management program. The Audit Committee receives regular reports from management on our cybersecurity risks. In addition, management updates the Audit Committee, as necessary, regarding significant cybersecurity incidents. The Audit Committee reports to the full Board regarding its activities, including those related to cybersecurity. The full Board also receives briefings from management on our cybersecurity risk management program. Board members receive presentations on cybersecurity topics from Vacasa s Vice President of Information Technology and Information Security, internal security staff, or external experts as part of the Board s continuing education on topics that impact public companies. Vacasa s management team, including the Vice President of Information Technology and Information Security, has overall responsibility for assessing and managing our material risks from cybersecurity threats. The Information Security Team, led by our Chief Technology Officer and our Vice President of Information Technology and Information Security, is primarily responsible for Vacasa s overall cybersecurity risk management program in collaboration with other key members of Vacasa s organization. Our Chief Technology Officer and Vice President of Information Technology and Information Security collectively possess experience in leading information security organizations and technical environments at public companies and in highly 53 Table of Contents regulated industries such as Financial, Healthcare, and the Federal Government.. This includes, but is not limited to, responsibility for the following areas: Information Security Audit, Security Operations, Application Security, security awareness training and education.

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