Disclosure · Form 10-K · fiscal 2025
TransUnion 10-K cybersecurity disclosure (Item 1C), fiscal 2025
Filed February 27, 2026· period ended December 31, 2025· TRU· CIK 1552033· Updated · filing on sec.gov ↗· company page
TransUnion's Form 10-K for fiscal 2025, filed February 27, 2026, names the Chief Information Security Officer as its top security role, with oversight by the Risk and Compliance Committee.
- TransUnion: who leads security, and the seat's history
- How other services-consumer credit reporting, collection agencies filers describe the seat
What TransUnion's Item 1C says
TransUnion's Form 10-K for fiscal 2025 places oversight of cybersecurity risk with the Risk and Compliance Committee of the Board. The filing states that the CISO leads the Company's overall cybersecurity function.
Board and management oversight
The Risk and Compliance Committee oversees the quality and effectiveness of the information security framework, including capabilities, policies and controls, and methods for identifying, assessing and mitigating risks. The Risk and Compliance Committee also assesses the effectiveness of the company's management of information security-related risks, consulting with internal and external advisors as appropriate. The Board receives quarterly reports from the Chair of the Risk and Compliance Committee with updates on cybersecurity risk, and briefings on the cyber risk management program and significant cybersecurity incidents. Key Information Security risks are overseen by the Security and Technology Risk Committee, which escalates significant issues to the Enterprise Risk Management Committee. The STRC provides oversight to ensure key risks related to technology and information security have appropriate controls and mitigations in place. The ERMC is chaired by the Chief Risk & Compliance Officer and includes the Chief Executive Officer, the Chief Executive Officer's direct reports, other key function heads or senior subject matter experts, and the CISO. The ERMC, which meets monthly, monitors TransUnion's risk and governance policies and procedures to keep risks within the Board-approved Global Risk Appetite Statement.
Who leads security
The CISO reports quarterly to the Risk and Compliance Committee. The CISO has over 20 years' experience in the technology and security fields, including over 10 years in executive security leadership roles. The CISO has primary responsibility for leading the overall cybersecurity risk management program and supervises both internal cybersecurity personnel and external cybersecurity service providers.
How the company manages cyber risk
The cybersecurity risk management program is integrated with the overall enterprise risk management program. The company performs security testing itself and also uses third parties to test its security. The Information Security Department develops security policies, standards and procedures guided by the ISO/IEC 27001:2022 principles and aligned to the Center for Internet Security controls. The company has dedicated global incident response teams and regularly runs incident response training exercises.
Third parties and incidents
The company uses external cybersecurity service providers, where appropriate, to assess, test or otherwise assist with aspects of its security processes. The company has not identified incidents from known cybersecurity threats that have materially affected it.
What the section does not state
The section does not name the person who holds the top security role.
Read from the Form 10-K filed February 27, 2026, on . Every sentence rests on a passage of the section reproduced below.
The filing's fields, each with its sentence
Who leads security (the top role, as the filing names it)
Chief Information Security Officer
Reports to
not identified
Board oversight
Risk and Compliance Committee
“Our Board considers cybersecurity risk as critical to the enterprise and delegates the cybersecurity risk oversight function to the Risk and Compliance Committee of the Board.”
How often the board or committee hears about it
Quarterly
“Our CISO reports quarterly to the Risk and Compliance Committee and leads the Company's overall cybersecurity function.”
CISO or other person named
not identified
Frameworks and standards named
ISO/IEC 27001, CIS Controls
Where the filing names them
- ISO/IEC 27001: “Our Information Security program is led by a global-level Information Security Department that develops our security policies, standards and procedures guided by the ISO/IEC 27001:2022 principles and aligned to the Center for Internet Security controls.”
- CIS Controls: “Our Information Security program is led by a global-level Information Security Department that develops our security policies, standards and procedures guided by the ISO/IEC 27001:2022 principles and aligned to the Center for Internet Security controls.”
Outside assessors, consultants or testers
not identified
Experience of the security leadership, as stated
Stated
“Our CISO has over 20 years' experience in the technology and security fields, including over 10 years in executive security leadership roles.”
Material incident
The filing states none
“We have not identified incidents from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.”
The section
1,031 words, Form 10-K filed February 27, 2026 for the period ended December 31, 2025
Read by claude-sonnet-5-5 on October 19, 2026; every quote verified in the stored text by code.
How peers in the same industry describe the seat
The SEC assigns TransUnion standard industrial classification 7320, Services-consumer credit reporting, collection agencies (SEC SIC list). 2 other filers in our library have the same code. Also shown: filers whose codes the SEC assigns to the same review office (Office of Trade & Services).
| Filer | Top security role | Reports to | Board oversight |
|---|---|---|---|
| CreditRiskMonitor Com IncFY 2025, filed August 19, 2026 | Chief Technology Officer | not identified | Audit Committee |
| EquifaxFY 2025, filed February 19, 2026 | Chief Information Security Officer | not identified | Technology Committee |
| Filer | Top security role | Reports to | Board oversight |
|---|---|---|---|
| VIP Play, Inc.FY 2026, filed September 29, 2026 | Chief Technology Officer | not identified | full board |
| GenFlat Holdings, Inc.FY 2026, filed September 25, 2026 | Chief Executive Officer and Chief Financial Officer | not identified | full board |
| Stitch Fix, Inc.FY 2026, filed September 24, 2026 | Chief Information Security Officer | Chief Product and Technology Officer | Audit Committee |
| H&R BlockFY 2026, filed August 14, 2026 | Chief Information Security Officer | not identified | Audit Committee |
| Caro Holdings Inc.FY 2026, filed July 15, 2026 | not identified | not identified | not identified |
| Barnes & Noble Education, Inc.FY 2026, filed July 9, 2026 | Chief Information Security Officer | Chief Information Officer | Audit Committee |
Item 1C, verbatim from the filing
The text below is the Cybersecurity item of TransUnion's Form 10-K as filed with the SEC on February 27, 2026, reproduced word for word from the filing on sec.gov. Page numbers and navigation lines have been removed; nothing has been added. It describes governance as of that date.
Item 1C. CYBERSECURITY
Cybersecurity Risk Management and Strategy
We have developed and implemented a cybersecurity ris k management program intended to protect the confidentiality, integrity, and availability of our systems and information. Our cybersecurity risk management program includes a cybersecurity incident response plan. We have dedicated global incident response teams and regularly run incident response training exercises. We proactively perform security testing ourselves and employ the use of third parties to test our security as well. These are performed in the form of penetration tests, red teams and a bug bounty program.
Our Information Security program is led by a global-level Information Security Department that develops our security policies, standards and procedures guided by the ISO/IEC 27001:2022 principles and aligned to the Center for Internet Security controls. We seek to evolve our approach to protect against increasing and changing security threats around the world.
Our cybersecurity risk management program is integrated with 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 the following key elements:
• risk assessments designed to help identify material cybersecurity risks to our critical systems, information, services, and our broader enterprise information technology environment;
• monitoring and reporting of those risks to appropriate levels of management;
• a team comprised of information technology security, infrastructure, and compliance personnel principally responsible for directing our (1) cybersecurity risk assessment processes, (2) security operations processes, and (3) response to cybersecurity incidents;
• the use of external cybersecurity service providers , where appropriate, to assess, test or otherwise assist with aspects of our security processes;
• global associates with access to information technology systems in more than 30 countries and territories across North America, Latin America, Europe, Africa, India and Asia Pacific who receive a combination of general and targeted training to help keep Information Security top of mind;
• a cybersecurity incident response plan and Security Operations Center for responding to cybersecurity incidents; and
• a third-party security risk management process for key service providers based on their respective roles and risk profiles.
We have not identified incidents from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition. We face ce rtain ongoing risks from cybersecurity threats that, if realized, could be reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition. Refer to Part I, Item 1A "Risk Factors" for risks related to cybersecurity.
Cybersecurity Governance
Key Information Security risks are overseen by our Security and Technology Risk Committee (the "STRC"), which escalates significant issues to our Enterprise Risk Management Committee ("ERMC"). The STRC, which is co-chaired by t he Chief Technology, Da ta & Analytics Officer and the Chief Information Security Officer ("CISO") , is responsible for overseeing key risks related to technology and information security for the global enterprise. The STRC provides oversight to ensure key risks related to technology and information security have appropriate controls and mitigations in place. The STRC also oversees associated policies, projects and programs for enterprise risk assessments related to technology and information security. The ERMC is chaired by the Chief Risk & Compliance Officer, and includes the Chief Executive Officer, his direct reports and other key function heads or senior subject matter experts, including the CISO.
The ERMC, which meets monthly, also monitors TransUnion's risk and governance policies and procedures to ensure that TransUnion's risks remain within the Board-approved Global Risk Appetite Statement. The ERMC reviews the broader risk environment applicable to TransUnion and provides direction to mitigate (to an acceptable level) certain identified risks that may adversely affect our ability to achieve strategic objectives. The ERMC stewards our Enterprise Risk Management Policy and additional enterprise policies in risk-related areas, such as privacy and information security and key issues are reported to the appropriate committee of the Board.
Our Board considers cybersecurity risk as critical to the enterprise and delegates the cybersecurity risk oversight function to the Risk and Compliance Committee of the Board. The Risk and Compliance Committee oversees the quality and effectiveness of our information security framework, including capabilities, policies and controls, and methods for identifying, assessing and mitigating information and cybersecurity risks. The Risk and Compliance Committee also assesses the effectiveness of the Company's management of information security-related risks, including consulting with internal and external advisors as appropriate.
Our CISO reports quarterly to the Risk and Compliance Committee and leads the Company's overall cybersecurity function. The Risk and Compliance Committee receives reports from our CISO on key security topics, which may include, among other things, the cybersecurity risk landscape, our cyber risk management program activities and significant cybersecurity incidents. The Board receives quarterly reports from the Chair of the Risk and Compliance Committee with applicable updates on the Company's cybersecurity risk landscape, and briefings on our cyber risk management program and significant cybersecurity incidents. The CISO and/or the Chief Legal Officer also periodically present to the Board on cybersecurity topics that impact public companies.
Our CISO assists the ERMC in staying informed about and monitoring efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external cybersecurity service providers; and alerts and reports produced by security tools deployed in the information technology environment.
Our CISO is primarily responsible for assessing and managing our material risks from cybersecurity threats. Our CISO has primary responsibility for leading our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our external cybersecurity service providers. Our CISO has significant global experience in managing and leading information technology and cybersecurity teams. Our CISO has over 20 years' experience in the technology and security fields, including over 10 years in executive security leadership roles. Our CISO and senior members of the cybersecurity team also participate in both private and public knowledge shares, including maintaining ongoing relationships with government and non-public entities.
Earlier filings on record
Fiscal 2024 Form 10-K, filed February 13, 2025 sec.gov ↗
Top security role, as the filing names it
Chief Information Security Officer
Reports to, as the filing names it
Risk and Compliance Committee
“Our CISO reports quarterly to the Risk and Compliance Committee and leads the Company's overall cybersecurity function.”
Board oversight
Risk and Compliance Committee
“Our Board considers cybersecurity risk as critical to the enterprise and delegates the cybersecurity risk oversight function to the Risk and Compliance Committee of the Board.”
Person named in the filing
not identified
Experience, as stated
Stated
“Our CISO has over 20 years' experience in the technology and security fields, including over 10 years in executive security leadership roles.”
Material incident
The filing states none
“We have not identified incidents from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.”
Read by claude-sonnet-5-5 on October 19, 2026; every quote verified in the stored text by code.
Item 1C. CYBERSECURITY
Cybersecurity Risk Management and Strategy
We have developed and implemented a cybersecurity ris k management program intended to protect the confidentiality, integrity, and availability of our systems and information. Our cybersecurity risk management program includes a cybersecurity incident response plan.
Our Information Security program is led by a global-level Information Security Department that develops our security policies, standards and procedures guided by the ISO/IEC 27001:2022 principles and aligned to the Center for Internet Security controls. We seek to evolve our approach to protect against increasing and changing security threats around the world.
Our cybersecurity risk management program is integrated with 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 the following key elements:
• risk assessments designed to help identify material cybersecurity risks to our critical systems, information, services, and our broader enterprise information technology environment;
• monitoring and reporting of those risks to appropriate levels of management;
• a team comprised of information technology security, infrastructure, and compliance personnel principally responsible for directing our (1) cybersecurity risk assessment processes, (2) security operations processes, and (3) response to cybersecurity incidents;
• the use of external cybersecurity service providers , where appropriate, to assess, test or otherwise assist with aspects of our security processes;
• global associates with access to information technology systems in more than 30 countries and territories across North America, Latin America, Europe, Africa, India and Asia Pacific who receive a combination of general and targeted training to help keep Information Security top of mind;
• a cybersecurity incident response plan and Security Operations Center for responding to cybersecurity incidents; and
• a third-party security risk management process for key service providers based on their respective roles and risk profiles.
We have not identified incidents from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition. We face ce rtain ongoing risks from cybersecurity threats that, if realized, could be reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition. Refer to Part I, Item 1A "Risk Factors" for risks related to cybersecurity.
Cybersecurity Governance
Key Information Security risks are overseen by our Security and Technology Risk Committee (the "STRC"), which escalates significant issues to our Enterprise Risk Management Committee ("ERMC"). The STRC, which is co-chaired by t he Chief Technology, Da ta & Analytics Officer and the Chief Information Security Officer ("CISO") , is responsible for overseeing key risks related to technology and information security for the global enterprise. The STRC provides oversight to ensure key risks related to technology and information security have appropriate controls and mitigations in place. The STRC also oversees associated policies, projects and programs for enterprise risk assessments related to technology and information security. The ERMC is chaired by the Chief Risk & Compliance Officer, and includes the Chief Executive Officer, his direct reports and other key function heads or senior subject matter experts, including the CISO.
The ERMC, which meets monthly, also monitors TransUnion's risk and governance policies and procedures to ensure that TransUnion risks are within the Board-approved Global Risk Taxonomy, which is described below. The ERMC reviews the broader risk environment and provides direction to mitigate (to an acceptable level) identified risks that may adversely affect our ability to achieve strategic objectives. The ERMC stewards our Enterprise Risk Management Policy and additional enterprise policies in risk-related areas, such as privacy and information security and key issues are reported to the appropriate committee of the Board.
Our Board considers cybersecurity risk as critical to the enterprise and delegates the cybersecurity risk oversight function to the Risk and Compliance Committee of the Board. The Risk and Compliance Committee oversees the quality and effectiveness of
our information security framework, including capabilities, policies and controls, and methods for identifying, assessing and mitigating information and cybersecurity risks. The Risk and Compliance Committee also assesses the effectiveness of the Company's management of information security-related risks, including consulting with internal and external advisors as appropriate.
Our CISO reports quarterly to the Risk and Compliance Committee and leads the Company's overall cybersecurity function. The Risk and Compliance Committee receives reports from our CISO on key security topics, which may include, among other things, the cybersecurity risk landscape, our cyber risk management program activities and significant cybersecurity incidents. The Board receives quarterly reports from the Chair of the Risk and Compliance Committee with applicable updates on the Company's cybersecurity risk landscape, and briefings on our cyber risk management program and significant cybersecurity incidents. The CISO and/or the Chief Legal Officer also periodically present to the Board on cybersecurity topics that impact public companies.
Our CISO supervises and assists the ERMC in staying informed about and monitoring efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external cybersecurity service providers; and alerts and reports produced by security tools deployed in the information technology environment.
Our CISO is primarily responsible for assessing and managing our material risks from cybersecurity threats. Our CISO has primary responsibility for leading our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our external cybersecurity service providers. Our CISO has significant global experience in managing and leading information technology and cybersecurity teams. Our CISO has over 20 years' experience in the technology and security fields, including over 10 years in executive security leadership roles. Our CISO and senior members of the cybersecurity team also participate in both private and public knowledge shares, including maintaining ongoing relationships with government and non-public entities.
Fiscal 2023 Form 10-K, filed February 28, 2024 sec.gov ↗
Top security role, as the filing names it
Chief Information Security Officer
Reports to, as the filing names it
Risk and Compliance Committee
“Our CISO reports quarterly to the Risk and Compliance Committee and leads the Company's overall cybersecurity function.”
Board oversight
Risk and Compliance Committee
“Our Board considers cybersecurity risk as critical to the enterprise and delegates the cybersecurity risk oversight function to the Risk and Compliance Committee of the Board.”
Person named in the filing
not identified
Experience, as stated
Stated
“Our CISO has over 20 years' experience in the technology and security fields, including over 10 years in executive security leadership roles.”
Material incident
The filing states none
“We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.”
Read by claude-sonnet-5-5 on October 19, 2026; every quote verified in the stored text by code.
Item 1C. CYBERSECURITY
Cybersecurity Risk Management and Strategy
We have developed and implemented a cybersecurity ris k management program intended to protect the confidentiality, integrity, and availability of our systems and information. Our cybersecurity risk management program includes a cybersecurity incident response plan.
Our Information Security program is guided by the ISO/IEC 27001:2022 principles and led by a global-level Information Security Department that develops our security policies, standards and procedures. We seek to evolve our approach to protect against increasing and changing security threats around the world.
Our cybersecurity risk management program is integrated with 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 the following key elements:
• risk assessments designed to help identify material cybersecurity risks to our critical systems, information, services, and our broader enterprise information technology environment;
• monitoring and reporting of those risks to appropriate levels of management;
• a team comprised of information technology security, infrastructure, and compliance personnel principally responsible for directing our (1) cybersecurity risk assessment processes, (2) security operations processes, and (3) response to cybersecurity incidents;
• the use of external cybersecurity service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes;
• global associates with access to information technology systems in more than 30 countries and territories across North America, Latin America, Europe, Africa, India, and Asia Pacific receive a combination of general and targeted training to help keep Information Security top of mind;
• a cybersecurity incident response plan and Security Operations Center to respond to cybersecurity incidents; and
• a third-party security risk management process for key service providers based on their respective roles and risk profiles.
We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition. We face ce rtain ongoing risks from cybersecurity threats that, if realized, could be reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition. Refer to Part I, Item 1A "Risk Factors" for risks related to cybersecurity.
Cybersecurity Governance
Key Information Security risks are overseen by our Security and Technology Risk Committee (the "STRC"), which reports to our Enterprise Risk Management Committee ("ERMC"). The STRC, which is co-chaired by t he Chief Technology, Data & Analytics Officer and the Chief Information Security Officer ("CISO"), provides oversight of mitigation of key risks related to technology and information security. This oversight includes monitoring and approving relevant policies, projects, and programs for the enterprise risk assessments related to technology and information security. The STRC also serves as an escalation point to the ERMC with respect to technology and information security risks. The ERMC is chaired by the Chief Risk & Compliance Officer, and includes the Chief Executive Officer, his direct reports and other key function heads or senior subject matter experts, including the CISO.
The ERMC, which meets monthly, also monitors TransUnion's risk and governance policies and procedures to ensure that TransUnion risks are within the Board-approved Global Risk Taxonomy, which is described below. The ERMC reviews the broader risk environment and provides direction to mitigate (to an acceptable level) identified risks that may adversely affect our ability to achieve strategic objectives. The ERMC stewards our Enterprise Risk Management Policy and additional enterprise policies in risk-related areas, such as privacy and information security and key issues are reported to the appropriate committee of the Board.
Our Board considers cybersecurity risk as critical to the enterprise and delegates the cybersecurity risk oversight function to the Risk and Compliance Committee of the Board. The Risk and Compliance Committee oversees the quality and effectiveness of our information security framework, including capabilities, policies and controls, and methods for identifying, assessing and mitigating information and cybersecurity risks. The Risk and Compliance Committee also assesses the effectiveness of the Company's management of information security-related risks, including consulting with internal and external advisors as appropriate.
Our CISO reports quarterly to the Risk and Compliance Committee and leads the Company's overall cybersecurity function. The Risk and Compliance Committee receives reports from our CISO on key security topics, which may include, among other things, the cybersecurity risk landscape, and briefings on our cyber risk management program and significant cybersecurity incidents. The Board receives quarterly reports from the Chair of the Risk and Compliance Committee with applicable updates on the Company's cybersecurity risk landscape, and briefings on our cyber risk management program and significant cybersecurity incidents. The CISO and/or the Chief Legal Officer also periodically present to the Board on cybersecurity topics that impact public companies.
Our CISO supervises and assists the ERMC in staying informed about and monitoring efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external cybersecurity service providers; and alerts and reports produced by security tools deployed in the information technology environment.
Our CISO, along with the STRC, are responsible for assessing and managing our material risks from cybersecurity threats. Our CISO has primary responsibility for leading our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our external cybersecurity service providers. Our CISO has significant global experience in managing and leading information technology and cybersecurity teams. Our CISO has over 20 years' experience in the technology and security fields, including over 10 years in executive security leadership roles. Our CISO and senior members of the cybersecurity team also participate in both private and public knowledge shares, including maintaining ongoing relationships with government and non-public entities.
The fields above are exact quotes from the stored text. "Not identified" means no supporting sentence was found, not that the company has no such arrangement. A name in a filing is not a record of who holds the seat today: the Wire tracks that.
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