Nets Denmark A/S

Yes it is our assessment that the methodology captures all of the incidents. The criteria for classifying an incident as major are in line with Nets current criteria.
Trigger- vs. root cause
Our understanding of the section ‘4 – Incident description, subsection “Cause of incident’’ is, that it is the trigger cause of the incident that is asked for and not the root cause since that is addressed in section 8.

Recommendation: Change “Cause of incident” to “Trigger cause of incident” to define more clearly what information is requested in this section.
We suggest more clear instructions, preferably with examples to illustrate.
Initial report outside of regular business hours

Recommendation: Only send the report if the recipient of the Incident report has an on-duty resource required to initiate actions/chain of communication immediately after receiving the report (24/7). Otherwise sending the report outside of regular business hours should be postponed until the next day (start of business).

Comment: Our assumption is that the Initial report only contains the fields that are marked as mandatory, because the on-duty personnel will focus on solving the incident rather than reporting.

Deadlines for Initial within regular business hours, intermediate and final report are feasible.
It is not our impression that it is normal reporting procedure.
Yes - the procedure is aligned with normal business setup and allows a 3rd party reporting on behalf of others, thus being more efficient, increasing quality and timely response.
Nets Denmark A/S