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Intesa Sanpaolo S.p.A.

Yes, we consider that the definitions included in the draft Guidelines are sufficiently clear and we do not have any comments.
Concerning the methodology for the assessment and classification of major incidents (point 1.5 of Guideline 1 “Incident classification” and point 20 of the chapter 3.2 “Rationale”) we ask for a clarification on the rationale behind the choice of a minimum threshold of 3 criteria reaching a level 1 severity, and 1 criteria reaching a level 2 severity to classify an incident as major.
In our view, the criteria and the methodology are thorough and allow to identify and evaluate any kind of major incidents. However, please consider also our comment provided in response 2.
In our view, the thresholds should be defined in terms of parameters instead of absolute values, so that they can be better adjusted to the different operational practices. Therefore, we propose that absolute values would be used only when it is not possible to define a parametric threshold (such as, for example, for the AISPs).
We deem that the proposed template is sufficient to meet the objectives mentioned.
The instructions provided are clear and helpful to fill the template.
In our view, the drafting of the initial report shall start when the incident is classified as “major” and not when the incident has been detected (see point 2.8 of the guidelines).
We believe that the use of a delegated reporting procedure will provide added value to the market. However, at this stage we are not considering this opportunity.
We deem that the use of a consolidated reporting procedure will provide added value to the market. However, at this stage we are not considering this opportunity.
Francesca Passamonti
+32(0)26400080