Probably (b). We are looking at a 2 stage notification of incidents. The preliminary form that gives the minimum information required to be given to the ICO. The preliminary form is to be sent by email to a specific monitored mailbox (by the DPO) within 48 hours of becoming aware that there has been or there is likely to have been an incident.
There is to be a later supplementary notification with more background information as to what went wrong and what has been done to prevent re-occurrence. Mainly to allow for any subsequent enquiry from the ICO.
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