Sometimes - it depends.
The loss would be logged via internal incident management system as soon as reported and assessed.
Part of that assessment would be to look at usage. If there was any evidence of use since user could last account for the card it could very well reach level 2 - depending particularly on user access profile since it is at least possible that some users in fact have no access to personal data systems. However if it was clear card had not been used between last accountable use and cancellation the incident would be unlikely to reach a level 2 score.
An interesting aspect from my initial thought is whether in taking into account "one or more previous incidents in last 12 months" you count all losses within the organisation or only losses by the particular user. IMO just the user - that indicates a risk you need to address. If you take the organisation there is a totally arbitrary factor - size of organisation.
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