Unmentioned assumption of normal distributed errors is pretty evil.
This is exactly this approach is worthless for rare events which by definition have very skewed distributions. In that case, probably is overestimated a lot.
On the other hand, I'd the is a rare but systematic error, the error probably will likely be grossly underestimated.
Thought experiment: suppose you're writing a long string of digits that consists of 1 followed by a large number of zeroes (say 99 for simplicity) followed by (say 10000) uniformly distributed digits.
Your writing system has an issue that changes half of 5 digits into 6. What probability of error will be estimated by this dumb method after 100th digit?
Correct bayesian approach updates the prior based on input variability keeping the error estimates high when input has low variability etc. (This can be with variance or another method.)
The even better method tries to estimate the shape of input distribution.
In other words, your result would be a difference of likelihood ratio of both input and output prior distributions (estimated to date - since no errors the ratio would be 1) minus likelihood ratio of posterior distributions.