Thanks for this Tim.
May I add that "Just" Get Permission can also be related to the number of
times an organisation might be faced with transfer rather than just
organisation size.
I am aware of two occasions when this Council has been faced with transfer
of personal data outside the EEA. One was an adoption case where the family
concerned came from another country originally and the other involved a
council tax payer working overseas who wanted communications sending to his
overseas address rather than the address on which he paid the tax.
In both cases consent of the data subject was both easy and appropriate to
obtain in order to process the data lawfully.
As you say, different sized shoes fit different feet.
Graham
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