I do not see this as a consent issue. As others have pointed out it may be exempt anyway but, as a data controller, having regard to the nature of the data, the purposes for which the data are intended to be processed and the risks I am quite content that USA etc. provides adequate protection.
The only live issue is fair processing and para 2(3)(d) of Sched 1 Part II . If I were (perhaps unlikely) to consider it "necessary, having regard to the specific circumstances" to tell staff what was being done that would not be difficult.
Assuming of course it is PD. I have much sympathy with the view that it is not (Durant anyone?) but accept precedent and law may be to the contrary.
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