Apologies. I only looked quickly at the PN and saw it referred to "submit anonymised workforce data" and I took that at face value.
Having read it again this is clearly not correct having regard to the level of detail.
Terrible PN - they do not even seem to know who they are collecting the data from. They use "you" indiscriminately to refer both to the submitting organisation and the data subject.
One thing is clear. There is no basis for using consent (which it refers to) as it is impossibly vague as to who the data may be shared with and rather open ended about purposes etc. Besides which as an employer you cannot get freely given consent here.
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