I can't speak for FE specifically but the approach you suggest seems sound.
By analogy patient surveys are conducted in NHS and the use of patient data to conduct those is not by consent, but under official authority. They have the benefit of a specific requirement in R17 (2)(a) of The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 to assess the quality of the experience of service users.
You may need to look carefully however at what you already have in place. Any options for marketing and surveys must be kept separate. If these have been conflated you may risk misleading people if they think they have opted out of all surveys and you then try to conduct one based on public task. If there is a survey opt-out it should, perhaps, explicitly exclude those.
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