A summary of a view from Europe in a similar vein:-
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A German ex-employee of a US-based multinational discovered that his HR data had been transferred between other companies within the same group, both in the US and other countries. The data contained adverse remarks about the employee's work performance, even though the company had given him a good reference.
The transfer was ruled illegal and the personal data was ordered to be deleted by all non-German members of the multinational. It also highlighted that transfers between multinational group members is not provided for in the German DPA and these are still effectively transfers to third parties. In this case, companies would need to ensure each employee consents in writing to the transfer of personal data to the group members for specified reasons.
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