"I don't see how ICO's approval or confirmation would resolve the issue. This is GDPR not UK GDPR, so surely the stance that counts is that of the EDPB and the supervisory authority in the EU state where the processor is established?"
Fair point. I put my suggestion forward more as a way of resolving the "is it a transfer?" question.
In fact I have not yet come across any situations which worry me in practice. Everyone I have looked at could easily use an Art 49 exemption so the argument is rather academic. I am not in a "big data" scenario here
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