1. We are immediately reviewing known contracts affected (actually only one)
2. Just in case we are contacting all managers & procurement to see if there are any they have been hiding from us!
3. We will look to change the basis, if needed, to the EC approved clauses. Since the ICO approves these (we have asked him if he has changed his mind!) this will protect us as a data controller even if it does not protect the data, as it exempts P8
4. Alternatively - as is in fact practicable on the one contract we know about as only a handful of subjects may be affected p.a. - we will use explicit informed subject consent.
5. If 3 or 4 not possible would risk assess whether we can continue at all - but this is not actually likely to be necessary - unless something dreadful has been hidden.... In which case they might keep it hidden rather than have me ban it!
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