Of course given the ICO reticence to engage with this over many years (he did once have some specific guidance - possibly long since withdrawn as he recognized it was dodgy) and COP, you could on a risk assessment basis decide to go ahead as planned, trusting that if there was ever a complaint and the ICO was (a) forced to assess and (b) pushed to concede a technical breach, he would probably decide "no further action" or at most an anodyne undertaking based on his assessment that it was all "fair". The possibility of a claim for compensation by a DS also seems remote.
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