Thanks Phil,
Funnily enough the trite answer is exactly what I expressed to the service area :-)
There are clear issues of transparency here which I believe is making this less than straightforward. Had the privacy notice, consent form etc all been a lot better and the contract exit strategy defined when the service was created I feel that the transfer could have been done without consent.
However, given the lack of transparency I am also of the opinion consent will need to be sought for the transfer and as you say, service users given the option to withdraw.
Thanks for the help.
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