> Are you arguing that if my colo provider burned down I'd need to get explicit informed consent from every user before restore a db backup somewhere else? AIU

> Are you arguing that if my colo provider burned down I'd need to get explicit informed consent from every user before restore a db backup somewhere else? AIUI, it could swing either way depending on several factors, such as: the format and usage of the data; how and where the data is transferred, processed, stored and exposed; what access and role the colo provider has (are you purely renting a dedicated server in a DC with FDE that you unlock remotely with an HSM or is the data processed by one of their managed services?); how the consent you already acquired was formulated. If the colo provider has an outsourced support engineer in Asia looking at logs/coredump or temporarily transferring a backup where the PII appears, that would constitute a transfer, for example, and full compliance needs to be guaranteed throughout. It's years since I considered myself to have a clear and deep understanding of it and it's gotten a bit fuzzy since, so someone else might chime in with a more clear answer.