I’m not so sure about this interpretation. GDPR Article 3:2(a) says the regulation applies where:
Tim Boucher
21

Have a look at https://iconewsblog.org.uk/2017/08/16/consent-is-not-the-silver-bullet-for-gdpr-compliance/ — this is about ‘legitimate interest’ — If consent is not an issue, there is not an issue over how it is (not) collected.

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