Yes. There's no question that Bill C-11 is a comprehensive and serious attempt to address privacy issues in the digital world, but at the most general level, we think that in order to provide adequate protection for privacy, the bill needs very significant changes.
Why? In part it's because we think that even though there are provisions on consent in Bill C-11, the ultimate impact would be less control for individuals, in part for the reason you suggest, that a requirement in the current law that individuals, consumers, understand the consequences of what they are being asked to consent to does not exist in Bill C-11 as drafted.
There are also important exceptions to consent in Bill C-11, some of which are appropriate but others much too broad. For example, there is an exception to consent where it is “impracticable” to obtain consent. We think that such an extremely broad exception to consent makes the rule hollow—so less control for individuals, more flexibility in Bill C-11 for organizations. We're not against additional flexibility for organizations per se, particularly when organizations want to use personal information for the public good or for a legitimate public interest, but we think additional flexibility should come with additional accountability.