You are absolutely correct. That is what we recommended further to a research project carried out in 2004. We have always maintained this position. We favour the “opt-in“ framework, as do most of the Canadians we surveyed at the time, that is to say we believe prior consent must be given before a request for information is sent, if only for the fact that a person's email address is personal information.
I wonder how businesses will initially contact a consumer if there is no prior existing relationship. How will they access email addresses? That is what I would like to know.