There are individuals within businesses who are having trouble understanding it. Mr. Sookman described this fairly explicitly in a previous question, but essentially, you have multiple layers of text that you need to be able to follow. The act is very prescriptive, so you need to follow it very closely. Then you need to follow the regulations that came through Industry Canada. You need to pay attention to the CRTC regulations, to what the Competition Bureau has put out in terms of guidance, and to what the Office of the Privacy Commissioner has put out in guidance. You need to read the regulatory impact statement to get some understanding or context of why the law is there in the first place. Then you need to read the guidance from the CRTC, which in many cases hasn't been that helpful, because it doesn't give you a lot of guidance.
The problem is that the CRTC is both the enforcement agency and the guidance agency. The challenge for businesses in going back to the CRTC for guidance is that as soon as they open the door to say they have a problem, it opens the door to an investigation.
From a business person's perspective, if you are a small business and you have four or five employees, you as the business owner are likely the person who's going to be responsible for figuring out how to comply with this at the same time as running your business and dealing with all the other regulations that come across your plate.
When we're saying they're having difficulty complying.... They're having difficulty understanding the definition of a CEM, why they can't send a message to their neighbouring business saying, “Let's go for coffee.” They don't understand it.