To your question, if the $40,000 that the Canadian Marketing Association...which would be a trade association really trying to do the right thing, you can't just really wing it, because if you do, then you're subject to potentially being found to be not compliant. If the CRTC were to send back to individual organizations right away any complaint that they got, that would be an opportunity for organizations, small and large alike, to see what changes they need to make.
There are some things that a small organization would have to deal with. Once they got over how broad the definition is, they would have to look at the unsubscribe requirements. No one has an issue with unsubscribing, but we also have to add some of the managing consents, separate consents, for all the different elements. With the record-keeping obligations, which are fairly onerous, you have to be able to show at every instance which consent you're relying on and how you obtained it. There's the way they have to manage their lists. Once you have an existing business relationship, you leave.... I'm sending you emails for two years, but then after that, I have to stop because the law says to. It's all these little artificial things that get in the way of just everyday, appropriate business practices.
Those are some of the elements that small and medium-sized enterprises in particular would have to deal with.