Right.
I think the business answer would be that we're not going to use that personal information to disadvantage you. We're going to offer you benefits. There's a new pumpkin spice latte. We're going to give you a coupon while you're waiting in line. Some people might accept that. Other people might think that's creepy. The trouble is that the first standard you mentioned in 18(1) is an objective standard. If it bothers me personally, I don't have the choice to say, “No, that bugs me personally. I don't want your coupons.” Right now, under PIPEDA the decision is more subjective and it's personal to me. I just don't give you my consent.
This flips it around backwards is what I was trying to say.