Hey Dan, not sure if it's worth taking a look into this, but there was an interesting Listrak blog post that sounds similar to what you're dealing with right now...
http://blog.listrak.com/post/89658910575/timely-advice-from-chief-privacy-officer-james-koons
Sending an email can't really hurt since you'll be gaining explicit opt-in from people, but don't dismiss the rest of your Canadian database (unless, of course, you don't already have a business relationship with them).