This is a bit of a loaded question, so I'll give you two answers: one that I think is to the letter of the law and one that I personally would do. In general, it's definitely not too late to backfill, and I don't believe anything has changed in relation to the implied consent rules (but I could be mistaken, definitely worth reading the actual regulations again). Letter of the law version: set up a batch campaign that will only set folks who have met the implied consent requirements within the last 180 days. Do the same for your CRM report of closed opportunities in the past two years. Anyone who doesn't fall into these two groups shouldn't have implied consent marked. What I would do: follow the letter of the law version for any of your records in Canada. For anyone outside of Canada, you may or may not be following the same rules on consent, but I would enforce it as a go-forward policy unless other regulations apply. For instance, if John Doe is in my database and has never interacted with us in any way, I would not mark him as implied consent. If Sally Sue is in my database and filled out a form in 2016 (e.g. more than 180 days ago), and has not unsubscribed since, I would mark her Opt-In Date (Implied) as whatever day I'm backfilling everyone. Obligatory disclaimer that you should consult your company's legal team on all of this and I am not endorsing a specific option -- everything heavily depends on the individual business, database composition, etc.
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