Nick Martin's Marketing Pages

Questionable ethics of data collection

Who is collecting data on behalf of 'The British Consumer' using offshore call centres? Despite being on the UK's Do Not Call List, The Telephone Preference Service (TPS) for 3 years, I'm getting duplicate calls from an offshore call centre requesting permission to undertake a 'survey' on behalf of this dubious entity.

Various tactics are being employed, from a request to verify address and telephone details before launching into a lifestyle questionnaire - and including one that promises to ensure that your details are taken off our list before then saying we'd just like to verify the details we hold about you and your household.

Either no record is maintained of previous contact or they just aren't bothering. All part of a truly low-cost, low-ethics exercise...

One can easily see how hundreds of thousands of consumers are surely being duped by these approaches, that seriously misrepresent, flout TPS regulations by calling under the guise of research when what they are doing is data gathering (but clearly not market research), and damage consumer confidence.

When I pushed representatives to disclose which legal entity they were calling on behalf of, the phones were put down. So they might be naive enough to call repeatedly in spite of several bruising encounters, but not that naive! 

Here's the thing; if data collection goes down an ethical slippery slope in pursuit of the lowest cost collection, campaign performance will follow. Not only that, execution comes with hidden costs arising from higher than average complaint rates. All of which feeds into a negative cycle of brand perception, at a time when reputation and trust is more important than ever.

Among other parameters, being able to provide a simple audit trail to complainants in respect of their personal information when asked, helps allay concerns and restores trust. Transparency is more important than ever, and practitioners using poorly acquired and badly permissioned data run greater reputational risks than ever before.

Dutch Require Consumer Consent to Put Cookies on PC - WSJ.com

The Dutch Parliament passed a law Wednesday that forces websites to get explicit consumer consent before they place small text files known as cookies on a computer. The new law was opposed by the online-advertising industry, which fears the legislation will pave the way for similar moves across Europe.

EU officials have said they probably won't challenge the Dutch law, indicating it is unlikely to be overturned and suggesting that industry may have a bigger fight on its hands than it feared.

In November 2010, the EU passed a directive requiring online advertisers to get "informed consent" from users before placing cookies on their computers. Under EU treaty law, countries then had until May to write that rule into their national legislation, but there has been some confusion about exactly how the language had to be interpreted.

"The Dutch law is an important case study because it's such a big market," said Kimon Zorbas, vice president of the Interactive Advertising Bureau Europe, which represents online advertisers. "We would expect companies from our sector to either move their operations to neighboring countries or lose their clients to companies located elsewhere in Europe."

Online advertisers are up in arms. An increasing number of ad campaigns are dependent on cookies, which store data on users and their viewing habits, and the business model could be crippled, they say. "Fifty percent of campaigns in euro volumes might be shut down," said Stephan Noller, chief executive of nugg.ad, an online-advertising consulting company.

In the Netherlands, publishing companies lobbied furiously against the bill, arguing the law exceeds the EU mandate because it includes a provision that websites must prove they have received permission from users to place cookies on their machines. One news portal called nu.nl said it might disappear entirely.

EU regulators will now "carefully assess the Dutch legislation to verify its compliance with the e-privacy directive," said Jonathan Todd, a spokesman for Neelie Kroes, the EU's commissioner for the digital agenda. EU officials in Ms. Kroes's cabinet say they believe the Dutch law is in the spirit of the EU requirement for "informed consent."

That could be bad news for the online-ad industry, because the EU is committed to harmonizing rules. "We all stand to lose from fragmented rules," said Ms. Kroes, speaking Wednesday afternoon in Brussels at a conference on online legal issues.

via online.wsj.com

With the highest broadband penetration in Europe, marketing practise and spend that has migrated substantially online, this news reported today in WSJ, threatens online behavioural advertising in the Netherlands, and might prove to be a key case point of influence for Eastern and Southern EU States in their own local interpretations of the EU Directive, whilst expanding the market opportunity for competing marketing methods that can target and personalise in real-time. Today the Country of Origin principles that exist within the EU permit multinational organisations to move their operations when local laws are not to their taste; but what happens if and when this basic principle is changed to require conformance to Country of Destination laws?

PETs to the rescue of OBA?

Industry presented plans for self regulation to the European Commission last month , following a public statement by Commissioner Neelie Kroes, in which she established clear benchmarks that a self-regulatory instrument would need to meet in order to be deemed acceptable and sufficient by the Commission.

These are:

1. Effective transparency (paramount). This means that users should be provided with clear notice about any targeting activity that is taking place.

2. Consent, i.e. an appropriate form of affirmation on the part of the user that he or she accepts to be subject to targeting.

3. A user-friendly solution, possibly based on browser (or another application) settings. Obviously we want to avoid solutions which would have a negative impact on the user experience. On that basis it would be prudent to avoid options such as recurring pop-up windows. On the other hand, it will not be sufficient to bury the necessary information deep in a website’s privacy policies. We need to find a middle way.

On a related note, I would expect from you a clear condemnation of illegal practices which are unfortunately still taking place, such as ‘re-spawning’ of standard HTTP cookies against the explicit wishes of users.

4. Effective enforcement. It is essential that any self-regulation system includes clear and simple complaint handling, reliable third-party compliance auditing and effective sanctioning mechanisms. If there is no way to detect breaches and enforce sanctions against those who break the rules, then self-regulation will not only be a fiction, it will be a failure. Besides, a system of reliable third party compliance auditing should be in place.

During the round table, Robert Madelin, Director General of DG INFSO, clarified that the Commission position is in favor of an opt-out approach for cookies. He also clearly stated that profiling is an appropriate tool for marketing purposes and that its use both online and offline needs no distinction. Finally, the Commission stated its interest to find the right balance between data protection and the legitimate interest of data processing for a balanced economy. 

This is good news, and takes us back to the fundamentals of the European Data Protection Principles. Those principles (subject to a EU statutory refresh of the legislation) should be applicable irrespective of channel or marketing application. 

Enter stage right, Microsoft announced its plans to roll out the functionality to block all online tracking as part of its new Internet Explorer 9 (IE9). This announcement, whereby the new IE9 will feature an "opt-in mechanism" and "tracking protection lists", comes only days after the publication of a report on the protection of online privacy by the US Federal Trade Commission (FTC). In its report the FTC prominently calls for industry to provide internet users with a functionality to block online tracking activities, often referred to as a "do-not-track list" (similar to a do-not-call register).

Mozilla are also known to be working on a do not track technology by 'cloaking' the user's internet activity, though they are citing technological difficulties.

In responding to the latest FTC concerns that current tools for blocking online tracking are blunt instruments, Microsoft may nonetheless have gone too far in proposing 'opt-in' for behavioural tracking, (depending on how the technology worked in practise and what they mean by opt in). 

Read more: http://online.wsj.com/article/SB10001424052748704594804575648670826747094.html#ixzz1AoD0nIJm

UK freezes in face of new ePrivacy Directive: Respond to the Consultation

The UK Department for Business, Innovation and Skills (BIS) has just published a public consultation on the implementation of the revised EU Telecoms Package. 

The Telecoms Package, a set of five directives that regulate the electronic communications sector in the European Union, contains the so-called e-Privacy Directive. As part of the review, the existing opt-out rule for the use of browser cookies, which are widely used to deliver targeted marketing messages on the internet, was replaced by a requirement to collect the consumers' "consent". This ambiguous wording leaves it up to national governments to clarify whether they interpret "consent" to mean "prior opt-in consent", or whether they prefer to stick with the existing "implicit opt-out consent" rule.

BIS proposes to implement the relevant parts of the Directive by copying the exact wording into the new, national law - without clarifying whether "consent" is to be interpreted as an opt-in or opt-out approach. In practice, this would mean that the exact meaning of "consent" is to be interpreted by the data protection regulator, the UK Information Commissioner's Office (ICO).

According to Outlaw.com, BIS recognises the importance of cookies (AKA targeting) to make the Internet work and deliver value to users:

 "The internet as we know it today would be impossible without the use of […] cookies," says BIS. "Many of the most popular websites and services would be unusable or severely restricted and so it is important that this provision is not implemented in a way which would damage the experience of UK Internet users or place a burden on UK and EU companies that use the web."

"The Directive acknowledges this by saying that consent is not required when the cookie is strictly necessary to deliver a service which has been explicitly requested by the user," it says.

BIS goes on to say that since the range of uses where a cookie is strictly necessary to deliver a service online are impossible to define due to the fast moving nature of the Internet, and therefore it will be down to the Information Commissioner's Office (ICO) to interpret the Directive in practise.

The risk, and likely outcome of this tactic, is that any degree of certainty around the use of 3rd party cookies for online targeted advertising, or online behavioural advertising, gets kicked into the long grass until next spring 2011 by which time the ICO will be forced one way or another to declare its hand. 

In the meantime, we await the moment that some EU member states will no doubt feel compelled to be more forthcoming - and give their view on what constitutes personal data; the weight they will give to Recital 66 (non binding guidance that suggests browser settings could constitute an affirmative consent mechanism), and illuminating examples of application areas that are to be construed to need cookies to deliver a service.

Imagine a scenario where every member state interprets the e-Privacy Directive differently. Now combine that with a further scenario which obliges business to apply country of destination laws to their online activities (instead of country of origin laws) and you end up in with an almightly mess. This, I'm afraid to say, is exactly the scenario we are about to face in reality.

That's why it's important to participate in BIS's Consultation, specifically responding to the impact assessment questions.

BIS Consultation is open until December 3rd. You can respond with your point of view and any evidence via this link or directly online via BIS's Survey Monkey. Don't just listen to the debate, submit your view to the UK Government and help legislators understand the impact of a literal implementation of the ePrivacy Directive.  

Spying for Secrets?

Late last year the European Parliament and Council set the scene for a potentially dramatic challenge to the way online advertising is developing, enabling targeting of advertising content based on online activity collected via cookies.

Online behavioural advertising  (OBA) uses  information  to  target  the consumer with advertising messages  that  match  their  interests and presumed buying intentions.  Information derived from online activity determines what ad or what version is served to whom (or not), dramatically improving targeting and reducing wastage.

OBA is a game changer, improving the consumer experience, cutting out irrelevant content, and delivering a better marketing return to brand owners.

As well as agreeing a revision of the EU Telecoms Package - designed to update the legal framework for the telecommunications sector – in slipped an e-Privacy Directive that requires consent prior to the setting of cookies on a web browser.  EU member states have until next May to implement the package.

At the EU-level, MEPs claimed success in introducing an opt-in regime; industry and some national governments maintain that the wording implies keeping the opt-out. This leaves it to the national governments to specify the meaning of “consent” when implementing the Directive. Plus ca change, and a recipe for wildly differing local implementations as we already have seen with the original Data Protection Directive, where they range from explicit prior consent to implied consent and soft opt-in for customers.

Against this backdrop the Article 29 Working Party published their opinion in the summer. It appears to significantly extend the definitions of personal data and comes down heavily in favour of explicit, prior consent prior to the collection of behavioural online data via browser cookies.

 1. That Article 5.3 of the ePrivacy Directive (the basis for setting and accessing cookies on a browser) applies irrespective of whether the information constitutes personal data or not.

 2. Where the tracking process involves personal data, the relevant provisions of the general Data Protection Directive have to be applied as well such as subject access rights. 

 3. That tracking usually involves personal data, because the cookies contain a unique identifier, or are linked to an IP address, which either identify a data subject or relate to them.

 4. Any party that stores or accesses a cookie must collect the user’s consent, regardless of whether this party acts as a data controller or as a data processor. In the case of 3rd party OBA this obligation falls to the ad network provider.

 5. The opinion stresses that consent, which must be freely given and specific, needs to be obtained before the cookie is stored. In order for consent to be valid, highly visible information must be provided. Information about the use of cookies also needs to be provided prior to the processing. In order to collect valid, informed consent, the working party recommends that ad network providers create prior opt-in mechanisms that require an affirmative action by the data subjects. Once given, it would not be necessary to request consent for each reading of a cookie.

 All this begs the question, how clearly do legislators really understand the use of anonymous cookies in 3^rd party OBA?

How would subject access requests work in the situation where vast number of cookie IDs containing recent behavioural data used in raw or aggregated form for advertisers from different sectors, nonetheless contain no personal data?

Do legislators really think that cookies are used to spy on consumers? Is there a common (mis)understanding of the benefits cookies offer to faster navigation and better user experiences, delivery of more appropriate offers, and data transparency?

The political dimension isn't helped of course when Wall Street Journal publishes an ‘expose’ on how tracking technologies are designed to share consumers’ secrets.

The WSJs investigation found that the nation's 50 top websites on average installed 64 pieces of tracking technology onto the computers of visitors, usually with no warning. A dozen sites each installed more than a hundred. The nonprofit Wikipedia installed none.

Tracking technology is getting smarter and more intrusive, they concluded.

“Monitoring used to be limited mainly to cookie files that record websites people visit. But the Journal found new tools that scan in real time what people are doing on a Web page, then instantly assess location, income, shopping interests and even medical conditions. Some tools surreptitiously re-spawn themselves even after users try to delete them.”

It’s time to address key concerns of user protection and security, in applying key principles of Data Protection to these burgeoning, global advertising channels.

a) For example, surely we should be insisting that a broad definition of sensitive data be used to ensure that offers such as dietary plans ought to be subject to explicit consent.

b) Deep Packet Inspection (DPI) has caused deep concerns for years, gaining Phorm notoriety, enabling an ISP uses technology to inspect the entire clickstream of a browser, and inevitably will end up subject to an explicit consent regime.

c) Where personal information that identifies a user by name, sex, age, household composition etc. is combined with online behavioural data, the use of that ensuing personal profile ought to be notified as a specific and fresh use requiring consent.

d) Certain uses of non-personally identifiable data collection may need to be proscribed such as using tracking to support discriminatory pricing, an issue of concern to legislators.

e) Lastly, Privacy Enhancing Technologies (PETs), overlooked beyond the basics such as SSL security over the last decade, may well be about to come of age, faced with an internet-wide challenge of incomparable commercial scale.

     

Technologies that separate data, that anonymise through splitting or masking and destroy personal data, as well as those that limit use are urgently needed to demonstrate users can be exceptionally well protected at the same time as experiencing the benefits of OBA.

As the market for well-executed OBA starts it’s long road towards maturity, organisations that aggregate user behaviour data are perfectly placed to apply these technologies to their platform, and must prepare to play their forthcoming role of responsible and respected data controllers.

For now the focus is on cookies. Browser settings do at least currently provide a consumer dashboard to express preference. In a recital to the e-Privacy Directive, non-binding guidance suggested that browser settings would indeed serve as a consent mechanism, which was interpreted as a pointer towards an opt out regime.  Whilst on the face of it, the Working Party’s guidance blows that interpretation out of the water, no one should conclude that that is the endgame.

This winter looks set to be one of the most significant in the history of the Internet.

Thanks to FEDMA for providing access to many of the source material used for this article, and from which I have borrowed.

The price of customer engagement

How many consumers start a transaction, only to drop out before agreeing terms or completing payment?

The truth is, winning the attention of consumers - then proving the value of your product or service in an increasingly frictionless environment - is tougher than ever.

In a recent consumer survey by Fastmap, a third of all people visiting financial services websites or dialling into a call centre found the experience confusing, whilst a further third would have appreciated a more skilled advisor.  That makes two thirds of consumers who might have bought a financial services product may not have done as a result of an inadequate user experience.

There is of course a broad range of reasons why people abandon a transactional process. Shipping charges and price comparison browsing are commonly quoted. Notwithstanding, understanding the avoidable barriers that dissuade buyers from following through with a purchase is key to improving the consumer engagement.

Established agency solutions to winning those consumers back who have dropped out of the online sales funnel includes retargeting – the process of serving ads via a network following, for example, basket abandonment on destination sites and portals.  

The trouble is, using browser data for retargeting falls under the broad category of online behavioural targeting (OBT), the recent subject of the EU Article 29 Working Party. Their published opinion does not augur well for the future of any kind of third party OBT marketing activity; even where browser based cookies do not hold any personal data.

To quote an excellent summary and initial analysis by FEDMA:

In the view of the Working Party (WP), the revised ePrivacy Directive (as a part of the reviewed Telecoms Package) reinforces the requirement to collect “informed prior consent” as an adequate legal basis for 3^rd party OBA. The opinion stresses that consent, which must be freely given and specific, needs to be obtained before the cookie is stored. In order for consent to be valid, highly visible information must be provided. Information about the use of cookies also needs to be provided prior to the processing. In order to collect valid, informed consent, the WP recommends that ad network providers create prior opt-in mechanisms that require an affirmative action by the data subjects, indicating their willingness to receive cookies and to the processing of these cookies for the purposes of delivering targeted advertising.

 So is now the time to look beyond online consumer activity and implying conclusions about habits and purchasing needs through behavioural analysis, notably in regard to acquisition marketing?

There is undoubted value in responding in real-time to consumer confusion or questions that demand a degree of expert knowledge and a consistent approach.

 Call Me buttons that route users to an off-line call centre, or Agent Chat programs that enable you to connect with a call centre are both important ploys to handle questions and improve conversion to sale. Their weakness is in the depth of knowledge of the call centre agents. Many times I have sought help, only to discover I know more about the product or service I wish to purchase than the agents on the other end of phone.

 Part of the answer surely lies in the creation of a really effective company knowledge base.  With this in place, it becomes possible to accurately respond to questions & obstacles to sell in real-time. Translating the product and service value proposition, together with detailed practical and operational information (e.g. delivery options) into a knowledge base needs to be a core building block of online marketing.

Currently this information is hopelessly fragmented across the majority of organizations and therefore is impossible for its customers to access. As a consequence, when IKEA implemented a rudimentary, cartoonish avatar on their site, its ability to answer questions effectively was severely limited.  On a recent visit it was unable to answer any of the questions my wife posed.  Needless to say, the impact is lost business.

Once the creation of the knowledge base is undertaken, it can be turned into consistent, accurate dialogue with consumers via enabled call centres, online avatars and drive social media conversations.

Recent experiences of avatar deployment have delivered astounding results, for example improving quote to book ratios by 300%+ in France, proving that there’s no help like real time help, as long as it’s delivered with the requisite level of expertise.

In an increasingly unforgiving, socially networked world, knowledge and the ability to apply it in real time must be a core business competency. It is up to marketing to seize ownership.

Email marketing on a wing and a prayer

Email marketing is poised for strong growth this year at the further expense of traditional offline channels. 

Having recently completed the survey analysis and report for FEDMA, here are some key excerpts. You can purchase the full report from FEDMA here.

In FEDMA’s first European Email Marketing Benchmark report published in April 2010, 19% of the respondent Email Service Provider (ESP) base expected their clients to increase volume of email marketing between a quarter and a half year on year; a continuation of the shift from offline to digital channels.

Hardly surprising when you consider the results of the Ipsos Mori poll for the Chartered Institute of Marketing’s report,The Shape of Digital to Come?. The question was asked which activities delivered the best return on investment. Top of the charts came CRM by some margin, followed by online advertising (12%) and email marketing (11%). Those activities considered to deliver the worst return were direct mail, sponsorship, and internal marketing, mirroring the evident shift in spend.

Econsultancy’s Email Marketing Census 2010 also predicts a net increase in email marketing over the course of the year, with the greater proportion coming from retention marketing, where 71% expect to ramp up their activities in this area, and only 1% expect to reduce activity on email marketing activity to their customer base. This reflects a growing recognition that email marketing is the perfect medium for customer management and development, and a key component within integrated multi-channel consumer engagement.

To that end, newsletter and related customer management activity is likely to be a key growth area over the next 12 months. This is reflected in the difference in click through rates reported in FEDMA’s Email Marketing Benchmark Report 2010 between newsletter and sales or product/service information campaigns, which average 17% higher. 

Practitioners need to plan use of email marketing more strategically to gain greater payback from ongoing customer engagement and the up and cross sell opportunities arising.  For example, 53% of respondents to FEDMA’s report do not use email marketing for customer or product (development) surveys. Where they do, they experience excellent results.

The majority of companies do not use email marketing for win-back campaigns following the loss of customers. The minority of respondents who do use email for win back see conversion to sale or action of between 2% and 5%. Nor do they systematically use transactional emails for cross and up selling.

In both cases here are clearly opportunities missed, which once again suggests that email marketing is deployed typically as a series of standalone activities, in some cases integrated with online and other channels, but generally not implemented as an end-to-end programme or integrated with other customer channels.

Whilst end users overwhelmingly believe email marketing to be strategically important, that belief is yet to translate into a rigorous approach around execution.

  Poor visibility of conversions to sale and conversions to action, and the lack of testing around aspects such as creative templates and frequency suggests there is much more critical measurement and insight needed. Practitioners would do well to test more rigorously each element of an email campaign, beyond the generally adopted focus on subject lines, sender name, time of day and week, and spam filter scoring. 

Continued growth may well be anticipated and planned for by the majority of respondents, but it should not be assumed at any cost. The future growth – and health – of email marketing will depend on some key factors:

 

• Better targeting, measurement and the use of properly permissioned and managed customer information databases and lists; the relevancy of campaigns and careful application of local/ EU laws.
• Careful stewardship of customer information, and developing its use further into the consumer/ buyer engagement process. The impetus to increase volume and activity can only be successfully achieved where it remains engaging.
• Delivery to inbox, which will be increasingly seen as a barrier to overcome, especially in B2C.

Whilst Deliverability rates are optimistically expected to improve or remain the same, this raises a key question of how deliverability is measured.

Most practitioners will determine deliverability as delivery to Internet or to mail server as the primary measure, but delivery to inbox or Inbox Placement Rate (IPR) is being seen as an increasingly key metric. 

IPR is tied in with reputation. If reputation is poor, acquired through issues like indiscriminate use or poor targeting, large groups of consumers belonging to the same ISP domain, for example, such as GMail or Hotmail will not receive bulk email from that source into their inbox. It is estimated as a much as 7% of email marketing campaigns go missing, which historically has not been accounted for. 

Marketers need to understand what their reputation is, and much in the same way they work to improve their click through rates, they need to monitor, manage and improve their reputation. If ISPs migrate from identifying sender by IP range to identifying the sender by their domain name, as some commentators believe may have already started to happen, this issue could become even more significant.

EU Commissioner lines up Google and Facebook for affirmative action

Fresh to the data protection portfolio at the European Commission, Vice President Viviane Reding has Google and Facebook in her sights.

The issue? Online Behavioural Marketing (OBM).

Underlying the problem is the principle of Fair Processing, that together with Notification form the essential twin pillars of data protection law in Europe.  Hitherto, 'term of use' clauses or privacy statements buried in site terms & conditions that visitors rarely read, have enabled brands to capture personal information and use it for whatever purposes those terms specify.

That could well change under a proposed review of fair processing law when tied to unfair contract terms.

Objections to Google's use of  are ads served that reflect your email traffic in GMail. Whereas users may well generally see benefit in receiving ads that reflect their real-time interests, what about the user communicating via GMail with his wife about a break-up, only to be served marriage counselling ads? The line between value and intrusion or outrage is not always obvious to a rules-based decision engine.

This is likely to be just one challenge to online targeting from legislators who have become increasingly dubious of self regulation.

Forces Of Hell unleashed as Italian court sanctions Google

An Italian court in Milan has found three Google executives guilty of privacy violations, convicting them to suspended six-month sentences. The Google employees were sued over a video posted to Google in 2006, showing four youths bullying a kid with Down syndrome.

It seems to me there are three points that this ruling highlights. Firstly, should user-generated content be policed by  service providers? Secondly, should the onus be on them to act upon user complaints? Thirdly was the punishment fair?

Though I self-classify as a liberal, I found myself shocked by the  reaction of supporters of unfettered rights to publish any user-generated content on the internet, no matter how shocking or reprehensible. 

Prosecutors successfully accused Google of negligence,  saying the video remained online for two months even though some web users had already posted comments asking for the video of the down's syndrome child being bullied by four classmates at a Turin school to be taken down. Google did act swiftly as soon as they were notified of its existence by Turin police.

Sentencing executives for vicarious responsibility over content posted by others may seem extreme, but what about this point?: " A company's rights cannot prevail over a person's dignity. This sentence sends a clear signal," public prosecutor Alfredo Robledo told reporters outside the Milan courthouse.  

There are precedents: don't forget ebay monitor auctions to ensure that certain items are not sold online, such as Nazi war memorabilia or human organs  .

In Europe the Human Rights agenda is gathering pace. This has far less in my view to do with state censorship and conspiracy theories inspired by Silvio Berlusconi, and more to do with a set of emerging beliefs that service providers must take responsibility for content, and that commercial rights cannot override consumer rights at any cost.

I do not buy the argument that the judgment ' attacks the very principles of freedom on which the internet is built'. Lazy liberalism isn't an answer to the question of whether content should be policed, and if so how? Community is a powerful answer. Community is very good at judging content against societal moral standards. Social media owners have a responsibility to use it. Whether they like it or not, an element of judgement reflected in basic rules is unavoidable.