Accountability-Based Privacy Governance
In 2011 the Center for Information Policy Leadership continued work on the Accountability Project, a collaborative initiative to develop an approach to data protection that fosters the protected, robust flow of data and that reflects the way information is collected and processed in the 21st century. This effort builds on work carried out at meetings in Ireland in 2009 and in Paris in 2010, in which the Project developed essential, commonly-accepted elements of accountability, and articulated the nature of the programs and processes accountable organizations would implement. The Project has relied upon experts from privacy enforcement agencies, industry, civil society and academia to develop consensus white papers outlining the findings of these discussions.
This year, the Centre convened meetings facilitated by the Spanish Data Protection Agency in Madrid. An additional meeting was hosted by the United States Federal Trade Commission in Washington. The Project considered the requirements and benefits of accountability when it is applied across the marketplace. It further explored under what circumstances organizations might wish to be recognized as accountable, how recognition would be attained, and what benefits might accrue to organizations that achieve recognized accountability. On November 1, 2011, the Centre released "Implementing Accountability in the Marketplace: A Discussion Document" at the 33rd International Conference of Data Protection and Privacy Commissioners in Mexico City.
Phase IV of the Accountability Project to be carried out in 2012. It will consider the infrastructure necessary for accountability to work in practice. Issues to be examined include:
- Data protection authorities' expectations of a comprehensive privacy program
- Validation of assertions by organizations responding to official oversight
- The role, authority and requirements of accountability agents.
The Office of the European Data Protection Supervisor will serve as facilitator of Phase IV of the Project.