When the participants in the Accountability Project released its discussion paper on accountability’s essential elements in October 2009, they did so recognizing that within the framework described in that document, it would be necessary to address questions about the its real-world implementation. CIPL was excited to facilitate further work on accountability, assembling experts to consider practical questions:
- How do organizations demonstrate their accountability?
- How do regulators measure it?
This document proposes fundamental conditions that accountable organizations should be prepared to implement and demonstrate to regulators. It further considers how and under what circumstances organizations would measure accountability. Participants recognized that accountability could not be a one-size-fits-all approach. For accountability to work, both organizations and regulators must be able to implement and measure fundamentals in a way that is appropriate for the organization, its business model, and the way that it collects, uses and stores data. When accountability is demonstrated and measured may depend in some cases upon the risks to individuals an organization’s activities raise.
This paper has benefited from the insights and perspectives of all sectors – industry, civil society, academia, and government. CIPL is particularly encouraged by the participation of data protection commissioners and privacy regulators from Canada, France, Germany, Hungary, Ireland, Israel, Italy, the Netherlands, New Zealand, Spain, the United Kingdom and the United States, as well as the European Data Protection Supervisor. Their active involvement highlights the significance and timeliness of this effort.