Accountability, or the principle of accountability, is a fundamental pillar of the General Data Protection Regulation (GDPR), expressly provided for in Article 5(2) and operationalized by Article 24.
It requires the data controller not only to comply with the obligations of the GDPR, but also to be able to demonstrate this compliance at any time, especially in the event of a data protection authority audit.
This principle is concretely translated through a requirement for documentation, which relies primarily on maintaining a record of processing activities, but extends to all data protection governance actions. This includes, among others (non-exhaustive list):
- Internal procedures to govern the creation of new processing activities, including risk assessment, proportionality, and control mechanisms,
- A procedure for conducting privacy impact assessments (PIAs/DPIAs),
- Developing written data protection policies that are binding and made available to data subjects,
- Structured identification of all processing activities through data mapping or data mapping,
- Implementation of training programs for relevant personnel,
- Procedures for managing individuals' rights (access, rectification, erasure, objection, etc.),
- An internal mechanism for managing complaints,
- Procedures for notifying personal data breaches,
- Implementation of regular checks (internal or external audits) to ensure that measures are effectively implemented and functional.
Accountability thus relies on a proactive, continuous, and structured approach to compliance and constitutes the backbone of personal data governance within any organization.