CIPP/E Study Guide
Ch 6.8 - Conclusion / Accountability

Accountability and telling the principles apart

The GDPR reinforces every principle by adding accountability: it places the burden of proof on organisations to demonstrate proper implementation, and they may have to produce evidence at any time on a supervisory authority's request. This topic also drills the most-tested skill: telling the principles apart - purpose limitation (why), data minimisation (how much), storage limitation (how long), accuracy (correctness), and integrity and confidentiality (security).

Accountability is the principle that binds the others together: it puts the burden of proof on organisations to show they have implemented the principles properly, and they may be required to present evidence at any time upon a supervisory authority's request.

Distinguishing the principles - the exam's favourite trap
PrincipleCore questionOne-line meaning
Lawfulness, fairness, transparencyAre we allowed and open?Have a legal ground; be fair and clear with people
Purpose limitationWhy was it collected?Use only for specified, explicit, legitimate (and compatible) purposes
Data minimisationHow much?Collect only relevant, necessary, adequate data
AccuracyIs it correct?Take reasonable steps to keep data accurate/up to date
Storage limitationHow long?Keep no longer than necessary; then delete/anonymise
Integrity and confidentialityIs it secure?Protect with appropriate technical/organisational measures
AccountabilityCan we prove it?Demonstrate compliance with all of the above
The three that get confused

Purpose limitation = WHY (what it's for). Data minimisation = HOW MUCH (only what's needed). Storage limitation = HOW LONG (not kept too long). Map every scenario to one of these three questions.

Key terms - quick answers

What is “Accountability”?
The controller must not only comply with the principles but be able to demonstrate (prove) compliance to a supervisory authority.
What is “Burden of proof”?
Under accountability, the organisation must hold and produce evidence of compliance, on request.