Privacy & Information Security Law Blog

The Centre for Information Policy Leadership (“CIPL”) at Hunton Andrews Kurth LLP recently published a white paper on Organizational Accountability’s Existence in U.S. Regulatory Compliance and its Relevance for a Federal Data Privacy Law (the “White Paper”).

The White Paper looks at the origins and applications of organizational accountability in U.S. law, and concludes that accountability’s current role in U.S. regulatory frameworks lends significant support for including accountability in any new federal privacy law.

Specifically, the White Paper examines the elements of accountability as they relate to:

• The Foreign Corrupt Practices Act and the accompanying 2012 resource guide produced by the U.S. Department of Justice and the Securities and Exchange Commission;
• The Sarbanes-Oxley Act of 2002 and Chapter Eight of the U.S. Sentencing Commission Federal Sentencing Guidelines Manual;
• The U.S. Department of Justice Criminal Division Guidance on the Evaluation of Corporate Compliance Programs;
• The Federal Financial Institutions Examination Council Bank Secrecy Act/Anti-Money Laundering Examination Manual; and
• The Department of Health and Human Services Office of Inspector General Compliance Program Guidance for Hospitals.

To read more about these frameworks and their relevance to an accountability requirement in any new federal U.S. privacy law, please see the full paper.