The Centre for Information Policy Leadership at Hunton Andrews Kurth published a white paper titled "Organizational Accountability in Data Protection Enforcement — How Regulators Consider Accountability in their Enforcement Decisions." The paper expands on a key recommendation in a 2018 white paper urging data protection authorities to use organizational accountability measures as mitigating factors in enforcement and takes into account a 2020 survey further exploring the issue. It identifies areas for improvement, including consistency among DPAs and transparency, and makes specific recommendations. 
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