Accountability has long been the subject of discussion within public administration. Especially given the potential privacy and security risks arising from rapidly changing usage of information technology (IT), it can be useful to apply this notion also in the commercial world, relating to the actions of private organisations. However, accountability may be neither a necessary nor a sufficient condition for trust. In order to provide an improved basis for trustworthiness via enhancing accountability, certain conditions need to be met. In this paper we elucidate what these conditions are and explain the related notion and importance of strong accountability. Further, we ground this analysis within the wider context of organisational ethical decision making. As a topical case in point we focus on the data protection area and the protection of personal data.