This Framework sets out a multi-stakeholder governance structure, goals for collaboration, and a system of ensuring accountability. A system of independent third-party assessment of company compliance with the Principles on Freedom of Expression and Privacy and the Implementation Guidelines is being phased in over three stages:
- In Phase One (which ended in December 2010) each participating company was to establish internal policies and procedures to implement the Principles on Freedom of Expression and Privacy, and the Board was to approve independence and competence criteria for the selection of independent assessors.
- In Phase Two (2011) independent assessors were to conduct process assessments of each participating company to review and evaluate their internal systems for implementing the Principles on Freedom of Expression and Privacy.
- In Phase Three (January 2012 onwards) the Board is to begin accrediting independent assessors to review the internal systems of companies and company responses to specific government demands implicating freedom of expression or privacy. Each participating company is to submit an annual report to the Organization. The assessors are to prepare reports explaining each company's responses to government demands and evaluating the effectiveness of the company's responses. Each company is to be given the opportunity to respond to the assessor's draft and final report. The Board of the Organization is to assess whether the company is in compliance with the Principles on Freedom of Expression and Privacy and its determination is to be made public. The Board of the Organization is to publish an annual report assessing each participating company's compliance with the Principles on Freedom of Expression and Privacy.
- China, Internet Freedom, and U.S. Policy, at 18-19.