This article examines different explanations for the cross-national diffusion of three recent innovations in bureaucratic accountability-the institution of the ombudsman, freedom of information legislation and data protection (information privacy) law. The first two explanations a-re based on the assumption that these innovations are by-products of modernization, either the growth of the state or democratization. The third assumes that policy is shaped through processes of international communication A combination of methodologies is employed to conclude that while the growth of government and liberal democratic values are necessary conditions for the adoption of all three policy instruments, they are not sufficient conditions. The pattern of adoption observed is best explained by examining how evidence about these respective policies flows from adopting states to non-adopters. In the case of the ombudsman, this process can be characterized as one of lesson-drawing; for freedom of information, evidence is used for legitimation purposes; for data protection, the diffusion is attributable to harmonization through international organizations. Policy transfer is hence a multi-faceted concept that embraces a number of distinct processes of transnational learning and communication.
