The movements by national governments, funding agencies, universities, and research communities toward "open data"' face many difficult challenges. In high-level visions of open data, researchers' data and metadata practices are expected to be robust and structured. The integration of the internet into scientific institutions amplifies these expectations. When examined critically, however, the data and metadata practices of scholarly researchers often appear incomplete or deficient. The concepts of "accountability"' and "transparency" provide insight in understanding these perceived gaps. Researchers' primary accountabilities are related to meeting the expectations of research competency, not to external standards of data deposition or metadata creation. Likewise, making data open in a transparent way can involve a significant investment of time and resources with no obvious benefits. This paper uses differing notions of accountability and transparency to conceptualize "open data"' as the result of ongoing achievements, not one-time acts.
