Sagi Leizerov and Ken Askelson

The American Institute for Certified Public Accountants (AICPA) and the Canadian Institute for Chartered Accountants (CICA) have updated the Privacy Framework. The groups also decided to refer to the framework as the Generally Accepted Privacy Principles (GAPP, pronounced ga-pi).

Members of the AICPA task force that developed and updated the GAPP have presented it in pre-conference sessions during the IAPP's National Summit in March 2005 and again this year during the conference in Washington, D.C. Many IAPP members are familiar with the principles, but a quick refresher about this framework of privacy principles and criteria may be useful.

GAPP, then the Privacy Framework, was developed by the AICPA and CICA to serve as a benchmark for good privacy practices. The Framework can be used to guide and assist an organization as it implements privacy programs. GAPP contains 10 privacy principles and related criteria that are essential to the proper protection and management of personal information. These privacy principles and criteria are based on internationally known fair information practices included in many privacy laws and regulations of various jurisdictions around the world and recognized good privacy practices.

The 10 privacy principles are Management, Notice, Choice and Consent, Collection, Use and Retention, Access, Disclosure to Third Parties, Security, Quality, Monitoring and Enforcement. For each of the 10 privacy principles, there are relevant, objective, complete and measurable criteria to evaluate an entity's privacy policies, communications, and procedures and controls. The criteria can be further used by auditors to conduct and report on privacy audits. Since its release in 2003, the Framework has become widely accepted and used as the basis for independent privacy audits by several large organizations in the U.S. and Canada by commercial entities during development of products and services, and by businesses as a benchmark in creating internal privacy practices.

The New Release

Some editorial changes were made to the criteria in GAPP, but no substantive changes were made to the criteria or principle, and no new principles were added during the review.  In addition to the name change, other changes include its availability in two versions, one for business and management and another for CPAs in public practice who provide consulting and auditing services. The principles and criteria in both versions are the same, but the discussion and additional information provided are different. GAPP expands on the framework to directly address marketplace trends such as outsourcing and the growing international focus on privacy. The complexity surrounding outsourcing increases when the entity that performs the outsourcing service is in a different country and may be subject to different privacy laws or often, no privacy requirements at all. In these circumstances, the organization that outsources a business process will need to ensure that it manages its privacy responsibilities appropriately.

Since the GAPP principles and criteria are based on internationally known fair information practices included in many privacy laws and regulations of various jurisdictions around the world and recognized as good privacy practices, it may be applied globally. For example, an organization may use GAPP in completing privacy assessments (including independent audits) of an entity performing outsourcing activities for them.

The Practitioner version of GAPP for CPAs/CAs in public practice expands on various auditing considerations and provides examples of audit reports appropriate for both U.S and Canadian audit engagements. The document also provides guidance for auditors on various audit engagements for privacy.  Although it is directed at auditors, we believe many non-auditors will find this guidance helpful. If you are considering an audit in your organization, or if you know that such an audit is imminent, whether internal or external, the guidance provided in this version will be helpful and interesting.

The GAPP and You

The GAPP can help privacy professionals in many different ways. It can serve as the basis for strategic planning of privacy activities. Relying on its criteria as well as the illustrations and explanations that accompany each of the criterions, privacy professionals and management alike can identify the various steps they should take to further enhance their privacy management. Similarly, the GAPP can be used to benchmark an organization's privacy standing. The GAPP is especially helpful when conducting an internal risk assessment. The information accompanying each of the 10 principles allows organizations to assess the privacy management risks an organization faces.

Furthermore, the GAPP is equally useful as a resource for internal auditors and  external auditors.

The GAPP is the de-facto standard for auditing for privacy management. Privacy professionals who address the principles and criteria detailed in GAPP in their privacy program are likely to have a more robust and comprehensive program, making them more prepared when auditors come knocking.  

A downloadable version of GAPP, along with additional information about the development and additional privacy resources, can be found at www.aicpa.org/privacy `and www.cica.ca/privacy.

Sagi Leizerov, CIPP, Ph.D. is a Senior Manager with Ernst & Young LLP.  He helps lead the firm's Privacy Assurance and Advisory Services Practice. Leizerov is a member of the AICPA/CICA Privacy Task Force that developed and updated the GAPP.

Ken Askelson, CPA, CITP, CIA is Senior IT Audit Manager with JCPenney Company.  He also is part of the team that provides oversight for the organization's privacy program and practices. Askelson is Vice-Chair of the AICPA/CICA Privacy Task Force that developed and updated the GAPP.


If you want to comment on this post, you need to login.


Board of Directors

See the esteemed group of leaders shaping the future of the IAPP.

Contact Us

Need someone to talk to? We’re here for you.

IAPP Staff

Looking for someone specific? Visit the staff directory.

Learn more about the IAPP»

Daily Dashboard

The day’s top stories from around the world

Privacy Perspectives

Where the real conversations in privacy happen

The Privacy Advisor

Original reporting and feature articles on the latest privacy developments

Privacy Tracker

Alerts and legal analysis of legislative trends

Privacy Tech

Exploring the technology of privacy

Canada Dashboard Digest

A roundup of the top Canadian privacy news

Europe Data Protection Digest

A roundup of the top European data protection news

Asia-Pacific Dashboard Digest

A roundup of the top privacy news from the Asia-Pacific region

Latin America Dashboard Digest

A roundup of the top privacy news from Latin America

IAPP Westin Research Center

Original works. Groundbreaking research. Emerging scholars.

Get more News »

Find a KnowledgeNet Chapter Near You

Network and talk privacy at IAPP KnowledgeNet meetings, taking place worldwide.

Women Leading Privacy

Events, volunteer opportunities and more designed to help you give and get career support and expand your network.

IAPP Job Board

Looking for a new challenge, or need to hire your next privacy pro? The IAPP Job Board is the answer.

Join the Privacy List

Have ideas? Need advice? Subscribe to the Privacy List. It’s crowdsourcing, with an exceptional crowd.

Find more ways to Connect »

Find a Privacy Training Class

Two-day privacy training classes are held around the world. See the complete schedule now.

NEW! Raise Staff Awareness

Equip all your data-handling staff to reduce privacy risk, with Privacy Core™ e-learning essentials.

Online Privacy Training

Build your knowledge. The privacy know-how you need is just a click away.

The Training Post—Can’t-Miss Training Updates

Subscribe now to get the latest alerts on training opportunities around the world.

Upcoming Web Conferences

See our list of upcoming web conferences. Just log on, listen in and learn!

Train Your Team

Get your team up to speed on privacy by bringing IAPP training to your organization.

Learn more »

CIPP Certification

The global standard for the go-to person for privacy laws, regulations and frameworks

CIPM Certification

The first and only privacy certification for professionals who manage day-to-day operations

CIPT Certification

The industry benchmark for IT professionals worldwide to validate their knowledge of privacy requirements

NEW! FIP Designation

Recognizing the advanced knowledge and issue-spotting skills a privacy pro must attain in today’s complex world of data privacy.

Certify Your Staff

Find out how you can bring the world’s only globally recognized privacy certification to a group in your organization.

Learn more about IAPP certification »

Get Schooled in Privacy

Looking to get some higher-ed in privacy? Check out these schools that include data privacy courses in their curricula.

Privacy Vendor List

Find a privacy vendor to meet your needs with our filterable list of global service providers.

NEW! Raise Staff Awareness

Equip all your data-handling staff to reduce privacy risk, with Privacy Core™ e-learning essentials.

The Industry of Privacy

Take stock, compare your practices to those of other organizations, and get budget with these studies on the industry of privacy.

More Resources »

P.S.R.—One Powerhouse Program

The program is too good to miss. The speakers are world-renowned. P.S.R. brings you the best of the best in privacy and security. Don't wait: Register now!

Speak at the Intensive!

The call for proposals for our London event, the Data Protection Intensive, is now open! Submit your session idea today.

Time to Get to Work at the Congress

Thought leadership, a thriving community and unrivaled education...the Congress prepares you for the challenges ahead. Register today.

GDPR Comprehensive London: Last Chance!

The IAPP GDPR Comprehensive heads to London this fall. This is your last chance at this popular program this year!

Sponsor an Event

Increase visibility for your organization—check out sponsorship opportunities today.

More Conferences »

Become a Member

Start taking advantage of the many IAPP member benefits today

Corporate Members

See our list of high-profile corporate members—and find out why you should become one, too

Renew Your Membership

Don’t miss out for a minute—continue accessing your benefits

Join the IAPP»