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From GAAP to GAPP: Generally Accepted PRIVACY Principles

Posted by Ken Leeser in Compliance, IT Security, Information Security Plan

November

Developed by the AICPA but applicable to all types of businesses, GAPP is designed to assist firms in creating an effective privacy program that addresses their privacy obligations, risks, and business opportunities.

GAPP can be used by organizations for the following:

Designing, implementing, and communicating privacy policy
Establishing and managing privacy programs
Monitoring and auditing privacy programs
Measuring performance and benchmarking

The privacy principles and criteria are founded on key concepts from significant local, national, and international privacy laws, regulations, guidelines, and good business practices. By using GAPP, organizations can proactively address the significant challenges that they face in establishing and managing their privacy programs and risks from a business perspective.

The following are the 10 generally accepted privacy principles:

1. Management. The entity defines, documents, communicates, and assigns accountability for its privacy policies and procedures.

2. Notice. The entity provides notice about its privacy policies and procedures and identifies the purposes for which personal information is collected, used, retained, and disclosed.

3. Choice and consent. The entity describes the choices available to the individual and obtains implicit or explicit consent with respect to the collection, use, and disclosure of personal information.

4. Collection. The entity collects personal information only for the purposes identified in the notice.

5. Use, retention, and disposal. The entity limits the use of personal information to the purposes identified in the notice and for which the individual has provided implicit or explicit consent. The entity retains personal information for only as long as necessary to fulfill the stated purposes or as required by law or regulations and thereafter appropriately disposes of such information.

6. Access. The entity provides individuals with access to their personal information for review and update.

7. Disclosure to third parties. The entity discloses personal information to third parties only for the purposes identified in the notice and with the implicit or explicit consent of the individual.

8. Security for privacy. The entity protects personal information against unauthorized access (both physical and logical).

9. Quality. The entity maintains accurate, complete, and relevant personal information for the purposes identified in the notice.

10. Monitoring and enforcement. The entity monitors compliance with its privacy policies and procedures and has procedures to address privacy related complaints and disputes.

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