In developing the GAPP the AICPA and CICA expanded on the framework to address risk arising from international privacy considerations and outsourcing.

“Managing privacy risk can be even a more significant challenge for organizations operating in a multi-jurisdictional environment,” says Everett C. Johnson, CPA, chair of the AICPA’s Privacy Task Force and a retired partner with Deloitte & Touche LLP. “Organizations need to be aware of significant privacy requirements in all the jurisdictions in which the organization does business. In addition, the use of outsourcing, which allows businesses to focus on their core competencies while still meeting customer needs, raises significant additional privacy considerations.”

The new GAPP document includes a section that provides step-by-step guidance on how businesses and other entities can use the document. The document references domestic and international privacy regulations, incorporating complex privacy requirements into a single privacy objective supported by 10 privacy principles. Each principle is supported by objective, measurable criteria that need to be met. Examples of policy requirements, communications and controls, including monitoring controls are provided as support for the criteria.

The AICPA and CICA tracked the impact of the 2003 policy framework and found that it had been accepted and widely used:

• As the basis for independent privacy audits by several large organizations,
  
• By commercial entities in developing products and services, and
  
• By business as a benchmark in creating internal privacy practices.

Several organizations worked in conjunction with the AICPA and CICA on the GAPP, including Information Systems Audit and Control Association (ISACA) and the Institute of Internal Auditors. A downloadable version of “Generally Accepted Privacy Principles; A Global Privacy Framework”can be can be found at www.aicpa.org/privacy and www.cica.ca/privacy.