Generally Accepted Privacy Principles (GAPP)

Why it Matters

Generally Accepted Privacy Principles (GAPP) help organizations structure effective privacy programs, enabling accountability, transparency, and alignment with global privacy expectations.

Key benefits include:

• Strengthen privacy governance

Establish clear accountability and oversight for personal data handling across organizational functions and third-party relationships.

• Enhance regulatory alignment

Support compliance with diverse privacy regulations by providing a principles-based framework that maps to multiple legal requirements.

• Build stakeholder trust

Demonstrate commitment to responsible data handling through transparent privacy practices that foster customer and partner confidence.

• Improve risk management

Identify and mitigate privacy risks systematically through structured assessments and controls aligned with GAPP principles.

• Support audit readiness

Provide documented privacy practices and controls that facilitate privacy audits and assessments by internal and external parties.

How it Works

GAPP is structured around ten privacy principles that define the core components of an effective privacy program: Management, Notice, Choice and Consent, Collection, Use Retention and Disposal, Access, Disclosure to Third Parties, Security for Privacy, Quality, and Monitoring and Enforcement. Each principle includes specific criteria and illustrative controls that organizations use to assess and improve their privacy practices.

Organizations implement GAPP by conducting privacy assessments against each of the ten principles, identifying gaps in current practices, and implementing improvements to meet the criteria. Implementation activities include updating privacy policies, establishing consent mechanisms, conducting privacy impact assessments, implementing data security controls, and creating monitoring and enforcement mechanisms. GAPP is often used as a foundation for SOC 2 privacy criteria assessments and broader privacy program development.

SmartSuite enables operationalization of GAPP by providing control libraries mapped to the ten principles, risk registers for privacy-related risks, and policy governance modules. Evidence collection, compliance tracking, and reporting dashboards support ongoing privacy program management and audit readiness.

Key Elements

• Management Principle

Establishes accountability for privacy policies, procedures, and oversight within the organization.

• Notice Principle

Specifies requirements for communicating privacy practices to individuals before or at the time of data collection.

• Choice and Consent

Defines mechanisms for obtaining individual consent for data collection and use.

• Collection Principle

Outlines limitations on data collection to information necessary for stated purposes.

• Use, Retention and Disposal

Establishes requirements for appropriate use, retention periods, and secure disposal of personal information.

• Security for Privacy

Specifies safeguards to protect personal information against unauthorized access, disclosure, and loss.

Framework Scope

GAPP is adopted by organizations across industries seeking to establish comprehensive privacy programs aligned with professional standards. It governs the collection, use, retention, and disclosure of personal information, and is typically implemented when developing privacy programs, preparing for privacy audits, or demonstrating privacy maturity to customers and regulators.

Framework in Context

GAPP was developed by the AICPA and CICA and provides a comprehensive framework for privacy program management. It aligns with major privacy regulations including GDPR and CCPA and is commonly used as the basis for SOC 2 Type II privacy assessments. Organizations implement GAPP for privacy program governance, regulatory alignment, and third-party assurance.

Common Framework Mappings

Mapped frameworks include: AICPA Trust Services Criteria, CCPA/CPRA, EU GDPR, ISO/IEC 27701, NIST Privacy Framework, SOC 2