Records & DPIA depth
How this is scored
The DSMS core: records of processing (RoPA/VVT), data protection impact assessments, processor/DPA management and TOMs — how deeply the legal artifacts are modeled and connected.
0 — Document templates in a folder tree; the "register" is a Word file with version numbers in the filename.
3 — A structured RoPA with basic fields and a DPIA questionnaire, but processors, TOMs and legal bases live outside the system.
5 — RoPA and DPIA as linked modules with templates; processor management and TOM assignment exist but are shallow, and group reuse is copy-paste.
8 — A connected data model — processing activities linked to systems, processors, TOMs and legal bases — with DPIA triggers derived from the record, reusable group templates, and outputs a supervisory authority accepts.
10 — Privacy records as a system of record: the RoPA drives DPIAs, processor management and TOM coverage from one data model, multi-client/mandate capability included, and the documentation is audit-ready without manual assembly.
The IT Integrator
The record is genuinely connected: the processing register holds purposes, data categories, recipients, service providers, retention periods, TOMs and responsibilities as one central hub, and the DPIA pulls its data straight from that register instead of asking for re-entry, with a yes/no screening and an Art. 35-guided assessment built on EDPB guidance. Multi-client handling across country borders is real. I found no public information on legal-basis fields or a dedicated processor/DPA lifecycle, which keeps it short of a full system of record. 2 6 1