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 Skeptic
The register is a real structured hub — purposes, data categories, recipients, service providers, retention periods, TOMs and responsibilities — and DPIA data is imported directly from it, with a yes/no questionnaire for DPIA necessity, an EDPB-based questionnaire and automatic risk assessment on likelihood and impact; multi-client management across borders is stated. The field list we can see names no legal bases and no systems, and group reuse beyond drag-and-drop templates is not shown, so it sits one step below the fully connected model. 1 2 6