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 Drafted Generalist
The Datenschutz module is a real connected model: VVT as a dynamic system where changes to processes and assets update automatically, DSFA with in-system data flow visualization, processor management with contracts and audits, central TOMs with authority reports, plus TIAs — and multi-tenancy with inheritance and template tenants, handles group reuse. It stops short of the top anchor: legal bases are never mentioned, and nothing shows DPIA triggers being derived from the record or audit-ready output without manual assembly. 1 2 3