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 External DPO
The dynamic VVT that auto-updates from process and asset changes, DSFA with in-system data-flow visualization, central AVV/processor management and a TOM register with authority-facing reports form a genuinely connected model — and Mandantenfähigkeit with inheritance including template tenants, rollable from a master to any number of sub-tenants, is exactly the reusable-template engine a thirty-mandate practice needs. What holds it below the top anchor: no evidence of legal-basis modeling or DPIA triggers derived from the record — the DSFA looks like a strong module, not yet driven by the RoPA. 3 1 2