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 Lead Auditor
The VVT is sold as a dynamic system where changes to processes and assets update automatically, with DSFA incl. in-system data-flow visualization, central processor management, TOMs with authority-customizable reports and TIA, plus template-tenant inheritance for group reuse. That is a genuinely connected model, but legal-basis linkage and DPIA triggers derived from the record appear nowhere in the evidence, so I stop below the 8 anchor. 3 4 1