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 RoPA is treated as the engine: 65-77-activity industry template packs, save-as-template and group templates, delegation to responsible users, and export as an official authority register; AVV management even auto-generates the Art. 30(2) processor register, and the Group/Whitelabel editions with 2-46 Mandanten are explicitly built for external DPOs. Below 8 because legal bases and TOMs are not evidenced as linked into one data model and DPIA triggers are not derived from the record. 4 2 3