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 record of processing sits in a guided workflow with an approval step, and the things that usually live in separate files hang off it: the DPIA decision is derived automatically from risky activities, vendors link to the record with a compliance check, TOMs can be process-specific, and the deletion concept is generated from the record itself. Legal-entity counts per plan point to group use, and the package to the supervisory authority goes out with one click, "von AVV bis VVT". I found no public information on multi-client mandate work, so I stop just short of the top. 2 7 8 9