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 register drives the rest, which is exactly what I want to see: automatic synchronization of the RoPA with DPIAs, TOMs and vendors, DPIA threshold analysis tied to risky processing activities, a deletion concept generated from the record, and a deep template library — over 200 processing activities, 150 vendors, legal bases under Articles 6 and 9 — that makes the work reusable. That is a genuinely connected data model. I found no public information on multi-client or mandate-level operation, which for a thirty-mandate practice is the difference between a tool and infrastructure. 7 8 9