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 In-House Counsel
The record is a connected model: processing activities synchronize automatically with the impact assessment, TOMs and service providers, impact assessments trigger from an automated threshold analysis on risky activities, and the deletion concept is generated from the record itself. With legal-basis, vendor and TOM templates created and reviewed by legal experts, more than 200 processing activity templates, and group structures scaling by legal entities per edition, this is the depth I expect; I found no public information on multi-client mandate handling, which is what would make it a full system of record. 4 7 8 9