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 Article 30 record built from templates, questionnaires or AI, an asset-and-stakeholder register with data mapping, and a questionnaire platform spanning DPIA, LIA, TIA and retention analyses form a credible core, and external DPOs get genuine multi-client steering rather than copy-paste. I found no public information on legal bases modeled inside the record or DPIA triggers derived from it, so I cannot credit a fully connected data model. 2 6 10 12