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Data Protection

DATA FIRST Datenschutz-Software

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Panel rating · 6 judges · How to read the stars

Category median

Sovereignty: not determined

0–5 in half steps. 5 means the rubric's top anchor is met on the evidence.

by DATA FIRST · datafirst.de

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Read this page as one judge. Each weighs the same scores by what they care about.

The Skeptic

Weighted verdict

Hunts certification logos that link nowhere, "AI-powered" features with no substance behind them, consulting bundled as software, legal-update promises with no named lawyer, and customer counts that disagree between pages. Exists to keep the rest of the bench honest.

Same scores as the panel view — this lens weights them the way this judge cares.

Scored by The Skeptic

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.

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The Skeptic

The lone capture is a domain-transfer listing operated by a brokerage, not product documentation, and we found no public information on records of processing, DPIAs, processor management or TOMs. Nothing in the evidence shows a register of any kind, let alone a connected data model, so the score sits at the bottom of this criterion. 1

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Data subject rights & incidents

How this is scored

The operational half of the DSMS: data subject request handling with statutory clocks, breach register and authority notification, deletion concepts that actually delete.

0 — Requests arrive by email and live there; breaches are a phone call and a memo.

3 — A request log and a breach list exist, but deadlines are manual, intake is unstructured, and deletion rules are documentation rather than workflow.

5 — DSR workflows with the Art. 12 clock tracked, structured breach register with the 72-hour clock, deletion concepts assignable to records; automation is reminders.

8 — Intake channels for requests (portal/form), identity-check support, deadline automation with escalation, breach severity assessment and authority-report output, deletion rules tied to the RoPA with execution tracking.

10 — Rights and incidents as operations: end-to-end request handling an authority audit walks through, breach workflows that produce the Art. 33 notification, and deletion automation with evidence that the deletion happened.

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The Skeptic

We found no public information on data subject request handling, deadline tracking, a breach register or deletion workflows. The only time-based operational claim anywhere is the brokerage's 'average turnover time is only 24 hours', which concerns transferring a web address, not statutory clocks. 1

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Privacy regime coverage

How this is scored

Which privacy regimes the product actually operationalizes — GDPR, BDSG, Swiss nDSG, UK GDPR, ePrivacy, EU AI Act privacy duties — and whether one record maps across them or each regime is a fresh island.

0 — One regime, hard-coded; anything else is "on the roadmap".

3 — GDPR plus one national law as separate checklists; the same processing activity is documented once per regime.

5 — The major regimes for its market with partial cross-mapping; newer duties (AI Act, ePrivacy changes) present as content packs of varying depth.

8 — Broad current coverage with one-record-many-regimes mapping and visible maintenance as regimes evolve.

10 — Regime coverage as a living product: multiple privacy regimes on one data basis, per-country variants, and documented update cadence when the law moves.

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The Skeptic

We found no public information on which privacy regimes — GDPR, BDSG, Swiss nDSG or otherwise — the product operationalizes; the capture names no law at all. A listing for the web address itself leaves regime coverage entirely unevidenced. 1

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Audit readiness & evidence

How this is scored

Whether the system produces defensible proof: revision-safe history, evidence collection, reports for auditors, authorities and management.

0 — Exports are screenshots; history is overwritten in place.

3 — PDF reports exist but evidence is attached ad hoc and changes leave no reliable trail.

5 — Versioned records, standard report generators for the core registers, evidence attachments per activity; assembling a full audit file still takes days.

8 — Revision-safe change history, audit-scoped evidence packs on demand, management and authority reports current at a click, auditor access roles.

10 — Audit readiness as a standing state: continuous documentation status per regime and scope, exportable proof packs an auditor accepts as-is, and a defensible answer to "show me the state on date X".

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The Skeptic

We found no public information on versioning, revision-safe history, evidence collection, or reports for auditors, authorities and management. The only assurance mechanism described is the broker's escrow service, which guards a domain purchase rather than producing audit proof. 1

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Integrations & automation

How this is scored

Whether the platform feeds from the real IT estate — directory import, ticketing, API — and automates the recurring privacy work instead of re-typing it.

0 — A closed island: manual entry in, PDF out, no API.

3 — CSV/Excel import and export; no live connections, no API worth the name.

5 — Directory import (AD/Entra), a documented REST API for core objects, a handful of native connectors (ticketing or SSO); automation is reminders and recurrence.

8 — Real connector set (ticketing, HR or asset sources), webhooks, SSO/SCIM, workflow automation with delegation and escalation, useful AI assistance with human review.

10 — The platform behaves like infrastructure: API parity for the data model, event streams, bidirectional sync with the estate, and automation that measurably removes the recurring toil (reviews, attestations, evidence pulls) rather than renaming it.

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The Skeptic

We found no public information on an API, directory import, connectors, SSO or workflow automation. The capture describes exactly one 'service' — escrow — and it belongs to the marketplace intermediary, not to privacy tooling. 1

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European sovereignty

How this is scored

Where the compliance record of the whole company actually lives and under whose law — entity, hosting, subprocessors, DPA. A platform that maps your processing is itself your most concentrated processing.

0 — Non-EU entity, non-EU-default hosting, no public DPA or subprocessor list — for the system holding your RoPA.

3 — A DPA exists and an EU region is available on request or on top tiers; subprocessor exposure to US CLOUD Act reach is broad or undocumented.

5 — EU hosting is the default, DPA and subprocessor list published; the vendor or a critical subprocessor is still within non-European jurisdictional reach.

8 — EU entity, EU hosting with named data centers, published subprocessor list free of content-touching non-EU processors, DPA and TOMs public.

10 — Jurisdictionally clean end to end: European ownership, EU-only hosting and subprocessors, on-premises or sovereign-cloud options, and the whole chain documented publicly.

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The Skeptic

The only company identified anywhere on the page is Nameshift.com, KvK 88910652, Rijswijk — the Dutch brokerage operating the listing — and we found no public information on the software vendor's own legal entity, hosting region, DPA or subprocessor list. For the system that would hold a buyer's records of processing, that is exactly the situation the lowest description on this scale captures. 1

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Pricing transparency not rated — the vendor publishes no price

How this is scored

Whether a buyer can compute the real invoice — per module, per entity, per year, with consulting unbundled — from public pages alone. Unpublished pricing is the B2B norm in this market, so this criterion describes rather than condemns; the benches weight it accordingly.

0 — No public prices at all; every configuration is a sales conversation.

3 — An entry price exists, but module add-ons, entity counts or bundled consulting make the real total incomputable.

5 — Most editions carry real numbers with billing period stated and software separated from services; at least one commonly needed module or scale step is unpriced.

8 — Every edition and module priced publicly with entity/user boundaries and setup fees stated; only genuine corporate-group contracts are custom.

10 — Complete price computability: modules, scale steps, service packages and renewal rules public, so the invoice for a 100-employee company and a 10-client consultancy is a two-minute exercise.

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The Skeptic

We found no public prices for software of any kind — no editions, modules, user counts or setup fees. The only commercial terms published are the broker's: 'Our services are completely free for buyers. The seller pays for our commission.' — a commission model for buying a domain, from which no software invoice can be computed. 1

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Where this could be wrong

What we left out

A claim that does not survive our checks costs us the claim, not the page. This is what was taken off this one.

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Sources (1)

The pages every claim on this page was read from — each one checked, dated, and kept verifiable.

  1. 1 Vendor page datafirst.de Checked 29 Sep 2026 Details →