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 Skeptic
The record of processing activities is a genuine register — guided form, autosave, tracked changes, automatic risk assessment with color coding, search and multi-format export — and processor, TOM and DPIA modules are at least named. But we found no public information on processing activities linked to systems, processors, TOMs and legal bases as one connected data model, on DPIA triggers derived from the record, or on what sits behind the DPIA assistant beyond its plan gating. Linked modules with unverifiable depth, not a connected system of record. 1 2 6 11