Records & DPIA depth
How this is scored
The DSMS core: records of processing activities (RoPA/VVT, Art. 30 DSGVO), data protection impact assessments (DSFA, Art. 35), processor and DPA management (AVV), and technical and organisational measures (TOMs) — how deeply the legal artefacts are modelled and connected.
0 — Not a privacy management tool; at most a set of document templates with no structured records.
3 — A structured record of processing activities with templates, and a DPIA questionnaire or checklist.
5 — Records of processing and DPIAs as modules with templates, processors and their DPAs recorded, and TOMs documented and assigned to processing activities.
8 — A connected data model — processing activities linked to systems, processors, TOMs and legal bases — with DPIA need derived from the record, reusable templates across companies, and outputs (Art. 30 register, DPIA report) ready for a supervisory authority.
10 — Privacy records as a system of record: the RoPA drives DPIAs, processor management and TOM coverage from one data model, multi-client capability for external data protection officers, and the documentation is audit-ready without manual assembly.
The In-House Counsel
The evidence shows a structured record — applications approved into a system inventory with one privacy declaration per data use, built on a data map — and data protection assessments whose answers export as a PDF the vendor describes as suitable for submitting to a supervisory authority. RoPA automation is claimed on the GDPR platform page. What I cannot defend on this evidence: processors with their DPAs and TOMs assigned to processing activities — I found no public information on either. 4 8 9 11 13