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 IT Integrator
A system inventory where each approved application gets a privacy declaration per data use, plus assessment question groups whose PDF is formatted for submission to a supervisory authority, is a real records-and-DPIA core fed by discovery scans rather than typing. I found no public information on processor and DPA records or on technical and organisational measures documented against processing activities, so the connected-record picture stops short of the higher levels. 4 8 9 11 13