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 Lead Auditor
The captured pages show a structured system inventory that creates systems with one privacy declaration per data use, a data map, GDPR guidance from mapping through assessments, and a data protection assessment module with question groups exportable as a regulator-ready PDF; RoPA automation is claimed on the GDPR platform page. We found no public information on processor and DPA management, and none on technical and organisational measures documented and assigned to processing activities, so the record stops short of a connected privacy data model. 4 8 9 11 13