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 IT Integrator
The record of processing activities and the impact assessment run on a shared data basis with the CMDB, ISMS and emergency planning, with measures linked to target objects, supplier and contract management, industry processing templates and multi-tenant capability — that is a connected model I can feed from the estate instead of retyping it. The captured pages stop at capability names though: we found no public information on legal basis modelling, processor/DPA management as a privacy artifact, or DPIA triggers derived from a record. 2 3 7 3