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Data Protection

iubenda

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Panel rating · 6 judges · How to read the stars

Category median

Sovereignty: 1 of 4 dimensions proven

0–5 in half steps. 5 means the rubric's top anchor is met on the evidence.

by iubenda S.r.l. · www.iubenda.com

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Read this page as one judge. Each weighs the same scores by what they care about.

The External DPO

Weighted verdict

Carries thirty client mandates and bills by the hour they save. Optimizes for multi-client capability, reusable templates, a RoPA that drives the rest, and client-ready reports. Rejects single-tenant tools that treat the consultancy as thirty separate customers.

Same scores as the panel view — this lens weights them the way this judge cares.

Scored by The External DPO

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.

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The External DPO

The register of processing activities is genuinely structured — legal bases, transfer bases, security measure pick-lists, retention and controller/processor roles all live on the service record, with "areas" for website, employees, recruiting and more. But we found no public information on data protection impact assessments, on processor contract or DPA management, or on group template reuse across mandates, which is what I would need to run thirty RoPAs from one seat. 3 4 5

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Data subject rights & incidents

How this is scored

The operational half of the DSMS: data subject request handling with statutory clocks, breach register and authority notification, deletion concepts that actually delete.

0 — Requests arrive by email and live there; breaches are a phone call and a memo.

3 — A request log and a breach list exist, but deadlines are manual, intake is unstructured, and deletion rules are documentation rather than workflow.

5 — DSR workflows with the Art. 12 clock tracked, structured breach register with the 72-hour clock, deletion concepts assignable to records; automation is reminders.

8 — Intake channels for requests (portal/form), identity-check support, deadline automation with escalation, breach severity assessment and authority-report output, deletion rules tied to the RoPA with execution tracking.

10 — Rights and incidents as operations: end-to-end request handling an authority audit walks through, breach workflows that produce the Art. 33 notification, and deletion automation with evidence that the deletion happened.

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The External DPO

The rights tool has real intake — an embeddable request form, a dashboard, instant notifications and guided workflows covering access through objection. But we found no public information on statutory deadline tracking or escalation, on a breach register with the 72-hour clock, or on deletion execution tied to the record; erasure appears as a request type, not a workflow I could walk an authority through. 5 6

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Privacy regime coverage

How this is scored

Which privacy regimes the product actually operationalizes — GDPR, BDSG, Swiss nDSG, UK GDPR, ePrivacy, EU AI Act privacy duties — and whether one record maps across them or each regime is a fresh island.

0 — One regime, hard-coded; anything else is "on the roadmap".

3 — GDPR plus one national law as separate checklists; the same processing activity is documented once per regime.

5 — The major regimes for its market with partial cross-mapping; newer duties (AI Act, ePrivacy changes) present as content packs of varying depth.

8 — Broad current coverage with one-record-many-regimes mapping and visible maintenance as regimes evolve.

10 — Regime coverage as a living product: multiple privacy regimes on one data basis, per-country variants, and documented update cadence when the law moves.

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The External DPO

GDPR, ePrivacy, UK GDPR, US privacy laws, Swiss FADP and LGPD are all named as covered, geo-aware banners adapt per region, and a legal team updating the tools automatically when the law moves is an unusually explicit maintenance claim. But we found no public information showing a single processing activity documented once across regimes rather than per tool, and no public information on AI Act privacy duties. 1 2 7 8

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Audit readiness & evidence

How this is scored

Whether the system produces defensible proof: revision-safe history, evidence collection, reports for auditors, authorities and management.

0 — Exports are screenshots; history is overwritten in place.

3 — PDF reports exist but evidence is attached ad hoc and changes leave no reliable trail.

5 — Versioned records, standard report generators for the core registers, evidence attachments per activity; assembling a full audit file still takes days.

8 — Revision-safe change history, audit-scoped evidence packs on demand, management and authority reports current at a click, auditor access roles.

10 — Audit readiness as a standing state: continuous documentation status per regime and scope, exportable proof packs an auditor accepts as-is, and a defensible answer to "show me the state on date X".

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The External DPO

Consent evidence is the strong point — timestamped consent logs with proofs, IP and banner versions, legal notices retrievable per version through the API, plus claimed detailed action logs. But we found no public information on revision-safe history for the register itself, auditor access roles, or report generators that would let me hand a client a finished audit file without days of assembly. 2 6 9 10

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Integrations & automation

How this is scored

Whether the platform feeds from the real IT estate — directory import, ticketing, API — and automates the recurring privacy work instead of re-typing it.

0 — A closed island: manual entry in, PDF out, no API.

3 — CSV/Excel import and export; no live connections, no API worth the name.

5 — Directory import (AD/Entra), a documented REST API for core objects, a handful of native connectors (ticketing or SSO); automation is reminders and recurrence.

8 — Real connector set (ticketing, HR or asset sources), webhooks, SSO/SCIM, workflow automation with delegation and escalation, useful AI assistance with human review.

10 — The platform behaves like infrastructure: API parity for the data model, event streams, bidirectional sync with the estate, and automation that measurably removes the recurring toil (reviews, attestations, evidence pulls) rather than renaming it.

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The External DPO

The consent API is properly engineered — documented REST with subjects, consents and legal notices, cursor pagination, honest rate limits — and Zapier plus an MCP connector that registers a site, runs a scan and generates documents is real automation I could use for batch client setup. But we found no public information on directory import, SSO or SCIM, ticketing or HR connectors, webhooks, or API access to the register and rights modules — the estate feeds a DSMS lives on. 10 11 12

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European sovereignty

How this is scored

Where the compliance record of the whole company actually lives and under whose law — entity, hosting, subprocessors, DPA. A platform that maps your processing is itself your most concentrated processing.

0 — Non-EU entity, non-EU-default hosting, no public DPA or subprocessor list — for the system holding your RoPA.

3 — A DPA exists and an EU region is available on request or on top tiers; subprocessor exposure to US CLOUD Act reach is broad or undocumented.

5 — EU hosting is the default, DPA and subprocessor list published; the vendor or a critical subprocessor is still within non-European jurisdictional reach.

8 — EU entity, EU hosting with named data centers, published subprocessor list free of content-touching non-EU processors, DPA and TOMs public.

10 — Jurisdictionally clean end to end: European ownership, EU-only hosting and subprocessors, on-premises or sovereign-cloud options, and the whole chain documented publicly.

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The External DPO

The legal entity is Italian — iubenda S.r.l. of Milan under EU jurisdiction, directed and coordinated by team.blue NV — which is where I want a client's compliance record to live. But we found no public information on hosting location, data residency, subprocessors or a published DPA in the captured pages, so the chain below the entity is undocumented. 6 7

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Pricing transparency not rated — the vendor publishes no price

How this is scored

Whether a buyer can compute the real invoice — per module, per entity, per year, with consulting unbundled — from public pages alone. Unpublished pricing is the B2B norm in this market, so this criterion describes rather than condemns; the benches weight it accordingly.

0 — No public prices at all; every configuration is a sales conversation.

3 — An entry price exists, but module add-ons, entity counts or bundled consulting make the real total incomputable.

5 — Most editions carry real numbers with billing period stated and software separated from services; at least one commonly needed module or scale step is unpriced.

8 — Every edition and module priced publicly with entity/user boundaries and setup fees stated; only genuine corporate-group contracts are custom.

10 — Complete price computability: modules, scale steps, service packages and renewal rules public, so the invoice for a 100-employee company and a 10-client consultancy is a two-minute exercise.

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The External DPO

The only public pricing facts are a free plan with no credit card and a named Ultimate plan whose perks are listed without figures; we found no public prices for any edition, module, billing period or scale step. Multi-licenses mechanics appear only as API behavior for creating policies per destination user, unpriced, so neither a 100-employee company nor my ten-client practice can compute a real invoice. 1 6 11

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European sovereignty — proven facts

1 of 4 dimensions proven

Built only from facts shown on the vendor's own pages. A dimension we could not prove is left open, not scored as zero.

Ownership Not determined — uncited Report an error
Data residency Not determined — uncited Report an error
Subprocessors Not determined — uncited Report an error

Where this could be wrong

What we left out

A claim that does not survive our checks costs us the claim, not the page. This is what was taken off this one.

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Sources (12)

The pages every claim on this page was read from — each one checked, dated, and kept verifiable.

  1. 1 Vendor page www.iubenda.com Checked 22 Sep 2026 Details →
  2. 2 Privacy policy — found from the homepage www.iubenda.com Checked 30 Sep 2026 Details →
  3. 3 Records & DPIA depth — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  4. 4 Records & DPIA depth — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  5. 5 Data subject rights & incidents — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  6. 6 Data subject rights & incidents — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  7. 7 Privacy regime coverage — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  8. 8 Privacy regime coverage — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  9. 9 Audit readiness & evidence — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  10. 10 Audit readiness & evidence — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  11. 11 Integrations & automation — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →
  12. 12 Integrations & automation — found from sitemap www.iubenda.com Checked 1 Oct 2026 Details →