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 External DPO
Ready-to-use templates for DPIAs, PIAs, TIAs, AI impact assessments, vendor reviews and the ROPA ship out of the box, and agent-driven discovery plus contract-versus-DPA reconciliation feed the record from the live estate rather than a questionnaire. What decides the score is the other half: I found no public information on TOMs modeling or legal-basis linkage inside the record, and nothing on reusable group templates or multi-mandate capability, which a thirty-client practice needs before the RoPA can drive everything else. 4 3 1