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 In-House Counsel
The live record of processing drawing from assessments, system integrations and imports into a central processing inventory, automated DPIA and PIA workflows, and vendor due diligence with a centralized record of data processing agreements and security obligations give me a connected data model I could put in front of a supervisory authority. I found no public information on legal bases tied to activities, on DPIA triggers derived from the record, or on multi-client mandate capability, which is what separates this from a full system of record. 3 2 10