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 is generated live from a central processing inventory fed by assessments, system integrations, questionnaire responses and bulk imports — records that stay current because they sync, exactly the model I run. DPIA and PIA workflows are automated, vendor records centrally hold DPAs, transfer mechanisms and security obligations, and there is a published, versioned GDPR transfer impact assessment template; I stop short of the top because the captured pages show no DPIA triggers derived from the record, no reusable group templates and no multi-client/mandate capability. 3 10