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
The suite names external data protection as a first-class scenario — clients managed in a structured manner, companies, locations and roles consolidated transparently — with the record of processing activities, TOMs and inquiries documented in a traceable, versioned way, which is exactly the multi-mandate shape I bill against. What holds it back is depth: DPIA and processor-contract handling appear only as knowledge-page content describing what a management system should do, and we found no public information on a linked data model that derives assessments from the record or on legal-basis linkage. 2 2 4