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Data Protection

PLANIT // PRIMA

EU-Made Report an error

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 PLANIT // TECH GmbH · www.planitprima.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

Expert-developed templates and tutorials in 'one single tool' with TOM/measure management inside the audit workflow are confirmed, but the evidence never evidences a structured RoPA, DPIA, processor/DPA register or legal-basis linkage — and multi-mandate capability is entirely absent. For a practice running thirty clients, undocumented register depth plus per-client copy-paste is exactly the margin killer I reject. 1 2 4

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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

Art. 12–23 requests handled via a structured digital workflow, 'fristgerecht und nachvollziehbar', gives me a DSR workflow with statutory-deadline handling. But breach register, 72-hour clock, authority notification and deletion execution are nowhere in the evidence — that is half of the operational DSMS missing. 3

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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

Every reference is DSGVO; no BDSG specifics, no Swiss nDSG, no UK GDPR, no AI Act duties appear anywhere in the evidence, and the 'regular updates' claim only maintains the one regime. A single hard-coded regime means a fresh documentation island for every client in a second jurisdiction. 1 2

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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

The audit module is their strongest card: dashboard, planning, assessment steps, measures management, Nachweisführung and Auditbericht & Export form a repeatable, client-ready report pipeline I could bill on. Missing: revision-safe change history, an answer to 'show me the state on date X', and auditor access roles — so a full audit file is not a standing state. 4

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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

Confirmed integrations begin and end with 'web-based' and an export at the end of the audit — no API, no directory import, no ticketing, no SSO, not even CSV import appears in the evidence. Every client's processing inventory would be typed in by hand thirty times over, which is the definition of a closed island. 1 4

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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

A Hamburg-based German GmbH with Germany-only hosting claimed in the provenance line is a decent jurisdictional base, but the sovereignty attributes record is literally empty: no published DPA, no subprocessor list, no public TOMs. For the system that would concentrate thirty clients' RoPAs, an undocumented chain is a diligence hole I cannot paper over. 2 3 4

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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 artifact is a 14-day trial without credit card; no editions, modules, user or entity counts carry numbers. The buying path is literally a 'Termin vereinbaren' button, so the real invoice for either a 100-employee client or my own book is a sales conversation, not a computation. 4

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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 ⚠ unverified — uncited Report an error
Subprocessors Not determined ⚠ unverified — 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 (14)

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

  1. 1 Vendor homepage www.planitprima.com Checked 17 Sep 2026 Details →
  2. 2 DSMS product page www.planitprima.com Checked 17 Sep 2026 Details →
  3. 3 Data subject rights feature page www.planitprima.com Checked 17 Sep 2026 Details →
  4. 4 Audit feature page www.planitprima.com Checked 17 Sep 2026 Details →
  5. 5 Data processing agreement (dpa) www.planitprima.com Checked 30 Sep 2026 Details →
  6. 6 Security / trust page — found from the homepage www.planitprima.com Checked 30 Sep 2026 Details →
  7. 7 Records & DPIA depth — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →
  8. 8 Records & DPIA depth — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →
  9. 9 Data subject rights & incidents — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →
  10. 10 Data subject rights & incidents — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →
  11. 11 Privacy regime coverage — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →
  12. 12 Privacy regime coverage — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →
  13. 13 Audit readiness & evidence — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →
  14. 14 Audit readiness & evidence — found from sitemap www.planitprima.com Checked 1 Oct 2026 Details →