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 data model is genuinely connected: every processing activity carries its systems, TOMs and data processing agreements in a graphical relationship view, the record itself feeds the Art. 35 necessity assessment, and deletion classes derive rules from linked activities — with multi-mandate operation, strict tenant separation and cross-client inheritance documented in depth. It stays below the top for me because missing DPA-to-record connections are established by hand and by name matching rather than flowing from one model. 2 16 17 2