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 Skeptic
The record model is genuinely connected: every Art. 30 mandatory field, graphical links from processing activities to systems, TOMs and contracts, and a contract view flagging which data recipients are covered by a DPA — with missing links still set by hand rather than derived. Reusable text modules, cross-client inheritance for mandates and one-click BayLDA procedure files match the connected-model anchor; we found no evidence that DPIA necessity or processor coverage is derived rather than AI-proposed and hand-confirmed, which keeps it below system-of-record territory. 16 17 2 7 11