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Privacysoft

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Panel rating · 6 judges · How to read the stars

Category median

Sovereignty: 2 of 4 dimensions proven

0–5 in half steps. 5 means the rubric's top anchor is met on the evidence.

by Projekt 29 GmbH & Co. KG · privacysoft.de

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Read this page as one judge. Each weighs the same scores by what they care about.

The In-House Counsel

Weighted verdict

Answers personally when the authority writes. Optimizes for defensibility: request clocks that never slip, a breach workflow that produces the Art. 33 notification, regime coverage that matches where the company actually operates. Rejects tools whose legal content nobody maintains.

Same scores as the panel view — this lens weights them the way this judge cares.

Scored by The In-House Counsel

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 In-House Counsel

The VV module is a real Art. 30 register — sample templates in DE/EN/FR, status evaluation restricted to the DSB role, and DPIA triggers derived from the record itself (risk point 13 red or supervisory authority blacklist). But the DSFA module is described as 'currently a listing' of conducted assessments, and nowhere in the registry is there processor/DPA management, TOM assignment or legal bases as structured data — they live outside the system. 3 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 In-House Counsel

Nothing in the registry evidences a data subject request workflow, a breach register or any authority notification path — no Art. 12 clock, no 72-hour clock, nothing I could show a supervisory authority. The only deletion facts concern RoPA records (archived, never deleted) and attachments, which is register hygiene, not deletion-as-workflow. Missing evidence is information: this half of the DSMS does not exist on this sheet, and I cannot defend a notification timeline with it. 2 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 In-House Counsel

Everything captured is GDPR in German practice — Art. 30 DSGVO, the Aufsichtsbehörden blacklist trigger — and the German/English/French options are language versions of the same GDPR template, not different regimes. No BDSG, nDSG, UK GDPR, ePrivacy or AI Act content appears anywhere, and no cross-regime mapping is evidenced. One regime, hard-coded; if my company operates outside Germany, this register has nothing to say about it. 3 4

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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 In-House Counsel

The report wizard outputs reports over VVs and DSFAs, and the non-deletability of processing records ('cannot be deleted, only archived') is a genuine integrity gesture. But there is no revision-safe change history, no evidence packs, no auditor access role and no defensible answer to 'show me the state on date X' — I would still assemble the audit file by hand. Reports exist; the trail behind them does not. 3 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 In-House Counsel

The registry shows no API, no directory import, no ticketing or SSO connectors, no webhooks — not even CSV import is evidenced. The only 'included' services are the vendor's own IT administration, maintenance and updates under the license fee, which is a managed-hosting promise, not estate integration. Manual entry in, report out: a closed island. 1 2

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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 In-House Counsel

The entity is verifiably German — Projekt 29 GmbH & Co. KG, Regensburg, HRA 8442, VAT DE278338298 — and hosting sits in a German ISO 27001 data center, which is what I want under the system holding my RoPA. But no DPA, TOMs or subprocessor list are published in the evidence, and the ownership chain stops at an undisclosed Verwaltungs-GmbH, so I cannot verify the chain is free of non-European jurisdictional reach. Solid facts, unreadable chain: middle of the field. 1 5

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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 In-House Counsel

The only pricing fact captured is what the license fee includes — IT administration, maintenance, updates — with no figure, edition, module price or billing period anywhere in the registry. The real invoice is a sales conversation by definition; rubric level 0 describes the market norm rather than condemning it, but it is 0 all the same. 1

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European sovereignty — proven facts

2 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 EU only ⚠ unverified 3/3 pts 1 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 (5)

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

  1. 1 Vendor homepage privacysoft.de Checked 15 Sep 2026 Details →
  2. 2 Product documentation portal help.privacysoft.online Checked 15 Sep 2026 Details →
  3. 3 RoPA module documentation help.privacysoft.online Checked 15 Sep 2026 Details →
  4. 4 DPIA module documentation help.privacysoft.online Checked 15 Sep 2026 Details →
  5. 5 Imprint privacysoft.de Checked 15 Sep 2026 Details →