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 RoPA module is real — Art. 30 register with sample templates in three languages, tags/links/comments, and a copy function for reuse — and DPIA triggers derive from the record's risk assessment or the authority blacklist. But the DPIA module is explicitly 'a listing of conducted DPIAs', and processors, TOMs and legal bases appear nowhere in the documentation; group reuse is literally copy-paste, so this sits between rubric level 3 and 5. 3 4