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Data Protection

SECJUR Digital Compliance Office

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 secjur GmbH · www.secjur.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

The entire privacy record surface is the word 'Datenschutz' in a product list plus a DSGVO claim — not one fact about RoPA/VVT structure, DPIA questionnaires, processor/DPA management or TOM assignment. As a multi-mandate practice I cannot even tell whether thirty clients live in one account or thirty; nothing here resembles the connected data model the anchor at 8 demands. 1 5

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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

Zero facts concern data subject requests, statutory clocks, breach registers, Art. 33 output or deletion — the only adjacent items are generic automated email notifications, task organization, and a whistleblower module, which is a different legal duty entirely. Missing evidence is information here: I have to assume my clients' DSRs and incidents would be handled outside this system. 1 2

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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

DSGVO and an EU AI Act framework (launched 2025) are evidenced, and cross-mapping between frameworks is claimed — but the cross-mapping story is built around the ISO/NIS2 security stack, not privacy regimes. No BDSG, no Swiss nDSG despite a Bern subsidiary since 2023, no UK GDPR, so privacy coverage is essentially one regime plus an AI content pack. 1 4 5

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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 story is outcome marketing — '100% success rate at ISO 27001 audits' — with no evidence of revision-safe change history, evidence packs, report generators or auditor access roles. For a compliance automation platform whose homepage sells certifications, the absence of any documented audit-trail capability is itself the finding; I'd spend days assembling a supervisory-authority file. 1 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

'Über 60 API-Anbindungen' with JIRA named is a genuinely broad connector claim, and automated notifications plus project/priority task organization show some workflow machinery — but no documented REST API for core objects, no directory import, no SSO/SCIM, no webhooks, and no delegation/escalation evidenced. The automation shown is reminders and to-do lists, which is anchor-5 territory nudged up only by the connector count. 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 External DPO

The entity and hosting half is actually solid: secjur GmbH registered in Hamburg (HRB 170383), 'HOSTED IN GERMANY' claimed, and ownership is European VC (Visionaries Club, Berlin; Alea Capital, Portugal). But there is no published DPA, no subprocessor list, and no named data centers anywhere in the captured evidence — for the system that would hold the RoPA of thirty clients, an undocumented subprocessor chain is disqualifying of anything above mid-band. 3 4 6 5

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Pricing transparency

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

No public price exists on any captured page — the only numbers in the pricing dimension are a €5.5m seed round and 'bis zu 67% günstiger'. For a consultancy pricing a ten-client rollout, every configuration starts with a sales conversation, which is exactly rubric level 0. 1 3

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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 EU only ⚠ unverified 3/3 pts 1 Report an error
Subprocessors Not determined — 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 (9)

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

  1. 1 Vendor homepage www.secjur.com Checked 5 Oct 2026 Details →
  2. 2 Platform page www.secjur.com Checked 5 Oct 2026 Details →
  3. 3 ISMS product page www.secjur.com Checked 5 Oct 2026 Details →
  4. 4 ISO 27001 product page www.secjur.com Checked 5 Oct 2026 Details →
  5. 5 About page www.secjur.com Checked 5 Oct 2026 +1 earlier capture: 24 Aug 2026 Details →
  6. 6 Imprint www.secjur.com Checked 5 Oct 2026 Details →
  7. 7 Privacy policy www.secjur.com Checked 5 Oct 2026 Details →
  8. 8 Privacy regime coverage — found from sitemap www.secjur.com Checked 5 Oct 2026 Details →
  9. 9 Integrations & automation — found from sitemap www.secjur.com Checked 5 Oct 2026 Details →