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 Lead Auditor
The captured pages show data flow mapping with Article 30 report generation, DPIA assessments under Article 35, and processor management with vendor contracts and compliance documents under Article 28, backed by a central records repository and a knowledge-graph architecture claim — more than templates in a folder. But we found no public information on TOM management, legal bases as linked records, DPIA triggers derived from the register, or reusable group templates, so I will not credit a fully connected data model on this evidence. 1 3 6 7 8