Records & DPIA depth
How this is scored
The DSMS core: records of processing activities (RoPA/VVT, Art. 30 DSGVO), data protection impact assessments (DSFA, Art. 35), processor and DPA management (AVV), and technical and organisational measures (TOMs) — how deeply the legal artefacts are modelled and connected.
0 — Not a privacy management tool; at most a set of document templates with no structured records.
3 — A structured record of processing activities with templates, and a DPIA questionnaire or checklist.
5 — Records of processing and DPIAs as modules with templates, processors and their DPAs recorded, and TOMs documented and assigned to processing activities.
8 — A connected data model — processing activities linked to systems, processors, TOMs and legal bases — with DPIA need derived from the record, reusable templates across companies, and outputs (Art. 30 register, DPIA report) ready for a supervisory authority.
10 — Privacy records as a system of record: the RoPA drives DPIAs, processor management and TOM coverage from one data model, multi-client capability for external data protection officers, and the documentation is audit-ready without manual assembly.
The External DPO
The Enterprise Privacy module names DPIAs, records of processing and PII discovery, and the Ironclad sync scans contracts and DPAs, so the core artefacts exist as modules. But we found no public information on TOMs, legal bases tied to processing activities, reusable templates across companies, multi-client capability, or an authority-ready register output — everything rests on one-line marketing claims, which is thin for running thirty mandates from one system of record. 1 2