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 IT Integrator
The Enterprise Privacy module automates DPIAs, ROPAs and PII discovery, and the Ironclad integration scans contracts and DPAs to extract risk exceptions, so structured records do exist. But nothing captured shows a processor register with DPAs, TOMs assigned to processing activities, or an Article 30 register generated as an authority-ready output — the product is built around design-time launch reviews rather than a standing record of processing. 1