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 External DPO
Data Mapping & Risk Manager captures purpose, legal basis and retention on system, vendor and process records, auto-triggers DPIA or PIA workflows when high-risk activity is detected, and ships a central library of pre-populated templates for common systems and vendors — that is the connected record model I clone across mandates, and the up-to-80-percent effort-reduction claim on ROPA creation is the right thing to automate. It stops short of full marks because I found no public information on TOM management depth or multi-client/mandate handling, which is the difference between a tool and a consultancy platform. 4 5 9