CONFIDENTIALITY POLICY

Last reviewed: January 2026 
Next review: January 2027 

1. Purpose of This Policy

Luma is committed to maintaining the highest standards of confidentiality, discretion, and professionalism in all work undertaken with families, household staff, agencies, and associated professionals. 

This policy sets out: 

• what information is treated as confidential
• how confidential information is handled and stored 
• the limits of confidentiality 
• how information may be shared appropriately 

This policy applies to all Luma engagements, regardless of location.

2. Scope

This policy applies to: 

• families and parents 
• household staff (including, but not limited to, nannies, tutors, PAs, drivers, chefs, security, and educators) 
• recruiters and agencies 
• external professionals (therapists, schools, consultants) 
• all communication channels, including WhatsApp, email, video calls, and written documentation

3. How We Define Confidential Information

Confidential information includes, but is not limited to: 

• personal details about the child or family 
• developmental, behavioural, educational, or emotional information 
• household dynamics, routines, or challenges 
• staff concerns, reflections, or experiences shared in confidence 
• professional opinions or recommendations 
• internal household communications shared with Luma 

All such information is treated as private and handled with discretion.

4. Luma’s Approach to Confidentiality

Luma operates as a trusted coordinating and advisory partner. 

We: 

• respect the privacy of families and staff 
• avoid unnecessary sharing of information 
• communicate sensitively and proportionately 
• do not engage in gossip, triangulation, or informal disclosure

Confidentiality underpins our ability to stabilise households and support long-term success. 

5. Confidentiality with Household Staff

Luma may provide: 

• 1:1 advisory support to staff members 
• group communication channels for guidance and updates

Staff may use these spaces to: 

• reflect on challenges 
• express stress or uncertainty 
• seek guidance or reassurance

These conversations are treated as confidential within professional limits.

However, staff are informed that: 

• Luma is not a confidential counselling service 
• information that affects a child’s wellbeing, safety, or household stability may need to be shared appropriately 
• venting or emotional expression is acceptable; safeguarding concerns cannot remain private 

6. Confidentiality with Parents and Families

Information shared by parents is treated as confidential and used only for the purpose of supporting the child and household.

Luma does not: 

• share family information with staff unnecessarily 
• disclose private family matters without justification 
• use family information for marketing or case studies without explicit consent 

Information is shared only when it supports alignment, safety, or effective implementation. 

7. Information Sharing and Alignment

Luma’s role often requires selective information sharing to support consistency and reduce risk. 

Information may be shared: 

• between parents and key staff 
• with external professionals (e.g. tutors, therapists, schools) 
• with recruiters or agencies (where agreed) 

Sharing is: 

• purposeful 
• proportionate 
• limited to what is necessary 
• framed constructively  

Wherever possible, Luma seeks explicit consent before sharing information with external professionals, agencies, or third parties.  

If immediate sharing is required for safeguarding or legal reasons, families are informed promptly and transparently. 

8. Limits of Confidentiality

Confidentiality cannot be maintained if: 

• a child is at risk of harm
• abuse or neglect is disclosed or suspected 
• there is a serious safeguarding concern 
• there is a legal obligation to disclose information

In such cases, Luma may: 

• raise concerns with parents or employers 
• seek safeguarding advice 
• contact relevant authorities if required 

These limits are clearly communicated at the outset of engagement and detailed in our Luma Safeguarding Policy. 

9. Data Protection and Storage

Luma takes reasonable steps to ensure confidential information is: 

• stored securely 
• accessed only by authorised individuals 
• not shared informally or unnecessarily

Information may be held in: 

• secure digital documents 
• password-protected devices 
• professional communication platforms

Luma complies with applicable data protection laws, including GDPR and relevant international regulations. 

Information is retained for 12 months after engagement unless legally required to keep longer. 

10. Use of WhatsApp and Informal Channels

WhatsApp and similar platforms may be used for: 

• accessibility 
• timely support and practical guidance 

While convenient, these channels are treated as professional communication spaces. 

Luma: 

• avoids informal or careless messaging 
• documents significant concerns appropriately 
• maintains professional tone and boundaries 

Clients are advised that no platform can be guaranteed to be entirely risk-free, and communication is kept proportionate accordingly. 

11. Boundaries and Professional Conduct

Luma does not: 

• take sides in internal household conflicts 
• act as a messenger for grievances 
• share one person’s private views without clear purpose 
• provide anonymous reporting  

Our role is to: 

• stabilise, not inflame 
• clarify, not complicate 
• support alignment, not division 

12. Breaches of Confidentiality

Any breach of confidentiality is taken seriously.

If a breach occurs, Luma will: 

• assess the impact 
• inform relevant parties where appropriate 
• take steps to prevent recurrence 

13. Review of Policy

This policy is reviewed annually or following any significant confidentiality incident.