Online Safety Policy

Organisation:WeareLumina Inc. (trading as Lumina)
Contact:info@wearelumina.co
Legal Contact:legal@wearelumina.co
Effective date:23 June 2026
Next review:June 2027

Applies to all platform users (learners aged 14–24), staff, contractors, contributors, partner institutions, and parents/carers.

1. Policy Statement

Lumina is committed to providing a safe online environment for all learners, staff, and stakeholders who interact with the platform. This policy sets out the measures in place to identify, prevent, and respond to online risks, with particular attention to the safety of children and young people under 18.

This policy should be read alongside Lumina's Safeguarding & Child Protection Policy, Privacy Policy, and Code of Conduct.

2. Scope

This policy applies to:

  • All learners aged 14–24, whether accessing the platform through a partner institution or independently
  • Parents and carers of learners under 18
  • Partner institutions, including schools, colleges, and other organisations
  • All Lumina staff, contractors, freelancers, and content contributors
  • Any third party with access to Lumina systems or data

This policy covers all online activity related to the Lumina platform, including content delivery, the AI Tutor, task submission, and platform administration.

3. Platform Model and Risk Context

Lumina is an online learning platform that delivers structured courses across 7 learning pillars. The platform operates a primarily pre-recorded content model with the following interactive elements:

Pre-recorded content (low risk)

  • All video, text, and multimedia learning content is created, reviewed, and approved before publication
  • Learners consume content independently at their own pace
  • There is no live teaching, live streaming, or scheduled group sessions

AI Tutor (moderate risk)

  • Learners can interact with an AI-powered tutor that answers questions and provides learning guidance
  • The AI Tutor operates in real time and generates responses based on learner inputs
  • Learner inputs are processed by a third-party AI provider (see Section 6)

Task submission (low risk)

  • Learners submit tasks at the end of each lesson, including text responses and image uploads
  • Submitted content is not publicly visible to other learners
  • There are no commenting, messaging, or peer-to-peer communication features on the platform

4. Online Risks Considered

Lumina recognises the following categories of online risk and has implemented controls to address each:

Content risks

  • Exposure to inappropriate, harmful, or inaccurate content through learning materials
  • AI Tutor generating responses that are inaccurate, misleading, or inappropriate for the audience

Contact risks

  • Unauthorised contact between adults and learners via any channel
  • Learners sharing personal information through AI Tutor inputs or task submissions

Conduct risks

  • Misuse of the platform by learners, including attempting to manipulate the AI Tutor
  • Unauthorised access to accounts or platform systems

Commercial risks

  • Exposure to advertising, sponsorship, or commercial content — Lumina does not display third-party advertising
  • Misuse of learner data for purposes beyond educational delivery

5. Safety by Design

Lumina embeds online safety into the design and operation of the platform through the following controls:

  • Secure login with encrypted credentials and access controls
  • No private or public messaging, chat, or communication tools between users
  • No user-generated content that is visible to other learners
  • All learning content reviewed and approved by the content lead before publication
  • Role-based access ensuring staff and contributors can only access areas relevant to their function
  • Session management including automatic timeouts and secure logout
  • HTTPS encryption on all platform connections

6. AI Tutor Safety Controls

The AI Tutor is an interactive feature that requires specific safety measures. The following controls are in place:

Content filtering

  • The AI Tutor is configured to operate within educational boundaries and decline requests for inappropriate, harmful, or off-topic content
  • Responses are scoped to the learning context and do not provide personal advice, medical guidance, or legal counsel

Data handling

  • Learner inputs are transmitted to a third-party AI provider for real-time processing
  • The AI provider does not retain personal data beyond the immediate session
  • Lumina does not use AI Tutor conversation data to train or fine-tune AI models
  • AI Tutor conversation data is retained for up to 30 days to support continuity of learning, then automatically deleted

Monitoring and review

  • AI Tutor interactions may be reviewed where a safeguarding concern is raised or suspected
  • Lumina monitors the AI Tutor for patterns of misuse, inappropriate queries, or attempts to extract harmful content
  • Any issues identified are escalated to the Designated Safeguarding Lead and the platform development team

Learner guidance

  • Learners are informed that AI Tutor responses are generated by artificial intelligence and may not always be accurate
  • Learners are advised not to share personal, sensitive, or identifying information in AI Tutor conversations

7. Content Standards and Review

All learning materials published on the Lumina platform must meet the following standards:

  • Be age-appropriate and suitable for learners aged 14 and above, including those under 18
  • Be free from offensive, discriminatory, sexualised, violent, or otherwise harmful material
  • Be factually accurate, well-sourced, and aligned with Lumina's educational values
  • Respect intellectual property rights and licensing requirements
  • Be reviewed and approved by the designated content lead prior to publication

Content that does not meet these standards will be removed immediately and may not be republished without revision and re-approval.

8. Learner Responsibilities

Learners are expected to use the Lumina platform responsibly. This includes:

  • Keeping login credentials private and not sharing accounts with others
  • Not attempting to access areas of the platform that are not intended for their use
  • Not submitting content that is offensive, harmful, or inappropriate in tasks or AI Tutor conversations
  • Not attempting to manipulate, bypass, or misuse the AI Tutor
  • Not sharing personal, sensitive, or identifying information through the platform
  • Reporting any concerns about content, safety, or other users to a trusted adult or directly to Lumina

Learners who repeatedly or seriously breach these expectations may have their access restricted or removed.

9. Roles and Responsibilities

Lumina will:

  • Maintain secure and appropriate platform controls at all times
  • Review and approve all content before publication
  • Monitor the AI Tutor for safety and appropriateness
  • Respond to online safety concerns promptly and in accordance with this policy
  • Ensure all staff and contributors are aware of their online safety obligations
  • Review this policy annually and update it to reflect changes in platform functionality or legislation

Partner institutions will:

  • Supervise learner access to the platform where appropriate, particularly for learners under 16
  • Support learners with digital safety awareness and responsible use
  • Report any online safety concerns to Lumina promptly
  • Ensure their own online safety and acceptable use policies are consistent with this policy

Parents and carers are encouraged to:

  • Be aware that their child is using the Lumina platform and understand what it involves
  • Discuss online safety with their child, including responsible use of AI tools
  • Contact Lumina with any concerns about their child's experience on the platform

10. Reporting Online Safety Concerns

Any online safety concern — whether relating to content, the AI Tutor, platform security, or the conduct of any individual — should be reported immediately.

How to report

  • Email the Designated Safeguarding Lead: legal@wearelumina.co
  • Email the Online Safety Lead: legal@wearelumina.co
  • If the concern involves the DSL, escalate to a senior director or contact the NSPCC Helpline (0808 800 5000)

What happens next

  • All reports are acknowledged within 24 hours
  • The concern is assessed, logged, and investigated as appropriate
  • Where a child protection issue is identified, the matter is referred to the relevant local authority or police in accordance with the Safeguarding & Child Protection Policy
  • The reporter will be updated on the outcome where it is appropriate and safe to do so

11. External Links and Third-Party Content

The Lumina platform may include links to external websites or resources for educational purposes. Lumina is not responsible for the content, privacy practices, or safety standards of external sites.

Where external links are included in learning materials, they are reviewed at the time of publication to ensure they are appropriate and functional. However, Lumina cannot guarantee that external content will remain appropriate over time. Learners and institutions should exercise their own judgment when following external links.

12. Staff and Contributor Training

All Lumina staff, contractors, and content contributors are required to:

  • Read and understand this Online Safety Policy before commencing work
  • Complete any online safety training specified by Lumina
  • Stay informed about current online risks affecting children and young people
  • Report any online safety concerns in accordance with Section 10 of this policy

Training requirements are reviewed annually and updated to reflect emerging risks and best practice.

13. Data Protection

Lumina handles all personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. For full details of how personal data is collected, used, stored, and protected, refer to the Lumina Privacy Policy.

In the context of online safety, the following principles apply:

  • Only the minimum personal data necessary for educational delivery is collected
  • Learner data is not shared with third parties except as described in the Privacy Policy
  • AI Tutor conversation data is processed by a third-party provider and not retained beyond the immediate session by that provider
  • Any suspected data breach is reported to the ICO and affected individuals in accordance with legal requirements

14. Related Policies

This policy should be read in conjunction with the following Lumina documents:

  • Safeguarding & Child Protection Policy
  • Privacy Policy
  • Code of Conduct
  • Terms of Service

15. Policy Review

This Online Safety Policy is reviewed annually or sooner if any of the following occur:

  • Significant changes to platform functionality (e.g. introduction of new interactive features)
  • Changes in relevant legislation or regulatory guidance
  • A significant online safety incident involving the platform
  • Changes to the AI Tutor provider or data processing arrangements

The next scheduled review is June 2027.

16. Contact

For any enquiries relating to this policy or online safety on the Lumina platform:

© 2026 WeareLumina Inc. All rights reserved.

See also our Privacy Policy, Terms of Service, and Safeguarding & Child Protection Policy.