Version 1.0 · Effective 28 June 2026
This notice explains, in plain English, what personal data lumi processes, why,
and the rights you have.
lumi.benchmark ("lumi", "we") operates a UK HR reward benchmarking service.
For the personal data described here, lumi is the data controller.
• Account data — your name, work email, organisation, and role. Used to
sign you in, set your permissions, and contact you about the service.
• Organisation profile — benign firmographic facts about your employer
(sector, size, region, ownership). Used to place you in the right peer
groups. This is organisation-level information, not personal data.
• Benchmark submissions — your organisation's reward data. This is
organisational, not personal; it is never published in a way that can
identify a single organisation (see the suppression rule in *How lumi works
→ How the numbers are calculated*).
• Usage data — basic logs needed to run and secure the service.
We do not sell personal data. We do not use your data to train third-party
models. We do not publish any peer figure that rests on fewer than the
suppression floor of organisations.
Account and usage data: our legitimate interest in providing and securing the
service, and performance of our contract with your organisation. Marketing
contact, where applicable, rests on consent you can withdraw at any time.
When AI Insights is active for your account, we process aggregated, derived
figures from your benchmark data — domain-level position counts, named metrics
with their percentile and sample-size figures, prevalence figures, and your
peer-group size — to generate plain-language descriptive summaries. **Individual
salaries and base-pay levels are not used.**
Generation is performed by our AI sub-processor, Anthropic PBC, which
processes the figures on our instructions and, under its commercial API terms,
does not retain them or use them to train its models (see the Sub-processor
List). Our lawful basis is legitimate interest (Art. 6(1)(f)), supported by a
Legitimate Interests Assessment; AI Insights are on by default and you can turn
them off at any time in Settings. The output is descriptive only and makes no
automated decision with legal or similarly significant effect (Art. 22 does not
apply). Cached summaries are regenerated when your underlying data changes. See
the AI Insights Terms for full detail.
We keep personal data only as long as we need it:
• Account data (your name, email, role and consent records) is kept while your
account is active. If your organisation leaves lumi, or you or your organisation
ask us to delete your data, it is removed from live systems within 30 days of
the request (see the Data Sharing Agreement, §5.2). Residual copies in our
encrypted backups then expire under our backup rotation **within a further 35
days**, after which no copy remains.
• Benchmark submissions are versioned per collection window and retained as
anonymised historical snapshots so trends stay meaningful; these carry no personal
identifiers.
• Sign-in and security records are short-lived by design: sessions expire after
14 days, and password-reset links after 2 hours.
You may request access to, correction of, or deletion of your personal data,
and you may object to or restrict certain processing. To exercise any right,
contact your organisation's lumi Admin, or email us at dpo@lumihr.co.uk.
See the separate Cookie Policy for how we use cookies and similar
technologies.
We may update this notice from time to time; material changes will be posted
here with a revised effective date.