1. Governance and credentials 

 

• Company registration details (legal entity name, registration number, address) 

We are CJM Lumina Ltd, trading as LuminaFD, and supported by our sister organisation Parris & McNally Ltd. Our company registration number is SC348264.  

LuminaFD offices, and all of their employees and contractors are based in Scotland. Our main office address is 6 Crofthead Road, Prestwick, KA9 1HW. 

• Insurance information 

We are fully insured by Hiscox for employers’ liability, professional indemnity, and public and products liability. 

• Client confidentiality statement  

Our Commitment to Confidentiality 

At Lumina, we recognise that the nature of our work gives us access to highly sensitive financial, commercial and strategic client information. Protecting that information is fundamental to how we operate and to the trust our clients place in us. 

We treat all information received from clients – whether written, verbal, digital, or otherwise – as strictly confidential.  We will not disclose, share or use any client information for any purpose other than to provide our professional services, unless we have the client’s explicit written consent or are legally obliged to do so. All Lumina FD team members, associates and contractors are bound by confidentiality and non-disclosure obligations as part of their engagement terms. 

We maintain appropriate technical and organisational safeguards to protect client data against unauthorised access, alteration, or loss. Where we use third-party systems (for example, cloud-based platforms such as Xero), we ensure those providers meet recognised data protection and security standards. We never sell, rent or trade client information. 

Disclosure Exceptions 

We may only disclose confidential information if: 

• The client provides written consent; 

• The information is already in the public domain (through no fault of ours); or 

• Disclosure is required by law, regulation, or a valid court order – in which case the client will be informed where legally possible. 

Overall, Lumina FD is committed to maintaining the highest standards of confidentiality, integrity, and professional conduct in all our client relationships. Please refer to our Terms of Engagement for full details.  

• Privacy Policy  

Privacy Policy v2025.docx  

• Privacy Statement  

At Lumina, we take your privacy seriously. We collect only the personal information we need to deliver our services and respond to enquiries – typically your name, contact details, and any information you choose to share with us. 

We use this information solely for legitimate business purposes, such as managing client relationships, improving our website, and meeting legal obligations. We never sell or share your personal data for marketing. 

All data is handled securely and in line with the UK General Data Protection Regulations (GDPR), the Data Protection Act (DPA) 2018, and the Data Use and Access Act 2025 (DUAA). We may use trusted service providers (for example, for email or data hosting) who are also bound by these strict confidentiality and security obligations. 

You have the right to access, correct, or delete your personal data, or to withdraw consent at any time. To contact us about your data, please email colin@cjmlumina.co.uk 

For full details, please see our Privacy Policy (insert link) or contact us at our registered office.  If you require this policy in an alternative format (e.g., large print or accessible PDF), please contact us. 

• Cookie policy 

Cookies Policy v2025.docx  

• Accessibility statement  

Our Commitment 

Lumina FD is committed to digital accessibility and inclusive design. We welcome feedback to help us continually improve access for all users. We are committed to ensuring that our website and digital services are accessible to everyone, regardless of ability or technology. We aim to meet or exceed the recognised Web Content Accessibility Guidelines (WCAG) 2.2, as set out by the World Wide Web Consortium (W3C), and to comply with the principles of the Equality Act 2010.  We believe accessibility is fundamental to providing an inclusive, professional service to all our clients and website visitors. 

• Accessibility Policy  

Accessibility Policy v2025.docx  

• Data protection policy 

GDPR Policy v2025.docx 

• Data Protection Statement  

At CJM Lumina Ltd (“Lumina FD”), we take our data protection obligations seriously and are committed to maintaining the highest standards of privacy, security, and compliance in everything we do 

Your Rights 

Under data protection law, you have the right to: 

• Access your personal data (subject access request); 

• Request correction or deletion of your information; 

• Restrict or object to certain types of processing; 

• Withdraw consent (where processing is based on consent); 

• Receive information about how and why we process your data; and 

• Complain to the Information Commissioner’s Office (ICO) if you believe your data has been misused. 

We aim to respond to all valid requests within one month, with the ability to pause (stop the clock) if clarification or identification is required, in line with DUAA 2025. 

CJM Lumina Limited complies with the UK General Data Protection Regulations (GDPR), the Data Protection Act 2018, and the Data (Use and Access) Act 2025. We handle personal data lawfully, securely, and transparently. For full details, contact  colin@cjmlumina.co.uk

• Anti-bribery / anti-corruption statement  

At CJM Lumina Ltd (Lumina FD), we conduct all our business with integrity, honesty, and transparency. We have zero tolerance for bribery, corruption, or any form of unethical conduct. 

We are committed to complying with the UK Bribery Act 2010 and all relevant anti-corruption laws. This includes prohibiting the offer, giving, solicitation, or acceptance of any bribe or improper advantage, whether directly or indirectly, in order to influence business outcomes. 

All Lumina FD directors, employees, and associates are required to act professionally, fairly, and lawfully in all business relationships, avoiding conflicts of interest and ensuring that decisions are made solely on objective merit. 

We expect the same high standards from our clients, suppliers, and partners, and will not work with any party that engages in corrupt practices. 

If you have concerns about unethical behaviour or potential breaches of this policy, you can report them confidentially to colin@cjmlumina.co.uk. 

Lumina FD is committed to ethical, transparent, and accountable business at every level.

• Equality, diversity & inclusion policy (internally and in client work) 

Equality, Diversity and Inclusion Policy v2025.docx  

 

• Equality, diversity & inclusion statement 

At CJM Lumina Limited (Lumina FD), we are committed to creating and maintaining an inclusive working environment where everyone is treated with fairness, dignity and respect. We believe diversity strengthens our business, our people, and the quality of service we provide to clients. 

We provide equal opportunities in all aspects of employment and client engagement, regardless of age, disability, gender, marital or civil partnership status, pregnancy, race, religion or belief, sex, or sexual orientation. Decisions about recruitment, development, and promotion are based solely on merit, ability and performance. 

We are an equal opportunities employer and a responsible consultancy partner. We promote flexible working, make reasonable adjustments for disability, and expect the same commitment to equality and inclusion from our clients, suppliers and partners. 

We are proud to be a Disability Confident Employer, committed to creating an inclusive workplace where everyone has the opportunity to thrive. Being Disability Confident means we: 

• Actively recruit, retain, and develop talented people with disabilities or long-term health conditions; 

• Make reasonable adjustments to remove barriers to work and ensure equal access to opportunity; 

• Foster a supportive, respectful culture where differences are valued, and individual contributions are recognised; and 

• Work continuously to build awareness, challenge bias, and improve accessibility across all areas of our business 

In a recent employee Pulse survey, 100% of our employees either agree or strongly agree with the statement ‘I feel a sense of belonging and inclusion at work’ 

If you would like further details, please see our full Equality, Diversity & Inclusion Policy, or contact colin@cjmlumina.co.uk for more information. 

• Environmental / sustainability policy  

Environmental Policy v2025.docx  

 

• Environmental / sustainability statement 

At CJM Lumina Ltd (Lumina FD), we are committed to conducting our business responsibly and sustainably — minimising our environmental impact while supporting long-term social and economic wellbeing. Environmentally, we follow a carbon reduction plan and recently improved our EPC rating and switched from paper to digital in 2024 as can be seen in the articles section. 

Our environmental policy is built on the principles of continuous improvement, compliance, and accountability. We align our practices with the core values of ISO 14001, ensuring that environmental considerations are integrated into all aspects of our operations and decision-making 

Lumina FD is committed to responsible, sustainable business — reducing waste, lowering carbon emissions, and continually improving our environmental performance 

 

• Cyber Security / information security policy  

Cyber Security Policy v2025.docx  

• Cyber Security statement (public) 

Our Commitment 

CJM Lumina is committed to safeguarding our clients’ financial and personal information by maintaining a resilient, secure digital environment. Through certified systems, trained people, and robust processes, we ensure the confidentiality and integrity of all data entrusted to us. 

• Responsible AI Policy  

Responsible AI Policy v2025.docx 

• Responsible AI statement 

At CJM Lumina Limited (Lumina FD), we recognise the transformative potential of Artificial Intelligence (AI) and automation in improving financial insight, efficiency, and decision-making.  We are equally committed to ensuring that any use of AI technologies within our business — or in the services we provide — is ethical, transparent, and aligned with our professional values and legal obligations. Lumina FD uses AI responsibly and transparently — ensuring every application of technology upholds fairness, data protection, and professional human oversight. 

Our Commitment to Responsible AI 

We follow five guiding principles in the use and evaluation of AI tools, consistent with national and international frameworks for trustworthy AI: 

1. Transparency and Accountability 

• We are open about how and where AI tools are used in our work. 

• All AI-assisted outputs are reviewed and validated by qualified professionals before client use. 

• Responsibility for AI-assisted decisions remains with human experts — never delegated to automated systems. 

1. Fairness and Non-Discrimination 

• We assess AI tools for potential bias and take steps to ensure that automated processes do not produce discriminatory or unfair outcomes. 

• We use AI only in ways that are consistent with our Equality, Diversity & Inclusion Policy and the principles of fairness and respect. 

1. Privacy and Data Protection 

• Any AI system that processes personal or client data must comply fully with the UK GDPR, Data Protection Act 2018, and Data (Use and Access) Act 2025 (DUAA). 

• Personal or confidential data is never shared with AI systems that do not guarantee security, lawful processing, and data minimisation. 

1. Security and Reliability 

• AI systems are subject to the same security, integrity, and performance controls as all other digital technologies under our Cyber Security Policy. 

• We use only reputable, secure, and compliant AI providers that align with ISO/IEC 42001 and Cyber Essentials standards. 

1. Human Oversight and Professional Judgement 

• AI supports — but never replaces — human expertise. 

• All financial analysis, recommendations, and client deliverables are ultimately produced or approved by qualified professionals within Lumina FD. 

Our Approach 

• We use AI tools cautiously and responsibly, primarily to enhance efficiency, support analysis, and improve data quality. 

• We do not use AI for autonomous decision-making in client engagements. 

• We continually review the ethical, legal, and security implications of AI technologies and provide staff training to ensure responsible use. 

• We are committed to ongoing evaluation of emerging AI regulations and adapting our policies accordingly 

 

• Modern slavery Policy  

Modern Slavery Policy v2025.docx 

• Modern Slavery statement  

Our Commitment 

CJM Lumina Ltd is committed to conducting all business operations ethically and responsibly. We have zero tolerance for modern slavery, human trafficking, forced labour, or any form of exploitation in our own business or in our supply chains. 

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps CJM has taken during the financial year 2025-26 to prevent modern slavery and human trafficking in our operations and supply chains. Whilst we are not a large enough organisation to be required to do this by law, we like to take a proactive approach. 

Quality management statement 

Our Commitment to Quality 

At Lumina, we are committed to delivering excellence in every aspect of our work. Quality for us means accuracy, reliability, and consistent value for our clients. We operate structured internal processes designed to maintain the highest professional standards – from initial engagement through to project delivery and ongoing support. 

Our leadership team actively promotes a culture of continuous improvement, encouraging feedback, professional development and innovation across our organisation. Every team member takes responsibility for the quality of their work and adheres to clearly defined review and assurance procedures. 

We benchmark our practices against recognised quality management standards and regularly review our systems to ensure they remain effective, efficient, and aligned with client needs. Our aim is simple: to exceed expectations through dependable, high-quality service, every time.  Overall, we adhere strictly to CIMA guidelines in terms of quality management, and are certified by them annually.