LUMA – Privacy Notice for the Speaking Test

This notice explains how British Institutes / Domax Ltd processes personal data when a candidate takes the LUMA online speaking test. It should be read before registration and consent.

1. Data controller and contact

The data controller is British Institutes / Domax Ltd. Requests about access, correction, portability, restriction, objection, or erasure can be submitted through the official British Institutes contact channels. Identity verification may be required before a request is completed.

2. Data required to administer the test

The registration form requires first and last name, email address, date of birth, country, native language, and purpose of the test. During the test, LUMA processes microphone audio, the generated transcript, question and timing metadata, technical diagnostics, and the resulting assessment report. These fields are required for the current official test workflow; a candidate who does not provide them cannot start the assessment.

3. Purposes and legal basis

Data is used to register the candidate, administer the speaking test, preserve evidence of the attempt, generate and review the automated assessment, produce authorised report exports, investigate technical or assessment-integrity incidents, and meet certification, contractual, quality-assurance, security, and legal obligations. The applicable basis may include consent, performance of a requested service or contract, legitimate interests in security and quality assurance, and legal obligations.

4. Automated assessment and human review

LUMA uses automated language and audio analysis to estimate speaking performance. Reports may be reviewed or reassessed by authorised administrators. A technical or audio-processing failure is recorded separately from the linguistic result, and unsupported identity or nationality inferences are not used to assess the candidate.

5. Service providers and international processing

The service uses contracted infrastructure and AI providers for hosting, database storage, private audio storage, transcription, and assessment processing. Access is limited to the functions required to provide and secure the service. Transfers outside the candidate's country are handled under the controller's applicable contractual and legal safeguards.

6. Retention

The current default lifecycle retains raw speaking audio and detailed transcript events for up to 180 days after the attempt, unless a shorter period is required or a justified hold applies. Assessment reports and the minimum administrative record may be retained for up to five years for certification, dispute handling, quality assurance, and legal obligations. Operational and security logs are retained according to the configured provider schedules and are subject to redaction. Records may be anonymised earlier when identifiable data is no longer necessary.

7. Security and access

Audio is stored in private storage. Candidate sessions and administrator sessions use signed, time-limited credentials. Access, export, reassessment, deletion, and integrity-repair actions are restricted and audited. No internet service can guarantee absolute security, but reasonable technical and organisational safeguards are applied.

8. Candidate rights

Subject to applicable law and legitimate retention requirements, candidates may request a copy of their data, correction of inaccurate data, restriction or objection, portability where applicable, and erasure. Candidates may also ask for information about the automated assessment and request human review through the official British Institutes process.

9. Consent and withdrawal

Consent is collected before the microphone session starts. Withdrawal does not invalidate processing already carried out and may not require deletion of records that must be retained for contractual, certification, dispute, security, or legal reasons. Withdrawal before starting means the test cannot be administered.

Notice version: 24 July 2026. Retention periods may be shortened by operational configuration or extended only where a documented legal or dispute hold applies.