Confidentiality Regime

Version 1.0 · Effective from Monday 31 August 2026

Version. 1.0

Effective from. Monday 31 August 2026

Review. Annually.

Published at. bonsai.law/circle/confidentiality

1. One regime, everywhere

The Bonsai Circle runs on a single confidentiality regime. It applies in the room, on the forum, and in every one-to-one contact that arises from a Circle introduction. It is written into the Terms of Membership. It is signed on application and confirmed on renewal.

2. Chatham House Rule, in full

Everything said in a Circle meeting or posted on the Circle forum is usable by members afterwards. Nothing is attributable outside the Circle without the express consent of the person who said it or posted it.

That means:

(a) you can act on information you learn in the Circle;
(b) you cannot say "X said in the Circle that…" outside the Circle;
(c) you cannot identify a member as the source of information, whether or not you use their name;
(d) you may say generally that a view or piece of information came from your professional network, provided you are not identifying an individual member.

3. No recording

No recording of any kind, by anyone, ever.

In-person meetings: phones face-down on the table. If you must take a call, leave the room.
Online meetings: Microsoft Teams recording is disabled at the tenant level. Local recording (screen recorder, phone camera pointed at monitor, dictaphone) is a removal offence.
Notes for your own use are fine. Notes shared, published, or transcribed for another audience are not.

4. No screenshots

No screenshots of the member area, the forum, or an online meeting. If you need something for your own reference, ask us and we will send you the underlying document or a paraphrased extract.

Every page rendered to you in the member area, on the forum, and in the direct-message function carries a faint identity watermark tied to your session. You have consented to this by joining. It does not identify you to other members. It is decoded only if we investigate a suspected leak. See section 11 of the Privacy Notice.

5. No off-platform Circle group

No WhatsApp group.
No Signal group.
No Facebook group.
No LinkedIn group named or branded for the Circle.
No mailing list run off-platform in the Circle's name.
No "unofficial" Circle chat.

All Circle-branded group communication runs on the moderated forum at bonsai.law/circle/forum.

The Circle provides a native direct-message function for one-to-one contact between members. Direct messages are watermarked, visible to the founders, and subject to this regime in full. Members may also continue one-to-one contact off-platform for their own commercial or professional reasons, provided that off-platform contact complies with this regime.

6. Enforcement of this regime

Enforcement of this regime is by member reporting.

Posts, edits and direct messages on the Circle platform are published immediately and are not read by the founders before publication or delivery. If you become aware of content on the platform that you consider breaches this regime - a recording or screenshot reference, an attribution outside the Circle, an off-platform group established from Circle contacts, an unauthorised disclosure - use the flag button on the item to report it to the founders.

The founders review flagged items and decide to leave the item in place, edit, redact, remove or escalate under the Complaints, Concerns and Removal Procedure. The decision, with a short reason, is recorded and communicated to the poster. Safeguarding-adjacent items and confidentiality-core breaches are acted on immediately.

The confidentiality core (no recording, no screenshots, no off-platform Circle groups) is enforced by member reporting, by removal for cause on evidence, and by the ordinary sanctions in the Terms of Membership and the Code of Conduct. Members are asked to report suspected confidentiality-core breaches promptly.

Automated pre-publication screening is planned for a future release. Before we introduce it we will publish an Automated Decision-Making Disclosure and update this regime.

7. Your existing professional confidentiality obligations

You remain bound at all times by the professional confidentiality obligations imposed by your own occupation, employer, or regulator. That includes but is not limited to:

SRA obligations for solicitors (rule 6 of the SRA Code of Conduct);
ICAEW, ACCA and CIOT obligations for accountants and tax advisers;
FCA client confidentiality rules;
medical and dental council patient-confidentiality rules;
your employer's own contractual confidentiality obligations;
client instructions and non-disclosure agreements binding on you.

The Circle is not a shortcut around your own confidentiality obligations. Client information appears in Circle discussions in hypothetical form. Anything more requires your own professional judgement and, where appropriate, your client's consent.

8. Consent to identify

You may, of your own accord, choose to identify yourself as the source of something you said or posted. That is your choice. Once you have identified yourself as the source of a particular piece of information, other members may cite you as the source of that specific piece.

You may also give a member express permission to attribute a specific statement to you outside the Circle. Do so in writing on the platform (a direct message on the Circle will do). Do not give blanket permission and do not assume you have it.

9. Guests and visitors

Guests attending a meeting must sign a short confidentiality acknowledgement before the meeting starts. They are subject to this regime for the duration of the meeting and in respect of anything they hear or see. The chair may refuse a guest.

10. When we speak publicly about the Circle

We publish an anonymised annual transparency summary. We may talk about the Circle in general terms - its format, its size, its principles - to prospective members, to media, and in professional publications. We do not identify members without their consent. We do not describe meeting content beyond what a member has explicitly permitted.

11. When you speak publicly about the Circle

You may say that you are a member of the Bonsai Circle. You may refer prospective members to us.

You may not:

describe meeting content beyond what section 2 permits;
identify other members without their consent;
use the Circle's name or logo to endorse a product, service or third party;
hold yourself out as speaking for the Circle;
disclose the identity of an applicant or refused applicant.

12. Breach is a removal matter

Confidentiality breaches - recording, screenshotting, attribution outside the Circle, misuse of another member's information - carry a strong presumption of removal for cause.

Removal is applied through the Complaints, Concerns and Removal Procedure, which gives the member notice of the substance, an opportunity to respond, and the ordinary right of appeal. It is not a summary decision. But the starting point is removal, not warning.

There is no three-strikes indulgence for breaches of the confidentiality core.

Where a breach is inadvertent and no material harm has been done, we may accept an apology and a written commitment in place of removal. That is a founder decision made on the facts and recorded in writing. Members should not rely on it.

13. Legal exceptions

Nothing in this regime prevents you from:

(a) making a protected disclosure under the Public Interest Disclosure Act 1998;
(b) responding to a court order, subpoena, or lawful regulatory request;
(c) reporting a criminal offence to the police;
(d) taking advice from your own lawyer or regulator on a matter that affects you.

Where practicable, tell us before you make a disclosure of Circle content to a third party under an exception. We will not obstruct you.

14. What to do if you think a breach has happened

Report it under the concerns process at bonsai.law/circle/concerns. If the breach involves you as the person whose information was disclosed, tell us as soon as you reasonably can. We will act quickly.