Privacy Policy

Privacy Policy

We are committed to ensuring your privacy is protected.

Our Privacy Statement – how we’ll process your personal information.


We will hold data relating to some or all aspects of your:

  • Identity, place of residence, nationality and right to remain / work in the UK
  • Immediate family relationships
  • Occupation and income
  • Investments and savings
  • Other assets
  • Mortgage and other financial commitments
  • Household budget
  • Existing financial plans
  • Financial goals


Our sources are any one of more of:

  • Our Data Capture and Attitude to Risk questionnaire, completed with your consent and co-operation.
  • Family members, who assured us they had your consent before providing your personal details.
  • Product providers, after you have given us a signed letter of authority to ask for details of your existing plans. 
  • External sources in the public domain, either directly or when verifying your identity and residential status.


We will use the information only for permitted purposes, including:

  • Assessing your financial priorities and needs, and preparing suitable recommendations.
  • Monitoring the performance of your investment products and reporting to you.
  • Ensuring the continued suitability of investment and/or other products we have recommended.
  • Preparing review or renewal recommendations and/or advice when fixed term products mature / expire.


How we safeguard your personal information:

  • All employees and associates receive data security and cyber-crime training, and we regularly assess their continued understanding.
  • We enforce a ‘clear desk’ and a ‘lock-and-key’ policy in respect of any papers that reveal personal information.
  • When stored electronically, personal information is password protected.
  • Passwords are specific to each staff member or associate: we strictly forbid password sharing or disclosure.
  • We closely supervise interns and work placement students throughout their period of placement, and required a signed confidentiality agreement / indemnity. If the intern is aged under 18, we require an adult with parental responsibility to sign the same indemnity.


How we’ll respond to your requests:

  • If you ask for an account of the information we hold about you, we’ll provide it without charge within twenty days
  • If the information we hold is inaccurate or out-of-date and you ask us to correct it, we’ll amend it without undue delay.
  • We are legally entitled to retain personal information for specified reasons even if you ask us to erase it. We will use that entitlement but will quarantine your information, making it available only for the purposes prescribed by law.


We will disclose your personal information to third parties only if:

  • We have your specific prior consent, evidenced in writing.
  • Disclosure to providers is a necessary step in providing advice and/or carrying out our obligations to you.
  • We are compelled by law to disclose your details. NB: If we have any sound reason to suspect financial crime or money laundering, we must inform the National Crime Agency and we must not let you know we have done so.

© 2019 James Ryan Thornhill Ltd, 41 Wollaton Road, Beeston, Nottingham NG9 2RN.
Incorporated in England and Wales. Company Number 03921388. Legal Entity Identifier (LEI) – 213800FS9SZDN6A21K89.
Authorised and regulated by the Financial Conduct Authority, Firm Reference 306095.