Note: During the present COVID-19 Pandemic, a number of Hood Sweeney employees shall be working remotely. Where this occurs we will make use of secure network connections, appropriate levels of security precautions against malicious access to our systems, and full instruction of our employees as to their confidentiality and privacy responsibilities.
Within the Hood Sweeney Group we are committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you.
The Hood Sweeney Group comprises:
- Hood Sweeney Accounting & Business Advisory
- Hood Sweeney Securities Pty Ltd (Australian Financial Services Licence No. 220897)
- Hood Sweeney Finance Pty Ltd (Australian Credit Licence No. 391396)
- Hood Sweeney Consulting and Performance Coaching
- Hood Sweeney Technology Pty Ltd
Any mention of ‘Hood Sweeney” in this policy refers to all of the above.
Hood Sweeney abides by the Australian Privacy Principles established under the Privacy Act 1988 (Cth) (“Privacy Act”) and the credit reporting provisions under Part IIIA of the Privacy Act.
Further information regarding privacy may be obtained by visiting the website of the Office of the Australian Information Commissioner at www.oaic.gov.au/.
Your personal information
Our ability to provide you with a comprehensive accounting, financial planning, finance, technology and business advice service is dependent on us obtaining and holding detailed information that personally identifies you, and/or contains information or an opinion about you ("personal information") and personal information that is collected in connection with a credit application (including credit in the form of invoice terms of 7 days or more), such as ID information, default information or repayment history information (“credit information”).
Personal information held, used and disclosed by Hood Sweeney may include the following information:
- Your name, date of birth, current addresses, telephone/mobile/fax numbers, e-mail address;
- Your bank account details, taxation details, Medicare number, pension card number, and accounting and financial information;
- Information regarding your dependents and family commitments;
- Your occupation, employment history and details, family commitments and social security eligibility;
- Your financial needs and objectives;
- Your assets and liabilities (current and future), income, expenses;
- Your superannuation and insurance details;
- Your social security entitlements;
- Your risk profile details; and
- any other relevant information that you give to us for the purpose of providing you with our services.
We are required pursuant to the Corporations Act 2001, the Code of Professional Conduct of CPA Australia, the Code of Professional Conduct of Chartered Accountants Australia and New Zealand, the Rules of Professional Conduct of the Financial Planning Association of Australia, the Code of Practice of the Mortgage and Finance Association of Australia and the National Consumer Credit Protection Act 2009, to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients. If you elect not to provide us with the information referred to above, the appropriateness or adequacy of advice given to you may expose you to higher risks in respect of the recommendations made.
If you choose not to provide certain personal information or provide incorrect information, we may not be able to provide you with the services that you have requested or the advice and/or recommendations may be inappropriate or inadequate.
In order to provide you with advice in relation to certain types of insurance products, we may be required to collect information from you about your health and medical history. Any health information provided to Hood Sweeney by you will be handled in accordance with this Policy.
Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record (“sensitive information”).
This is subject to some exceptions including: when the collection is required by law; and when the information is necessary for the establishment, exercise or defence of a legal claim. Personal information will be treated as confidential information and sensitive information will be treated highly confidential.
You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.
We will assume that the personal information that you provide to us is accurate, complete and up to date. In the event that any of your personal information changes, please contact us as soon as possible and we will amend our records.
How we collect personal information
Hood Sweeney collects personal information in a number of ways, including:
- Directly from you, when you attend a face-to face interview;
- Directly from you, when you provide information through a data collection form;
- Directly from you, when you provide information by phone;
- Directly from you via an email, our website or the internet; and
- Directly from third parties such as banks, financial institutions, fund managers, superannuation funds, life insurance companies and other product issuers and any other businesses we work with once you have provided us with authorisation to do so.
You have the right to refuse us authorisation to collect information from a third party.
COVID-19 Health Information
As part of our response to the COVID-19 pandemic, Hood Sweeney is presently collecting information regarding visitors to our office. When you attend our offices we collect:
- Your name
- Details about your current health (eg. whether or not you have had flu like symptoms)
- Whether you have travelled interstate or internationally recently
- Your contact details
- Details of your visit.
The information is collected to ensure that, in the unlikely event of a COVID-19 case we are able to assist contact tracers. It is also collected to ensure that we are managing the risk when visitors attend our offices.
Your information will be stored on our secure online servers for a period of 60 days and will then be deleted.
You may choose not to provide the above information, however if you do we reserve the right to deny you entry to our offices. By providing this information to us, you consent to it being handled in the manner detailed above.
How we use your personal information
Primarily, your personal information is collected, held, used and disclosed in order to:
- provide the services you have requested whether that be accounting services, financing, comprehensive and/or limited financial planning services, consulting and performance coaching or technology services to you;
- enable you to access and use our website and services;
- to obtain feedback from you regarding our services;
- to communicate with you, including to coordinate events we hold that you may be invited to or attend;
- comply with our legal obligations; and
- for any purpose related to the above.
From time to time, we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you. If, at any time, you do not wish to receive this information any further, you may contact us with this request (refer to the “Complaints resolution” section for contact details). We will endeavour to meet your request within 2 weeks. We maintain a Register for those individuals not wanting to receive direct marketing material.
Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.
When do we disclose your personal information
Hood Sweeney's philosophy is based upon providing an integrated business services approach. Consequently, your personal information may be shared with any one of Hood Sweeney’s associated entities, for the purpose of providing the services detailed in the "How we use your personal information" section.
For the purposes set out above, we may disclose your personal information to organisations outside Hood Sweeney. The organisations to which we disclose information may include:
- superannuation fund trustees, banks/financial institution, ASIC, ATO, regulators, mortgage aggregators, insurance providers, fund managers and other product providers in order to implement your financial plan/recommendations;
- compliance consultants to ensure that our representatives are meeting our compliance standards;
- mailing houses;
- your professional advisers, including your solicitor or accountant as authorised by you;
- information technology service providers to manage our IT systems;
- third party suppliers, software providers and service providers such as SMSF cloud based software providers, accounting cloud based software providers (including software providers who create plug-ins or add-ons to the software we use), marketing and email automation software providers and feedback/survey software providers;
- another authorised representative of The Hood Sweeney Group if necessary;
- a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence
- a new owner of our business that will require the transfer of your personal information; and
- any other businesses we work with where we have collected your information for the purpose of providing services to that other business.
In addition, we are required, under the Code of Professional Conduct of CPA Australia, the Code of Professional Conduct of Chartered Accountants Australia and New Zealand, the Rules of Professional Conduct of the Financial Planning Association of Australia, the Code of Practice of the Mortgage and Finance Association of Australia, to make certain information available for inspection by the Associations on request to ensure ongoing compliance with mandatory professional standards.
Hood Sweeney takes reasonable steps to ensure that our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Hood Sweeney.
Hood Sweeney takes its obligations to protect your information seriously, this includes when we operate throughout Australia and overseas, as part of our operations some uses and disclosures of your information may occur outside your State or Territory and/or outside of Australia. We may disclose personal information outside of Australia to accounting/book-keeping service providers located in the Philippines.
Hood Sweeney utilises cloud based computing systems and software, including feedback/survey software and data storage and as such data maintained by Hood Sweeney may be disclosed and stored outside Australia, including in the United States of America, Netherlands, Ireland, Singapore, New Zealand and Hong Kong.
How we store and secure your personal information
We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure, including:
- We keep your personal information in your client file. These files are accessible to authorised personnel only and are appropriately secured out of hours.
- Your personal information may also be held on our computer database. All computer-based information is protected through the use of access passwords. Data is backed up regularly and stored securely off site.
- We train our staff about how to keep your personal information safe and secure.
- We have firewalls, intrusion detection and virus scanning tools to stop viruses and unauthorised access to our systems;
- We destroy and de-identify data when it is no longer required
- Where we use external software (including cloud based products) we take reasonable steps to ensure that the software is provided by a reputable vendor who takes reasonable steps to secure your personal information. For example, if we use an add-in for Xero (a cloud based accounting software service) we will only use add-ins that have been vetted by Xero against their minimum security standards. Whilst we will always act when we are made aware of any failure of a third party provider to keep personal information secure, as the information is stored and/or processed by a third party, we are limited in the impact we can have on how your information is handled other than our initial due diligence processes.
Hood Sweeney is subject to various legislative requirements that may require us to keep all personal information and records for a period of up to 7 years. Therefore, if you are no longer a client of Hood Sweeney, we may maintain your personal information on or off site in a secure manner for up to 7 years. After this, we will ensure it is destroyed in a secure manner.
Ensure your personal information is correct
Hood Sweeney takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date.
To ensure we can maintain this level of accuracy and completeness, we recommend that you:
- Inform us of any errors in your personal information as soon as possible; and
- Update us with any changes to your personal information as soon as possible.
Where we have provided personal information about you to a third party provider and you instruct us to notify the third party provider with the updated information, Hood Sweeney will take reasonable steps to provide notification unless it is impractical or unlawful to do so.
Should Hood Sweeney refuse the request by you to correct personal information, we will provide a written notice that explains the following:
- the reasons for the refusal except to the extent that it would be unreasonable to do so; and
- the mechanisms available to complain about the refusal; and
- any other matter prescribed by the Privacy Act.
Should Hood Sweeney refuse to correct the personal information as requested by you and you request us to provide a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to do so in such a way that will be apparent to users of this information.
Access to your personal information
You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) and we will (subject to certain exceptions) provide you with access to that personal information. Access to the requested personal information may include providing you with copies, the opportunity for inspection or with a summary. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.
In the event we refuse you access to your personal information, we will provide you with a written explanation for that refusal.
We will endeavour to respond to any request for access within 14 - 30 days depending on the complexity of the information and/or the request. If your request is urgent, please indicate this clearly.
You will not be charged a fee for making a request to access your personal information. However, if at the time of making the request you are no longer a client of Hood Sweeney , and Hood Sweeney incurs any costs in providing you access to your personal information (such as fees to retrieve information from off-site storage) we may pass those costs on to you at our discretion. If charges are applicable in providing access for you, we will disclose these charges to you prior to providing you with the information, so that you have the discretion of proceeding or not.
Disclosing information to credit reporting bodies
We do not disclose any of your credit information to credit reporting bodies including for the purpose of requesting a credit check on you.
To process your job application, we will collect, use and hold your information such as: full name; resume; email address; phone number; current company/employment information; a description of your right to work in Australia; salary expectations; current notice period; information from social media; and any other information pertaining to relevant experience or your suitability for the advertised job.
Hood Sweeney collects, holds, uses and discloses personal information for the following purposes, in addition to any purposes set out above:
- assessing your job application;
- performing reference checks (including personal references) and conducting background enquiries;
- verifying any information provided by you to us (including identification);
- any other purpose necessary to process your job application, and
- notifying you of other roles with us that may be suitable for you or that you may be interested in.
Unless you request otherwise, we will retain your personal information to allow us to consider you for future roles that may be suitable or to notify you of such roles.
In addition, we may disclose and/or collect your personal information from the following entities, in addition to any entities set out above:
- recruitment software providers
- referees provided to us
- recruitment agencies
- social media providers
- the Australian Federal Police (i.e. police checks), and
- other third parties that provide services used by us to process and assess your application.
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Further information and complaints resolution
11-16 South Terrace, ADELAIDE SA 5000
1300 764 200
(08) 8232 1968
If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner using any of the following details:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992