Privacy
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.
Note: In cases where Hood Sweeney employees work remotely 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.
Our Commitment
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 Pty Ltd’)
• Hood Sweeney Securities Pty Ltd (Australian Financial Services Licence No. 220897)
•Hood Sweeney Finance Pty Ltd is an Authorised Credit Representative (Credit Representative Number 537848) of BLSAA Pty Ltd (Australian Credit License # 391237)
• Hood Sweeney Consulting Pty Ltd including the registered business name Blue Jam and
trading as Blue Jam
• Hood Sweeney Technology Pty Ltd including the registered business name Orlo One and trading as Orlo One
• Hood Sweeney Corporate Services 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/.
This Privacy Policy sets out how the personal and credit information (jointly referred to as
“personal information” in this Policy) you provide to us, and our representatives, is collected,
used, held, disclosed and disseminated.
By providing your personal or credit information to us, you consent to us collecting, using and
disclosing your personal and/or credit information in accordance with this Privacy Policy.
We may change this Privacy Policy from time to time by publishing changes to it on our
website. We encourage you to check our website regularly for any updates to our Privacy
Policy.
Your personal information
Our ability to provide you with a comprehensive accounting, financial planning, finance,
technology, consulting 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 Financial Advice Association Australia Professional Code,
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.
If you provide Hood Sweeney with personal information about someone else, you must ensure
that you are authorised to disclose that information to Hood Sweeney and take reasonable
steps to ensure the individual concerned is aware of and/or consents to the various matters
detailed in this Privacy Policy, including the fact that their personal information is being
collected, the purposes for which that information is being collected, the intended recipients
of that information, the individual's right to obtain access to that information, Hood Sweeney’s
identity, and how to contact Hood Sweeney.
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.
Note: From time to time Hood Sweeney performs services on behalf of our clients that involve
us collecting personal information. This could be, for example, where we conduct a
recruitment process, marketing campaign or survey for our clients. Where this occurs, Hood
Sweeney may collect information about you, which may include personal information
regarding one or more of:
• your personal circumstances and/or those of your family;
• your opinions on certain matters;
• information included in a job application;
• your preferences; and
• other information relevant to the task we have been engaged to conduct on behalf of a
client.
Where this occurs, we will notify you as to the identity of our client before providing them with
your information, but will then provide that information to our clients. Certain of our clients will
be entities covered by the Privacy Act, in which case you should refer to their privacy policy
before supplying us with your information. Other clients may not be bound by the Privacy Act,
in which case you should enquire with them directly as to how they will handle your personal
information before supplying it to us.
The terms of this policy as they relate to job applicants will apply where we conduct a
recruitment campaign for a client, save that the information referred to in that section would
then be provided to our client to enable them to consider job applicants.
If we offer you access to a Third-Party Service, or make use of a Third-Party Service to provide products or services to you, this service
may collect information such as your name, address, age, contact details and email address, account information and passwords,
any alias used, social media account handles, account photos, gender, demographic data, contacts including contact
information, credit card details, ID documents including drivers licence, passport and government issued ID,
personal legal and other documents, information from linked third-party services and credit bureaus,
information from surveys and feedback, call centre recordings and chat or text records, and information
from your device and browser such as your IP address, user credentials, device and browser information including
identification details, website and connection logs, service usage, user preferences, geo-location,
computer and connection information, cookie or web beacon information, content and
metadata in content uploaded or created, photos, details of products and services provided
any messages comments or communication via the service or otherwise, including complaints,
requests or queries, interaction with emails, statistics on page views, clicks and interaction, referral information and
information displayed on screen during remote connections and recordings of such information via session replays.
Certain features may have access to your device and store information locally on that device. If you are applying for, or managing,
a product that requires access to your health or other Sensitive Information (such as insurance, retirement,
wealth management or superannuation products and services), we will provide this information to enable the Third-Party Service to consider
your application, provide you with, manage, or otherwise deal with any product or service you have sought via Hood Sweeney through that Third-Party.
Collection of your Personal Information by Third-Party Services is subject to change and
governed by their individual Privacy Policies available on their website. Should you access a
third-party service offered by us, we suggest you read their Privacy Policy to understand what
information they collect, use and share. If you aren’t sure which Third-Party Services are being
used in relation to your Personal Information, please ask us.
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;
• Directly from third parties such as our clients, 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, or where
doing so is necessary for us to provide our products and services to our clients;
• From third parties where we are checking references in relation to a job application either
for a person to be hired by Hood Sweeney or where we are conducting a recruitment
process for a client’.
You have the right to refuse us authorisation to collect information from a third party.
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;
• to provide services to our clients;
• to review and improve the quality of our services, and to ensure our compliance with regulatory and legal requirements;
• verify your identity pursuant to the Anti-Money Laundering and Counter-Terrorism
Financing Act (AML/CTF Act) when we provide you with a designated service (as defined
in the AML/CTF Act); 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.
Where we offer you access to a Third-Party Service, or where we use a Third-Party Service to
provide products or services to you, that service may collect and use your Personal
Information. This use may be to enable them to undertake a request made by us on your behalf
(such as applying for a product, making an enquiry, managing a product or service, or using
their service to provide an output useful in the provision of services to you). Third-Party Services
may use that information:
• to verify identify and accounts;
• for targeted advertising and general marketing purposes;
• to analyse and improve their site and services;
• to minimise risk, prevent, investigate and monitor for fraudulent, suspicious or illegal activity;
• for research, reporting and analytics;
• for training and quality assurance purposes;
• administrative and business development processes;
• to build algorithms and develop new products and services;
• to label and detect components in images, label raw data and translate audio
soundtracks;
• to communicate with you;
• to process transactions;
• undertake credit checks;
• to process applications, determine premiums and underwrite policies;
• to assess, process and manage claims;
• for reinsurance purposes;
• assessing guarantees (made by or for you);
• to manage and administer eligible discounts, cashback and rewards;
• for business functions conducted with or by related entities such as compliance reporting,
claims and risk management;
• share with external dispute resolution agencies;
• to participate in third party acquisition or potential acquisition of an interest in the third
party service or its assets;
• to send invoices and update you about the service;
• to connect you with other third-parties and manage such relationships;
• to verify eligibility for and deliver prizes in connection with promotions, contests and
sweepstakes; and
• to make inferences about you.
Third-Party services may also share your information with additional Third-Parties and may
process personal information using automated methods including artificial intelligence.
Use of your personal information by third-party service providers is subject to change and
governed by their individual Privacy Policies available on their website. Should you engage
with a Third-Party Service offered by us, we suggest you read their Privacy Policy to understand
what information they collect, use and share, and always ask us if you aren’t sure which (if
any) Third-Party Services are being utilised when we complete work for or with you.
Where we communicate with you, or assist our clients to communicate with you, via email to
provide newsletters and invitations to events, Hood Sweeney may use a Third-Party Service
Provider (such as Mailchimp or Swift) to automate the transmission of those emails. If you optin
to receive these email communications this is considered you accessing a Third-Party
Service. You can opt-out of receiving these emails at any time by following the unsubscribe
link in those emails.
From time to time Hood Sweeney may be given access to the mailing lists and email
management software used by our clients. Where that occurs, we will only use your information
to assist our clients. If your information is used for direct marketing by one of our clients, we will
only use it for this purpose if our clients have confirmed to us that you consented to the use of
your personal information in that manner.
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, mortgage aggregators,
insurance providers, fund managers and other product providers in order to implement
your financial plan/recommendations;
• compliance and quality improvement consultants to ensure that our representatives are meeting our compliance
standards and that the quality of the services we provide you meet our (and all regulatory) standards;
• mailing houses;
• your professional advisers, including your solicitor or accountant as authorised by you;
• information technology service providers to manage our IT systems, websites and web
apps;
• third party suppliers, software providers and service providers such as SMSF cloud-based
software providers, electronic signature cloud-based providers, accounting cloud-based
software providers, administrative service providers, marketing and email automation
software providers and feedback/survey software providers;
• credit reporting bodies, in certain circumstances only and in accordance with the Privacy
Act (see Disclosing Information to Credit Reporting Bodies);
• 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;
• our clients where we are conducting a service for them such as a recruitment process,
marketing campaign or survey;
• a new owner of our business that will require the transfer of your personal information; and
• any other business 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 Financial Advice Association Australia Professional Code, 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/bookkeeping,
administrative or IT managed service providers located in the Philippines and India.
Hood Sweeney utilises cloud-based computing systems and software, including
feedback/survey software, electronic signature software, and data storage and as such data
maintained by Hood Sweeney may be disclosed and stored outside Australia, including in
Austria, Bahrain, Belgium, Bermuda, Brazil, Canada, China, Columbia, Denmark, Fiji, Finland,
France, Germany, Guernsey, Ghana, Greece, Hong Kong, India, Indonesia, Ireland, Italy,
Japan, Kenya, Korea, Luxembourg, Malaysia, Mauritius, Mexico, Netherlands, New Zealand,
Norway, Papua New Guinea, Philippines, Poland, Romania, Serbia, Singapore, South Africa,
Spain, Sweden, Switzerland, Taiwan, Thailand, the European Union and the European
Economic Area, the United Arab Emirates, the United Kingdom, the United States of America, Turkey
and Vietnam.
Additionally, when we provide services to you, we may make use of Third Party Services,
meaning that we provide information to them that may be handled in offshore locations. Whilst
this Privacy Policy explains how and why we provide your information to Third-Party Services,
you should always ask us if you wish to receive information about which particular services we
will use when we work together. Each of these services has its own privacy policy that you
should always familiarise yourself with. If you are not sure which Third-Party Services are used in
relation to our work with you, please ask.
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 computerbased
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 (subject to legislative requirements as per below and as
reasonably practicable) and ;
• 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 at least 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 in line with legislative requirements (if any).
We utilise offsite document and record storage facilities to hold archived documents in hard
copy. These facilities are run by third parties but hold those documents securely within South
Australia.
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 may disclose information, with your express consent, to a credit reporting body, including
those listed below (CRBs), for the purpose of verifying your identity pursuant to the AML/CTF
Act, using third party verification sources, including Document Verification Services , when we
provide you with a designated service (as defined in the AML/CTF Act). We do not authorise
CRBs to access your credit file or credit data for this purpose.
Hood Sweeney Finance Pty Ltd is an Authorised Credit Representative (Credit Representative Number 537848) of
BLSAA Pty Ltd (Australian Credit License # 391237) is authorised to provide credit assistance under
the National Consumer Credit Protection Act. For Hood Sweeney
Finance Pty Ltd clients only, we may, with your express consent, disclose your credit information
to CRBs for the purpose of requesting a credit check on you when we provide you with credit
assistance. The disclosure of your credit information is limited to:
• your identity details, such as name, address, contact numbers and email address;
• the fact that you have applied for credit and the amount;
• repayment history information, including details of credit you have applied for
including but not limited to dates of credit contracts, due dates for repayments,
repayment history and any related information;
• in specified circumstances, default information (including payment information if you
pay a defaulted amount previously listed with a credit reporting body);
• advice that payments are no longer overdue and the date on which overdue
payments were made;
• in specified circumstances, our opinion that you have committed a serious credit
infringement; and
• the fact that credit provided to you has been paid or otherwise discharged (including
the date of discharge).
We disclose your credit information to the following CRBs. Each of these CBRs are required
under the Privacy Act to have a policy which explains how they manage your personal and
credit information. You can obtain their policy by contacting directly.
The CRBs we deal with are:
Equifax
Call: 13 83 32
Mail: PO Box 964 North Sydney NSW 2059
Email: customerserviceAU@equifax.com.au
Website: www.mycreditfile.com.au
Job applicants
The following terms apply both to when you apply for a job with Hood Sweeney, or when you
apply for a job with one of our clients, and we are engaged to assist in the recruitment or
testing processes. The only difference between these two scenarios is that in the case of us
providing a recruitment service to a client, we will additionally provide information and
opinions which we collect, create or otherwise form to our client for the purpose of progressing
your job application. The words below should be read in that context if you are applying for a
job with one of our clients.
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. We may additionally ask questions as to your vaccination
status and other health or medical information we believe relevant to assessing your ability to
perform the advertised job. We may additionally require you to undertake psychometric
testing and obtain results from the testing, which might include a report by a testing provider
on your results.
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);
• complying with our work, health and safety obligations;
• 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.
From time to time, Hood Sweeney may obtain personal information about you from publicly
available sources, or social media platforms on which you have a profile. Generally this will
occur where we are seeking to target candidates for positions either with Hood Sweeney, or
with a client we work for.
When we contact you via those platforms, we will tell you how to find this policy, and will also
ensure that your information is only used for the purposes of potential recruitment opportunities.
If you do not wish to be considered for such opportunities, please let us know and we will ensure
that the only information we retain is your preference not to be contacted in future.
If we do contact you as part of a recruitment process for a client, we may pass your personal
information to that client so that they can consider whether you are an appropriate candidate
for the relevant position. If you require details of to whom we have passed your personal
information, and the details of their privacy policy (if relevant), please contact us on the
contact details below.
Information regarding our employees
In general, information about employees is not regulated by the Privacy Act. There may,
however, from time to time be instances where we collect information about our employees
that are not directly related to their employment. If that occurs, we will generally only collect
the information with their knowledge and consent to provide them with access to employee
benefits (such as lifestyle and health offerings), to manage social events, or to provide other
ancillary services. We will only provide this information to third parties if it is either approved by
them, or if we reasonably conclude that they would consent to the disclosure if asked (such
as if they opt-in to a lifestyle offering and we pass their name on to the providers of that
offering). If you have any questions about how we handle employee personal information,
please contact the Privacy Officer.
Our website
Hood Sweeney’s website provides links to third party websites. The use of your information by
these third-party sites is not within the control of Hood Sweeney and we cannot accept
responsibility for the conduct of these organisations. We are not responsible for the privacy
practices of, or any content on, those linked websites, and have no control over or rights in
those linked websites. The privacy policies that apply to those other websites may differ
substantially from our Privacy Policy, so we encourage you to read them before using those
websites.
Our Website utilises cookies to provide you with a better user experience. Cookies also allow
us to identify your browser while you are using our site – they do not identify you. If you do not
wish to receive cookies, you can instruct your web browser to refuse them.
Further information and complaints resolution
If you would like further information about our Privacy Policy or practices, or to access or
correct your personal information, or complain about any breach or potential breach of your
privacy, please contact the Privacy Officer. Your complaint or request will be acknowledged
within 7 days.
Address 11-16 South Terrace, ADELAIDE SA 5000
Telephone 1300 764 200
Fax (08) 8232 1968
Email privacy@hoodsweeney.com.au
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
www.oaic.gov.au