Privacy

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 (Australian Credit Licence No. 391396)

• Hood Sweeney Consulting Pty Ltd including the registered business name Blue Jam and

trading as Blue Jam

• Hood Sweeney Technology Services (‘Hood Sweeney Technology Pty Ltd’)

• 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 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.

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;

• 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 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, 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

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/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

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 (credit representative no. 537848) 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