Bookkeeper handover notes and AI data leakage: what a staff note gives away in ChatGPT or Claude.

When a bookkeeper moves clients to a colleague, the handover note is written fast and holds everything the colleague needs on day one: where the passwords live, which pay run is tricky, what the owner has been told and what he has not. It is tempting to paste it into ChatGPT or Claude to turn it into a clean checklist. This page marks every item in a realistic handover note that APES 110, the TPB Code and the Privacy Act bear on, including the weekly routine that is safe to share, and shows how the same checklist is produced on Ermos inside the practice.

The bookkeeper handover note

Written by a departing team member when clients move to a colleague, and kept on the client files so the new bookkeeper can start without a gap.

An invented note. The phone number is a placeholder. Hover or tap any highlighted item for the analysis; the full list is below.

What leaves the firm

1. 1
   The people, the clients and a phone number

   Names two staff, two clients and a client’s personal number with his preferred call time. Personal information, and the key that ties everything below to real people and real files. Privacy Act guide.

2. 2
   Where the logins live

   Which password store is used, where a bank token is kept, and who has payroll access. A map of how to get into two clients’ systems. TPB(GS) 55/2026 lists how and where information is stored among the factors a tax practitioner should consider when using AI. TPB Code guide.

3. 3
   An underpayment and a live employment claim

   An employee’s underpayment, and that another employee has a Fair Work Commission application on foot with the records to be left as they are. Sensitive for both employees, neither of whom is the firm’s client. Privacy Act guide.

4. 4
   A director’s private spending

   How a director’s personal spending is coded and the journal a reviewer queried. The firm’s handling instruction and a point of exposure for the client. APES 110 confidentiality guide.

5. 5
   The payment plan and the cash position

   That the client is on a plan, when it starts, that a BAS must not be paid yet and that a lender is watching. The client’s position with two creditors, and an instruction the partner has not yet confirmed with the client. TPB Code guide.

6. 6
   A family loan and a request that a brother not see it

   The lender, the amount, and an instruction about who in the family may see the ledger. A confidence the firm holds inside a family, and an access control that depends on the instruction being followed. APES 110 confidentiality guide.

7. 7
   An elderly man’s memory problems

   A health matter about a named individual, recorded to explain who to call. Health information is sensitive information under the Privacy Act, and the Act applies to the firm where it is covered, with stricter rules on handling. Patient data guide.

8. 8
   The weekly routine

   A generic cycle of reconciliations, payments, pay runs and a balance check, which any practice would write. It names no client, person or figure.

9. 9
   Authority over a client’s bank account

   The limit on payments the bookkeeper may release. AUSTRAC’s guidance says a bookkeeper processing routine payments on fixed client instructions, without discretion to redirect funds, is less likely to be managing the client’s money for designated service item 3, but the facts decide, and the authority is a security matter as well. TPB Code guide.

10. 10
    Who lodges

    That the bookkeeper prepares and a registered agent lodges. TPB guidance says BAS services for a fee or other reward generally require registration, and a bookkeeper used by a registered practitioner is providing tax agent services on the practitioner’s behalf. The wording names the agent but otherwise describes an ordinary procedure. TPB Code guide.

What happens in Frontier Models (ChatGPT, Claude)

• The whole document is transmitted to the provider’s servers. On personal plans the user cannot choose where it is stored or processed, and for the major providers that has generally meant outside Australia, under that country’s legal process. Some business plans offer storage in Australia, but the provider still receives the content.
• On consumer tiers, prompts can be retained and used to train future models.
• The provider’s staff and systems can reach the content under the provider’s own policies.
• Once sent, the firm no longer controls it. Retention and deletion happen on the provider’s terms.

The same document on Ermos

Part of AI data leakage in accounting firms. See how this works in practice: Workpaper review on Ermos.

Common questions