Behaviour support plans and AI: what a restrictive practice record gives away in ChatGPT or Claude.

A behaviour support plan is where the law reaches furthest into a resident’s life. Section 18 of the Aged Care Act 2024 requires that a restrictive practice is used only as a last resort, after alternatives are tried and documented, with the consent arrangements followed and the use monitored. The plan is the record of all of that, which makes it dense, structured and tempting to run through ChatGPT or Claude. This page marks every item in a plan that includes chemical restraint, and shows how the same plan is maintained on Ermos inside the service.

The behaviour support plan

Prepared by the registered nurse with the GP, the resident where possible and the substitute decision-maker, before any restrictive practice is used, and reviewed regularly.

Behaviour support plan
Agnes Thornbury, Room 14B¹ · Version 4, 18 October 2026 · RN B. Santos⁸ · GP Dr P. Nair⁸

Behaviours of concern. Late-afternoon distress with calling out for her late husband, lasting one to three hours. Physical resistance to personal care, including striking staff (four incidents since July, two causing minor injury to staff). Night-time wandering into other residents’ rooms.²

Assessed triggers. Fatigue and low light after 4pm; being approached from behind; male staff during personal care (history of childhood trauma disclosed by daughter); hunger before dinner; pain from the left hip, which she cannot report.³

Alternative strategies tried. Afternoon rest period (partial effect); 1960s music from 3.30pm (good effect); female staff only for personal care (good effect); regular paracetamol for hip pain (moderate effect); daughter’s recorded voice message at 4pm (good effect on three of five days). Documented in progress notes 1 August to 15 October.⁴

Restrictive practice. Chemical restraint: risperidone 0.5mg nocte, prescribed by Dr Nair on 2 September for behaviours causing risk of harm to self and others, after the alternatives above were insufficient on their own. Reviewed 18 October: behaviours reduced in frequency; continue for a further eight weeks and review. Environmental restraint: sensor mat and closed (unlocked) door overnight.⁵

Consent. Mrs Thornbury lacks capacity to consent (assessed by Dr Nair, 28 August). Informed consent given by her enduring guardian, Carolyn Thornbury-Wu, on 1 September, in writing, after discussion of risks including increased falls and stroke risk with risperidone. Consent to be reconfirmed at each review.⁶

Monitoring. Behaviour charting each shift. Falls risk reassessed fortnightly. Any increase in sedation, falls or swallowing difficulty to be reported to the RN and GP the same day.⁷

An invented plan. Hover or tap any highlighted item for the analysis; the full list is below.

What leaves the service

The resident

A named woman with dementia and her room. Personal information the Act requires the provider to protect. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	Transmitted to the provider, generally offshore on personal plans
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

Behaviours, including violence

That she strikes staff and wanders at night. Health information about a person who cannot speak for herself, and information that could be used to characterise her unfairly. Patient data guide.

Frontier Models (ChatGPT, Claude)	Health information transmitted; on consumer tiers it can train future models
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

Triggers, including a disclosed trauma

A history of childhood trauma, disclosed by her daughter to keep her mother safe. The most sensitive sentence on this page, given for one purpose. Patient data guide.

Frontier Models (ChatGPT, Claude)	A disclosed childhood trauma now on a third party’s servers
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

What was tried

The record section 18 of the Act requires: alternatives considered and used. Clinical and personal, and the provider’s evidence of compliance. Patient data guide.

Frontier Models (ChatGPT, Claude)	The provider’s compliance record transmitted
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

The restrictive practice

A psychotropic used as chemical restraint, with the doctor’s reasoning, and an environmental restraint. The most regulated decision in aged care, about an identified person. Patient data guide.

Frontier Models (ChatGPT, Claude)	A chemical restraint decision transmitted
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

Capacity and consent

That she cannot consent, who consented for her, and the risks explained. Her guardian’s personal information and the legal basis for the practice. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	Capacity assessment and consent transmitted
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

Monitoring

Clinical monitoring arrangements. Health information. Patient data guide.

Frontier Models (ChatGPT, Claude)	Transmitted and kept on the provider’s terms
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

The nurse and the GP

Two named practitioners responsible for the plan, each with professional obligations of their own.

Frontier Models (ChatGPT, Claude)	Transmitted, and the leak is traceable to both of you
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

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 service no longer controls it. Retention and deletion happen on the provider’s terms.

The same document on Ermos

Ermos Dominion

The document is drafted on a unit in your office, from your own templates and the resident’s record. Every marked item stays on the unit, which keeps working with the internet switched off. Nothing in it is transmitted to an AI provider, so there is no disclosure to analyse: the confidentiality work is the same as for your file server.

Ermos Edge

Your documents, the index and your access boundaries stay on your own instance in an Australian data centre. When a staff member asks for this draft, only their question and the excerpts they are permitted to see go to a named Australian provider, who is contractually barred from keeping the content or training any model on it. Nothing is processed outside Australia.

	Frontier Models (ChatGPT, Claude)	Ermos Edge	Ermos Dominion
Where the document is processed	Provider servers, generally offshore on personal plans	Your instance in an Australian data centre; answers generated in Australia	The unit in your office
Who can read it	Provider staff and systems, under policy	Your staff, within the boundaries you set. The named Australian provider processes only permitted excerpts, under contract, and keeps nothing	Your staff only
Is it kept	On the provider’s terms	Kept on your instance; the provider is barred from retaining it	Stays on the unit
Can it train a model	On consumer tiers, yes	No, by contract	Only your own unit learns from it, on your hardware

Part of AI data leakage in aged care providers.

Common questions

Do ChatGPT and Claude use the information in a behaviour support plan?

Yes, a pasted plan is sent to the AI company and processed there to produce the reply. As at October 2026, whether a conversation on a personal plan (ChatGPT Free, Plus or Pro; Claude Free, Pro or Max) can be used to train the models depends on a setting each user controls. Business plans (ChatGPT Business and Enterprise, Claude Team and Enterprise) and the developer APIs sit under commercial terms, and OpenAI and Anthropic each say they do not train on that content by default (OpenAI, Anthropic). On either product, the thumbs up and thumbs down buttons can send a whole conversation back for training. It holds the behaviours of concern, a childhood trauma disclosed in confidence and the chemical restraint decision.

Is it safe to paste a behaviour support plan into ChatGPT or Claude?

No, because the plan records the most regulated decision in aged care about one identifiable resident. The Office of the Australian Information Commissioner (OAIC) recommends in its guidance on commercially available AI products that organisations do not enter personal information, and particularly sensitive information, into publicly available generative AI tools, because of the significant and complex privacy risks. It sets out the resident's behaviours toward staff, the triggers, the chemical restraint and the guardian's consent. Without the name, that history still describes one resident to family and staff. Section 18 of the Aged Care Act 2024 requires alternatives to be tried and documented, which makes the plan the service's record of a restrictive practice.

Can ChatGPT or Claude remember the details in a behaviour support plan later?

They can. Both products also have memory features that can carry details from one conversation into later ones, and on a personal account each user decides whether they are switched on (ChatGPT, Claude). For this plan, that could carry the resident's triggers and the restraint decision into later conversations on a staff member's account. The childhood trauma a daughter disclosed in confidence, to keep her mother safe during care, could travel the same way. Because the plan is reviewed regularly, each new version would be a further conversation in which those details could be carried forward.

How can an aged care service use AI for a behaviour support plan without sending it to ChatGPT or Claude?

Ermos is built so the document stays under your control. On the Dominion AI unit it is drafted inside your office and none of it is sent to an AI provider. On Ermos Edge your documents and index stay on your own instance in an Australian data centre, and only the question and the excerpts the user is permitted to see go to a named Australian provider that is contractually barred from keeping them or training any model on them. The plan is updated at each review in the service's own template, from the progress notes, behaviour charts and GP reviews. The alternatives tried are drawn from the notes that record them, and the registered nurse and GP check and sign the plan.

What does the Aged Care Act 2024 require for restrictive practices?

Section 18 requires the rules to provide that a restrictive practice is used only as a last resort to prevent harm, after consideration of its likely impact on the person; that alternative strategies are used first to the extent possible and documented; and that the practice is used only to the extent necessary and in proportion to the risk. Use of a restrictive practice other than in accordance with the rules is a reportable incident under section 16. The behaviour support plan is the record of compliance.

Why does a disclosed trauma matter more than the medication?

Both are sensitive. The trauma was disclosed by a family member for one purpose, to protect her mother during care. It exists nowhere else, and it should exist nowhere else. The medication is at least a matter of medical record.

How is a behaviour support plan maintained on Ermos?

The progress notes, the behaviour charts and the GP's reviews are on the unit in your own building, and the plan is updated from them at each review, with the alternatives tried and their effect drawn from the notes that record them. The compliance record the Act requires is built where the care happens.

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