Fees and refunds spreadsheets: what an aged care accommodation payment register gives away in ChatGPT or Claude.

The finance register is one of the quietest files in an aged care service and one of the most exposed. Admissions and finance staff keep every resident’s accommodation payment, daily fees and refunds owing in a spreadsheet, with the family contact beside each line, and they paste it into ChatGPT or Claude to check totals or draft a letter to an executor. The sheet names who is dying, who owes money, who is owed a refund and which relative may be told what. This page marks every item in a realistic register and shows what the Aged Care Act 2024 and the Privacy Act bear on, and how the same register is handled on Ermos.

The fees and refunds register

Kept by admissions and finance staff and updated whenever a fee changes, a resident leaves or a refund falls due.

Accommodation payments and refunds register
Kurrajong Gardens Aged Care · Updated 2 November 2026 · Prepared by P. Desai

fx=SUM(G2:G8)
ABCDEFGHI
1ResidentRmStatusRAD ($)DAP ($/day)Daily fees ($/day)Refund owing ($)ContactNotes
29ACurrent57.530
314BCurrent520,000 paid063.820
411ACurrent480,000 paid063.820
512BCurrent071.2063.820
610BCurrent280,000 paid075.300
7leftDied 2 Oct415,000 paid00Probate lodged but not yet sighted. Final fees to deduct.
8leftLeft 26 Oct350,000 paid00Moved to a home near family. Refund waiting for Lorraine to approve.
9765,000Total refunds owing (check against ledger)
10Rule
ResidentsRefundsArrears

An invented register. Figures are illustrative. Phone numbers and the bank details are placeholders. Hover or tap any highlighted cell for the analysis; the full list is below.

What leaves the service

  1. 1
    Residents by name and room

    Every resident in one list. Section 168 of the Aged Care Act 2024 requires a registered provider to protect personal information about the people it delivers services to, and one paste identifies them all. Privacy Act guide.

  2. 2
    The accommodation payment and what is still unpaid

    The size of a resident’s refundable deposit and the date the balance is due, which is the date a large sum will move. Financial information is personal information under the Privacy Act, and it is the detail a payment redirection scam needs. Privacy Act guide.

  3. 3
    Daily fees

    A daily total that includes the means-tested care fee, which reflects an assessment of the resident’s means. The assessment is the resident’s own information, and the total is arithmetic that a person has to check against the current assessment. Privacy Act guide.

  4. 4
    A palliative flag in a finance note

    A note that a named resident is dying, kept so finance can plan for a refund. Health information, which is sensitive information under the Privacy Act, in a finance cell. Section 168 limits use of residents’ personal information to purposes connected with delivering their care or the purpose it was given for, and the family has not been told. Patient data guide.

  5. 5
    Family and representative contacts

    Named relatives, their authority (EPOA, executor) and phone numbers. These people are not residents, but the provider holds their personal information, and as an organisation providing a health service it is covered by the Privacy Act whatever its size. Each is a target for a fake message about money. Privacy Act guide.

  6. 6
    Arrears and a family in financial difficulty

    That a family is behind with fees and may apply for hardship. Financial information is personal information but is not on the Privacy Act’s closed list of sensitive information. It is still a confidence the family gave for one purpose. Privacy Act guide.

  7. 7
    Who must not be told

    Instructions about which relative gets invoices, which gets clinical information and which gets nothing. They record a family’s division and the service’s arrangements, and a tool that sees them does not know to honour them. Privacy Act guide.

  8. 8
    Refunds owing to estates

    What is owed to two named people or their estates. Department of Health guidance says a refund after a death falls due within 14 days after the provider sights probate, letters of administration or other satisfactory evidence, and that interest at the maximum permissible interest rate can run from the end of the refund period until it is paid. A late or wrong refund has a cost, so a person has to check each line. Privacy Act guide.

  9. 9
    A bank account for the refund

    A BSB and account number for a payment of hundreds of thousands of dollars. The detail a fake executor email tries to change. Confirming any change of account by phone on a number already held is a common safeguard. Privacy Act guide.

  10. 10
    The refund rule in the sheet

    A general rule of the kind that sits on a reference tab. It is published guidance, names no person and is safe to share.

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 EdgeErmos Dominion
Where the document is processedProvider servers, generally offshore on personal plansYour instance in an Australian data centre; answers generated in AustraliaThe unit in your office
Who can read itProvider staff and systems, under policyYour staff, within the boundaries you set. The named Australian provider processes only permitted excerpts, under contract, and keeps nothingYour staff only
Is it keptOn the provider’s termsKept on your instance; the provider is barred from retaining itStays on the unit
Can it train a modelOn consumer tiers, yesNo, by contractOnly 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 fees and refunds register?
Whatever is pasted or uploaded is sent to the AI company's servers and processed there to produce a 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. This register lists Harold Baxter's $400,000 accommodation payment due on 14 November, his three weeks of arrears, Doreen Quigley's $415,000 refund and the BSB and account number for it.
Is it safe to paste an accommodation payment and refunds register into ChatGPT or Claude?
No. The register lists every resident with a room, a family contact and notes on health, money and who may be told what. 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 also pairs an executor's name with a refund amount and a bank account, which is the detail a fake change-of-account email needs.
Can ChatGPT or Claude be trusted to check a fees and refunds register?
Not without a person checking each line. Language models can produce fluent text with wrong figures, wrong dates or references that look real but are not, and in a spreadsheet that includes wrong formulas, wrong totals and mis-copied rows. A finance officer should check every item against the ledger. The $765,000 refund total, the 14-day clock after probate is sighted and the bank details would do most harm if wrong.
How can an aged care service use AI for a fees and refunds register 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. Ermos prepares the refund letter or register review from the resident's file and the service's own finance records. The finance officer checks each amount and date against the ledger and signs it off.
How quickly must a refundable deposit be refunded after a resident dies?
Department of Health guidance says a provider must refund the lump sum within 14 days after sighting probate, letters of administration or other satisfactory evidence. It says interest at the maximum permissible interest rate can be payable from the end of the refund period until the refund is paid. Check the current guidance and the Aged Care Rules 2025 for the detail that applies to a particular resident.
Is a resident's financial information protected as well as health information?
Section 168 of the Aged Care Act 2024 covers personal information about the people a registered provider delivers funded aged care services to, whatever its subject. Under the Privacy Act, financial information is personal information but is not on the closed list of sensitive information, so health and religion are treated more strictly than a balance. Both still call for care, and a fees sheet usually sits next to notes about health and family.
Why do refund amounts and bank details attract fraud?
A large refund owed to an estate, a named executor and a bank account together are what a payment redirection scam needs. A message that appears to come from the executor and asks for a change of account only has to arrive before the refund is paid. Confirming account changes by phone on a number already held is a common safeguard. Keeping these details out of third-party tools reduces the places they can be copied from.

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