Rosters and agency staff spreadsheets: what a weekly aged care roster gives away in ChatGPT or Claude.

A roster looks like a table of names and shift codes, which is why a manager will paste it into ChatGPT or Claude to fill gaps, check hours or rebalance agency cover. By the time it is finished it holds much more: mobile numbers, leave and health notes, police certificate dates, a worker who has been stood down, and instructions about which resident needs which staff member. Some of it is the staff member’s own information and some of it is a resident’s. This page marks every item in a realistic weekly roster and agency workbook and shows what the Aged Care Act 2024 and the Privacy Act bear on, and how the same roster is checked on Ermos.

The roster and agency workbook

Built each week by the facility manager and the care manager, then shared with staff and the agency. Notes accumulate in it through the week.

An invented roster. Mobile numbers are placeholders. Hover or tap any highlighted cell for the analysis; the full list is below.

What leaves the service

1. 1
   Staff names and mobile numbers

   Named workers with personal mobile numbers. Personal information, and the key that ties every note in the sheet to a person. The Privacy Act covers an aged care provider whatever its size, because aged care counts as a health service under section 6FB. Privacy Act guide.

2. 2
   An agency worker stood down

   The agency’s name, two agency workers and a named worker with an instruction never to roster him, after an allegation that is not a finding. His personal information, and a matter that sits inside the incident process for a Priority 1 reportable incident (24 hours to notify the Commission, according to its guidance). Privacy Act guide.

3. 3
   Which resident needs which worker

   Room numbers and care conditions that point to named residents. Section 168 of the Aged Care Act 2024 ties the use and disclosure of residents’ personal information to delivering their care, and a palliative flag or a dementia induction gap is exactly that. Patient data guide.

4. 4
   An instruction that reveals a disclosed history

   Female staff only for personal care, with the reason in brackets. The reason is a history a family member disclosed so that staff would care for the resident safely. Health information, given for one purpose. Patient data guide.

5. 5
   A worker’s leave, medical certificate and counselling referral

   Health information about a named nurse. A private employer’s handling of its own employee records can fall within the employee records exemption in the Privacy Act, which the OAIC reads narrowly and which does not cover volunteers. It does not follow that the exemption helps with agency workers, who are employed by the agency, or with a tool outside the service. Privacy Act guide.

6. 6
   A screening date and a renewal not lodged

   Department of Health guidance says aged care workers need a police certificate issued within the last three years with no precluding offences, or a current NDIS Worker Screening Clearance. A named worker’s certificate date, which is three years old on 14 November 2026, and a renewal not yet lodged are in the cell. The check is the service’s own and still needs a person to confirm it against the certificate.

7. 7
   A cell comment about a named nurse

   A manager’s comment that a nurse is not to give medicines alone. Comments in a spreadsheet are stored in the file and travel with it, often unseen on screen. It reads as a performance judgement, written for the service’s own supervision. Privacy Act guide.

8. 8
   A witness

   A worker who saw the incident and may be contacted by the Commission. Identifying who reported or witnessed a matter is a risk to that person and to the investigation. The Code of Conduct’s privacy element (rule 14-5(c)) concerns the individuals receiving services, so it speaks to the resident in this entry rather than the worker. Privacy Act guide.

9. 9
   Other tabs, hidden columns and file properties

   A workbook is a whole file. Uploading it sends every tab, hidden column and hidden row, every cell comment, formulas that read from other sheets and properties such as the author and last editor, even when the screen shows one tab. Treat the file as everything in it.

10. 10
    The shift key

    Generic shift codes and their start and finish times. No person and no resident is in it. A template with only this content is safe to share anywhere.

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

Part of AI data leakage in aged care providers.

Common questions