Trust account reconciliations and AI security: what a trust ledger gives away in ChatGPT or Claude.

A trust ledger lists the clients whose money the practice holds, how much and why. Reconciling it against the bank statement is routine, and a formula that will not balance is the kind of problem staff paste into ChatGPT or Claude to find. The sheet contains every client’s name and matter, their balance, the trust bank account, and free-text notes that often record a health or family circumstance. This page marks each cell that bears on the NSW trust account and audit rules and on privacy, and shows how the same ledger is checked on Ermos inside the practice.

The trust account reconciliation spreadsheet

Prepared at the end of each month by comparing the client ledgers with the trust bank statement, and drawn on by the auditor at year end.

fx=E8-E9
ABCDEFG
1Client and matterOpening 30 SepReceiptsPaymentsClosing 31 OctLast entryNote
2 0.000.0030 OctTowards duty and fees
3 0.00186,940.75186,628.3016 OctRefund owing, cheque to be drawn
4 5,400.000.000.005,400.0014 Aug
5 0.00154,310.00154,310.000.0030 OctSettled
6 2,150.000.002,150.000.008 OctUnused search fees refunded
7 0.0061,800.000.0061,800.0029 OctDeposit, held per contract
8Total client ledgers7,550.00423,050.75343,088.3087,512.45
9Trust bank statement 31 Oct
10Difference
Trust ledger 31-Oct-26Cash bookUnclaimed

An invented trust ledger. The BSB and account number are placeholders, and the clients and matters are fictional. Hover or tap any highlighted cell for the analysis; the full list is below.

What leaves the practice

  1. 1
    Client names

    Several clients who have nothing to do with each other, on one sheet. A single paste discloses all of them, though only one of them needed the check. Privacy Act guide.

  2. 2
    Matters and property addresses

    Which client is buying or selling which property. Keeping client information confidential is listed among the rules of conduct in Schedule 2 of the Conveyancers Licensing Regulation, according to the NSW Government’s conveyancers page.

  3. 3
    A client’s balance held in trust

    What a client has paid in and the date. NSW guidance says funds held for a person cannot be used for any other purpose, and the balance shows how much a client has set aside. Privacy Act guide.

  4. 4
    A balance owing back to a client

    A small amount left after settlement. The practice has to account for the balance, and an item left in the ledger is the sort of detail an auditor asks about.

  5. 5
    A health circumstance in a note

    A named client in hospital and a daughter who instructs. Health information is sensitive information under the Privacy Act, and a free-text note column is where it ends up. Patient data guide.

  6. 6
    A trust and its trustee

    The name of a family trust and the trustee, with the deposit it has paid. Information about a business structure and a named individual. Privacy Act guide.

  7. 7
    The trust bank account and statement balance

    The account the practice holds client money in and what it held on 31 October. NSW guidance says the account must be at an approved authorised deposit-taking institution, and this is the one a fraudster would want to name.

  8. 8
    The reconciliation sign-off

    That a named conveyancer reconciled and signed off the ledger on a date. The audit record shows a human did the work. NSW audits cover all records relating to trust money, and the period ends on 30 June each year.

  9. 9
    The difference formula

    A subtraction of two cells with no data in it. Spreadsheet files can also carry hidden columns, cell comments and formulas that read other sheets, so a formula is only harmless when the file around it is.

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 practice 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 matter file. 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 conveyancing practices.

Common questions

Do ChatGPT and Claude use the information in a trust account reconciliation spreadsheet?
Yes, whatever is pasted from the ledger 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. The ledger lists several unrelated clients' balances, a note about a hospital stay and the trust bank account number.
Can we use ChatGPT or Claude for a trust account reconciliation spreadsheet if we remove the names?
Not safely, because the matters, addresses and notes still identify clients without their names. Removing names rarely makes a document anonymous. Information stays personal information while the person is reasonably identifiable, and the OAIC warns that information can be at risk of re-identification even when it has been de-identified or anonymised. A purchase at a named street in Petersham, a sale held pending a pest report and a seller in hospital until mid November with her daughter instructing each point to one person. 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.
Can I upload a trust account reconciliation spreadsheet to ChatGPT or Claude instead of pasting it?
An uploaded file leaves the practice as a whole file, which can carry other sheets, hidden columns, comments, tracked changes and file properties as well as the part you meant to share. The OAIC's guidance also tells organisations to review carefully the terms and settings that will apply to their use of any AI product. This workbook has further tabs for the cash book and unclaimed money, so an upload meant for one reconciliation line could send every client's balance.
How can a conveyancing practice use AI for a trust account reconciliation spreadsheet 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 reconciliation is prepared from the client ledgers, the trust bank statement and the practice's own ledger template. A licensed conveyancer checks the difference line and signs off the reconciliation.
How are NSW conveyancer trust accounts audited?
NSW Fair Trading says all records relating to trust money held must be audited. The audit period is the year ending 30 June, and the audit is lodged by 30 September through the Auditors Report Online portal. A licensee who held no trust money must still lodge a declaration. Auditors must be registered with ASIC or qualified under section 79.
What does NSW guidance say about unclaimed trust money?
NSW Fair Trading's guidance refers to section 62(1) of the Conveyancers Licensing Act 2003 and says unclaimed money held in a trust account for more than two years must be reported to NSW Fair Trading each January. A ledger line that stays open for that long, like a small balance owed back to a client, is the sort of item that ends up in that report.
What happens if a practice lodges its trust audit late?
NSW guidance says late lodgement of the audit can lead to disqualification or stop a licence being renewed. It also sets fines for not lodging a correct declaration by the due date. The audit works from the ledgers and reconciliations, so a clean, accurate set of trust records matters well before 30 September.

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