Fact finds and AI data leakage: what a client data form gives away in ChatGPT or Claude.

The fact find is the densest document in financial advice. It exists to collect everything an adviser needs to know a client, which means it holds identity documents, tax file numbers, every account, every debt, the children, the health history and what the client wants to happen when they die. It is also the form staff most often paste into ChatGPT or Claude to extract into the planning software. This page marks every item on a standard fact find that the Privacy Act, the TFN Rule and the Code of Ethics protect, which is all of it, and shows how the same extraction happens on Ermos inside the practice.

The fact find

Completed with a new client before any advice is given, and updated at each review. Identifying the client’s objectives, financial situation and needs is the first step of the safe harbour in section 961B(2) of the Corporations Act, which an adviser can rely on to show the best interests duty was met.

Client data collection
Harbourview Wealth Partners · Confidential

Client 1
Client 2
Tax file numbers
Employment and income
Assets
Liabilities
Dependants
Health
Estate
Risk profile
Adviser

An invented fact find. The TFN is the ATO’s published example value; licence and passport numbers are placeholders. Hover or tap any highlighted item for the analysis; the full list is below.

What leaves the practice

  1. 1
    Full names, dates of birth and identity documents

    Two complete identities, with the government identifiers used for verification. The material identity theft is built from. Privacy Act guide.

  2. 2
    Tax file numbers

    The TFN Rule permits TFN information to be used or disclosed only for authorised purposes, with access restricted to people who need it. Advisers collect TFNs for superannuation forms; a frontier model provider is not such a person. Privacy Act guide.

  3. 3
    Employers and income

    Two incomes and a named employer. Financial and employment information under the Privacy Act. Privacy Act guide.

  4. 4
    Every account, with numbers

    Super member numbers, a bank account, share holdings and every debt. A complete balance sheet, with the identifiers needed to act on it. Privacy Act guide.

  5. 5
    The children

    Two named children, their ages and their school. Minors’ personal information, and where they are each weekday. Privacy Act guide.

  6. 6
    Health and family history

    A diagnosis, a medication, a treating doctor and a family cardiac history, collected for insurance underwriting. Sensitive information under the Privacy Act. Patient data guide.

  7. 7
    Estate wishes and a family disagreement

    What the clients want to happen when they die, a named relative they do not want as guardian, and a disagreement between the spouses. Nobody outside the room was meant to see this. Privacy Act guide.

  8. 8
    Risk profile and a confided episode

    How the clients handle loss, and a confession about 2020. Personal, the kind of detail Standard 8 expects in a complete and accurate client record, and the kind a practice keeps confidential.

  9. 9
    The adviser

    Ties the record to a named adviser bound by the Code of Ethics.

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 client 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 financial advice practices. See how this works in practice: Review preparation on Ermos.

Common questions

Do ChatGPT and Claude use the information in a client fact find?
Yes, whatever is pasted from a fact find is sent to the AI company's servers and processed there. 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. One paste carries two identity documents, a tax file number and the children's school.
Is it safe to paste a fact find into ChatGPT or Claude once the names are removed?
No, because a fact find identifies the household long after the names are gone. 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. Two birth dates, a school, a treating doctor and an employer are enough for anyone who knows the family, and the tax file number needs no inference at all. 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.
Is it safe to use an AI note-taker or meeting recorder for a fact find?
Not until the practice knows where the recording is stored, whether the vendor trains a model on it and who can review it. Recording and transcription tools send the audio or transcript to the tool's vendor, so each of those questions needs an answer first. The OAIC's guidance also tells organisations to review carefully the terms and settings that will apply to their use of any AI product. A recording of the meeting also holds what the form leaves out, such as the whole discussion over a guardian and a client's own account of selling in 2020.
How can an advice practice use AI for a fact find 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 fact find is drafted from the meeting notes and the practice's own fact find template. The adviser checks every entry against the client's own documents.
Why does a fact find need special care?
Because it is designed to hold everything. Most documents carry one kind of sensitive information; the fact find carries identity, tax file numbers, finances, health, children and estate wishes together, which is the complete set an identity thief, a scammer or a hostile relative would want.
We paste it to extract the fields into our planning software. Is that the problem?
The purpose is fine; the destination is the problem. On an Ermos unit the form is read on your own hardware and the fields go into your systems without the form leaving the practice. On Edge the form stays on your instance in Australia.
Is a fact find a notifiable data breach if it goes into ChatGPT or Claude?
Under the Notifiable Data Breaches scheme a breach is notifiable where unauthorised disclosure is likely to result in serious harm. A form with identity documents, TFNs, account numbers and health information is the kind of disclosure that assessment exists for. Whether a particular paste meets the threshold depends on the tool's terms and the practice's assessment, which is work nobody wants to do after the fact.

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