File notes and AI confidentiality: what a client meeting gives away in ChatGPT or Claude.

File notes are where an adviser writes down what the client actually said, before it is tidied into advice. They record the redundancy that has not been announced, the diagnosis the client mentioned in passing, the argument between spouses, and the adviser’s own read of the room. They are also exactly the dictation staff paste into ChatGPT or Claude to turn into prose. This page marks every item in a review meeting note that the practice holds under Standard 8 and the Privacy Act, and shows how the same note is written up on Ermos inside the practice.

The file note of a client meeting

Written on the day of a client meeting, for the file, and relied on if the advice or the instructions are later questioned.

File note
Harrington, T & L¹ · Annual review · NR⁹ · 21 October 2026, 10.00am to 11.20am, office

Attendees. Tom and Lucy. Lucy’s mother, Patricia Nolan, attended for the first twenty minutes to discuss her own aged care funding; see separate note.²

Changes since last review. Tom has been told confidentially that his role at Coastline will be made redundant in December. He has not told Lucy’s family or his own. Expected package approximately $85,000. He asked that we not contact his employer for income verification until he confirms.³

Lucy has had a recurrence of thyroid symptoms and is awaiting a specialist appointment. She is concerned this will affect the income protection application with Meridian, which is still in underwriting. Advised that the application must be updated to disclose the change before it is accepted; she was reluctant.⁴

Instructions. Clients want to pause the salary sacrifice increase until Tom’s position is clear, and to hold the Tesla shares rather than sell, against our recommendation. Confirmed they understand our view; they wish to proceed anyway. To be documented as a client-directed decision.⁵

Lucy raised again the question of changing the guardian in her will. Tom became visibly frustrated and said “we are not doing this here”. Left it. Lucy emailed separately afterwards asking for a referral to an estate lawyer, and asked that I not copy Tom.⁶

Impressions. Tom is anxious about the redundancy and minimised it in front of Lucy. Lucy is more worried about her health than she said. I think the insurance application is at risk and they may need to accept exclusions.⁷

Actions. Update Meridian application with Lucy’s change in health. Prepare ROA for the paused sacrifice. Diary Tom’s redundancy date. Referral for Lucy to Carrick Doyle Lawyers, sent to Lucy only.⁸

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

What leaves the practice

The clients

Named. Everything below is identifiable. 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

A third person and her affairs

A named relative’s presence and a reference to her aged care funding. Her personal information, in someone else’s file note. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	A third person’s affairs 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

A confidential redundancy

That a named employer is making the client redundant, before it is announced, with the expected payout. Employment information the client was told in confidence, and the employer’s business too. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	A confidential redundancy transmitted before it is announced
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

A health change and an underwriting problem

A recurrence, a pending specialist appointment, and the client’s reluctance to disclose it to an insurer. Sensitive health information, and a record that bears on what the client tells the insurer before the policy is accepted. Patient data guide.

Frontier Models (ChatGPT, Claude)	Sensitive 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

Instructions against advice

That the clients overrode the adviser’s recommendation. The kind of record Standard 8 expects, which also helps the practice show the best interests duty in section 961B was met, and the one it relies on if the decision goes badly.

Frontier Models (ChatGPT, Claude)	The record of a client-directed 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

A marital disagreement and a private request

A disagreement about the will, and one spouse’s request for a referral the other is not to know about. A confidence inside a confidence. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	A marital disagreement and a private request 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 adviser’s impressions

Candid notes on the clients’ states of mind and the adviser’s prediction about the insurance. Written for the file, never for the clients.

Frontier Models (ChatGPT, Claude)	Your impressions 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

Actions, including a referral to a named law practice

The next steps, including a referral and an instruction about who is copied. Operational, and revealing.

Frontier Models (ChatGPT, Claude)	The next steps 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 adviser

Initials that tie the note to an identifiable adviser bound by the Code of Ethics.

Frontier Models (ChatGPT, Claude)	Transmitted, and the leak is traceable to 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 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 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 financial advice practices. See how this works in practice: File notes on Ermos.

Common questions

Do ChatGPT and Claude use the information in a file note?

Yes, a pasted note 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. A review note can hold an unannounced redundancy, a health change and the adviser's private impressions.

Can we use ChatGPT or Claude for a file note if we remove the names?

Not safely, because a file note still points to one couple 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 coming redundancy, a recurring thyroid condition, a mother's aged care funding and a referral to a law practice each narrow the field, and together they identify the family. 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 file note?

Only once the practice has answers on where the recording is stored, whether the vendor trains a model on it and who can review it. A recorder or transcription tool sends the audio or transcript to the tool's vendor. 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 review would also hold the twenty minutes when a client's mother was in the room, along with the redundancy and the disagreement over the will.

How can an advice practice use AI for a file note 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 note is drafted from the adviser's own meeting notes in the practice's own file note format. Afterwards the adviser reads it against what the client said before it goes on the file.

Why does Standard 8 make file notes more sensitive rather than less?

Standard 8 requires client records to be complete and accurate, which is why file notes record the confidential redundancy, the health change and the disagreement. Completeness inside the practice is the obligation. The same completeness is what makes the note dangerous anywhere else.

Staff use AI to turn dictation into prose. Is that the problem?

The use is sensible; the destination is the problem. On an Ermos unit the dictation is written up on hardware in your office and the note never leaves. On Edge it stays on your own instance in Australia, and only permitted excerpts go, per question, to a named Australian provider under contract.

What about Lucy's request not to copy Tom?

A joint client relationship with a private request from one spouse is a judgement call for the adviser and, sometimes, the licensee's compliance team. It is recorded so the practice can show how it was handled. That record, on a third party's servers, is the opposite of the discretion it describes.

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