Records of Advice and AI data leakage: what a short advice document gives away in ChatGPT or Claude.

A Record of Advice is the short form: the document the Corporations Act allows instead of a full Statement of Advice when further advice is given to a client who already has a Statement of Advice from the practice and the client’s circumstances and the basis of the advice have not changed significantly. Short means it gets written in a hurry, and in a hurry means it gets pasted into ChatGPT or Claude. This page marks every item in a routine ROA that the Code of Ethics and the Privacy Act protect, and shows how the same ROA is produced on Ermos from the client file inside the practice.

The Record of Advice

Prepared when further personal advice is given to an existing retail client whose circumstances, and the basis of the advice, are not significantly different from those covered by a previous Statement of Advice, so that section 946B of the Corporations Act (as substituted by regulation 7.7.10AE of the Corporations Regulations) does not require a new one.

Record of Advice
Tom and Lucy Harrington¹ · Nadia Reyes, Harbourview Wealth Partners⁸ · 23 October 2026

Basis. This record relates to the advice in our Statement of Advice dated 24 October 2025. Your circumstances have changed in one respect: Tom expects his employment with Coastline Developments to end in December 2026 with a redundancy payment of approximately $85,000. We have considered whether that change calls for a new Statement of Advice. Because the redundancy is expected rather than confirmed, and the advice below holds your position until we review it with you in January, we have recorded it here.²

Your instructions. You have asked us to pause the increase in Tom’s salary sacrifice until his employment position is settled, and you have decided to retain the Tesla shareholding against our recommendation to sell.³

Our advice. Pause the salary sacrifice increase from 1 November 2026. Retain the existing contributions of $6,000 per year. Direct the redundancy payment, when received, to the CBA offset account (ending 5678) pending our review of your position in January. Do not make any non-concessional contribution to superannuation until Tom’s income for the 2027 year is clearer.⁴

Reasons. Pausing the increase preserves cash while Tom’s income is uncertain and costs approximately $1,400 in forgone tax saving for the year. Holding the redundancy payment in offset saves 6.1% and keeps it available. We continue to recommend selling the Tesla shares, which represent 18% of your non-super investments in a single stock; you have chosen to retain them, and we have recorded that decision.⁵

Fees. No additional fee applies. This advice is covered by your ongoing service agreement.⁶

Please confirm these instructions by signing below. If you have any concerns about Tom’s employment before December, contact us before acting.⁷

An invented Record of Advice. 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

The change in circumstances

A redundancy from a named employer, with the expected payment, before it has happened. Confidential employment information about the client, and about the employer. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	A 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

Instructions against advice

That the clients are holding a stock against the adviser’s recommendation. A record that protects the practice, which is why it exists and why it should stay inside.

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

The advice and an account number

Specific instructions about contributions and a partial account number for where the redundancy payment should go. Advice, and a financial identifier. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	Advice and an account number 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

The reasons and the portfolio concentration

The adviser’s reasoning, with figures, and the fact that a client holds a concentrated position. The best interests judgement under section 961B, which the practice may later need to evidence.

Frontier Models (ChatGPT, Claude)	Your reasoning 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

The fee arrangement

That the clients are on an ongoing service agreement. Commercial information about the practice and the client.

Frontier Models (ChatGPT, Claude)	The fee arrangement 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 warning

A caution tied to a future event. Part of the advice record.

Frontier Models (ChatGPT, Claude)	Transmitted and kept on the provider’s terms
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

Ties the record to a named 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: Advice drafting on Ermos.

Common questions

Do ChatGPT and Claude use the information in a Record of Advice?

Yes, the record 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. Even this short form carries an expected redundancy, a stock held against advice and part of an account number.

Is it safe to paste a Record of Advice into ChatGPT or Claude?

No, because most of a Record of Advice records a decision about one household's money. 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. Taking the names out still leaves an earlier Statement of Advice cited by date, an unannounced redundancy and the last digits of the account that will receive the payout. The instruction to hold a stock against advice is also the practice's own protection if the decision goes badly.

Can ChatGPT or Claude be trusted to draft a Record of Advice?

Not without a qualified person checking every line against the client file. Language models write fluent text that can contain details that are not in the source, wrong figures, wrong dates and references that look genuine and do not exist. The costliest errors in a Record of Advice would be a wrong date for the earlier Statement of Advice and a wrong account ending for the redundancy payment. A softened version of the client's instruction to hold the stock would misstate the decision the record exists to prove.

How can an advice practice use AI for a Record of Advice 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 Record of Advice is drafted from the client file in the practice's own template. The adviser checks every line and signs it.

Why does a short document matter as much as the SOA?

Because it is written quickly, between meetings, which is when a tool that is already open gets used. An ROA carries the change in circumstances and the client's decisions, and those are often the most sensitive facts on the file.

Does an ROA have to be a particular form?

The Corporations Act and the Corporations Regulations set out when an ROA may be used instead of an SOA and what the record must contain; ASIC RG 175 and ASIC INFO 266 explain the detail. The form is the practice's. On an Ermos unit it is drafted from the file in the practice's template, and the adviser checks and signs it.

Does recording a client-directed decision protect the practice?

It is the evidence that the advice was given and the client chose otherwise, which is why advisers record it carefully. That protection depends on the record being the practice's, kept where the practice controls it.

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