Recall spreadsheets and AI patient data: what a billing and recall sheet gives away in ChatGPT or Claude.

Practice managers keep recall lists in spreadsheets, because the practice software exports to them and a spreadsheet is quick to filter. Someone then uploads the sheet to ChatGPT or Claude to draft recall messages, find overdue patients or check a formula. The sheet is a table of patient names against birth dates, mobile numbers, Medicare item numbers, condition codes and a notes column, repeated for every patient on the list. This page marks what a routine billing and recall sheet exposes under the Privacy Act and the NSW health records law, and shows how the same list is worked on Ermos inside the practice.

The billing and recall spreadsheet

Kept by the practice manager or recall nurse from the practice software, to chase overdue reviews, plan recalls and reconcile billing. It is often shared by email, which is how it reaches an AI tool.

fx
ABCDEFGH
1PatientDOBMobileMBS itemLast seenRecall dueCondition (ICPC-2)Note
211/03/195912/10/2026
319/06/196822/10/2026
404/08/199719/10/2026
527/01/198214/10/2026
602/09/195408/10/2026
715/05/201820/10/2026
830/12/199215/10/2026
911/07/194509/10/2026
1003/03/201021/10/2026
1122/10/197906/10/2026
Recall list

An invented spreadsheet. All patients are fictional and the phone numbers are placeholders. Hover or tap any highlighted item for the analysis; the full list is below.

What leaves the practice

  1. 1
    Patient names and dates of birth

    Ten names against birth dates. Personal information, and because the practice collected it in providing a health service, health information under section 6FA(b) of the Privacy Act. Privacy Act guide.

  2. 2
    Mobile numbers

    Direct contact details for every patient on the list. Personal information, and the starting point for phishing and impersonation. Privacy Act guide.

  3. 3
    Medicare item numbers

    Which service was billed to which patient. A single number is public, but against a name item 2715 reveals a mental health plan and 965 a chronic condition management plan.

  4. 4
    Last seen and recall dates

    When each patient was seen and when they are due back. It shows treatment schedules and when a person will next be at the practice.

  5. 5
    Condition codes

    A code per patient for the problem managed, from diabetes to depression, pregnancy, contraception for a 16-year-old and HIV. Health information is sensitive information under the Privacy Act, and these are among its most sensitive entries. Patient data guide.

  6. 6
    The notes column

    Free text with the most candid detail: a complaint, a custody arrangement, an undisclosed pregnancy, a teenager whose parents are unaware. Instructions about who must not be told, which the practice has to be able to follow. Patient data guide.

  7. 7
    The recall formula

    A date test with no patient information in it. The same formula can be shared safely, and the sheet it sits in cannot.

  8. 8
    Other tabs, hidden columns and file properties

    A spreadsheet file generally carries more than the visible tab: other sheets, hidden columns, cell comments and properties such as the author. Uploading the file sends all of it, including what is off screen.

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 patient record. 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 healthcare practices. See how this works in practice: Recall letters on Ermos.

Common questions

Do ChatGPT and Claude use the information in a billing and recall spreadsheet?
Yes, a pasted recall list 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. One sheet lines up ten patients' names, birth dates and mobile numbers with condition codes that include depression, pregnancy and HIV, and a notes column saying who must not be told.
Is it safe to paste a billing and recall spreadsheet into ChatGPT or Claude if we delete the names?
No, because every row keeps a birth date, a mobile number and a note. 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 teenager whose parents are unaware and a patient at 24 weeks whose employer has not been told stay recognisable to anyone who knows them. Condition codes are health information, which is sensitive information under the Privacy Act. 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 billing and recall spreadsheet to ChatGPT or Claude instead of pasting it?
An uploaded spreadsheet 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 an Archive 2025 tab beside the Recall list tab, and both could travel with the ten patients on screen.
How can a medical practice use AI for a billing and recall 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 recall wording is drafted from the practice's own recall records and message templates. The practice manager or a nurse checks each message before it reaches a patient.
Is a recall list health information if it only holds names and dates?
Yes. Section 6FA(b) of the Privacy Act makes other personal information collected to provide, or in providing, a health service health information. A name, a date of birth and a mobile number on a patient recall list were collected in providing a health service, so the practice holds them as health information.
Which practices does the Privacy Act reach if their turnover is small?
Section 6D(4)(b) provides that a business which provides a health service to another individual and holds health information other than in an employee record is not a small business operator. A GP practice with allied health on a modest turnover is therefore still covered by the Act, and so is its recall list.
What does the practice owe patients about keeping a recall list secure?
APP 11.1 requires an APP entity to take reasonable steps in the circumstances to protect personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. A sheet uploaded to a tool the practice does not control is the kind of step a reasonable practice has to be able to justify.

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