Broker transfer letters and AI confidentiality: what a letter of appointment gives away in ChatGPT or Claude.

When a client moves to a new broker, a letter of appointment tells the insurer to deal with the new broker and release the policy history. It looks like paperwork, which is why it is easy to drop into ChatGPT or Claude to tidy or to turn into a covering email. The signed letter and the new brokerage’s file note carry the client’s policy numbers, premiums, claims, its reasons for leaving the old broker and sometimes a note about who is able to sign. This page marks every item in a realistic transfer letter that the Code of Practice and the Privacy Act bear on, and shows how the same letter is handled on Ermos inside the brokerage.

The broker transfer letter

Signed by the client and lodged with the insurer before renewal so that the new broker can obtain the policy documents and claims history and negotiate the renewal.

Letter of Appointment
29 October 2026

To: Broker Services, Southern Cross Insurance

Effective from 1 December 2026 we appoint Pacific Harbour Insurance Brokers (AFSL 123456) to manage the following insurance.

Property.

Policy.

Claims history.

Why we are changing.

Our plans.

Signed: Lena Marchetti, Director · Giuseppe Marchetti, Director (to follow)


Pacific Harbour file note, P. Desai, 29 October.

Terms of engagement.

An invented letter. The policy number is a placeholder. Hover or tap any highlighted item for the analysis; the full list is below.

What leaves the brokerage

  1. 1
    The trust, the trustee and the directors

    A named family trust, its corporate trustee and two named directors. Personal information about the directors, and the structure through which the family holds property. Privacy Act guide.

  2. 2
    The property and what is insured

    A named commercial building, its sum insured and the 12-month loss of rent limit. A statement of what the building is insured for and what rent it earns the family.

  3. 3
    The policy number, renewal date and premium

    A policy reference, when it ends and what it costs. Confidential commercial terms, and a policy number is the key insurers use to find the policy.

  4. 4
    The claims history

    A claim and its amount over five years. Claims history is what an insurer prices a risk on, and the client has authorised its release only to the new broker.

  5. 5
    The reason for leaving, with a named broker

    A complaint about a named competitor, that it let an extension lapse. An allegation about a third party, drafted before it has been put to that brokerage.

  6. 6
    The authority wording

    The authority for the insurer to release policy information and claims history to the new broker, and the statement that the letter overrides earlier appointments. One major insurer’s published instructions for a business policy transfer contain wording of this kind, and insurers’ requirements vary. The wording is standard and holds no client data.

  7. 7
    The plan to sell

    That the trust may sell the property in 2027. A commercial intention the tenant, the other directors or a purchaser might not yet know.

  8. 8
    The file note about who can sign

    An 81-year-old director’s diagnosis and a doubt about whether the signature is valid. Health information about an individual, which is sensitive information under the Privacy Act to the extent the brokerage is bound by it, and a legal question the brokerage has not resolved. Patient data guide.

  9. 9
    The fee and the terms of engagement

    The broker’s fee and commission arrangement. Under the Code of Practice a brokerage’s terms of engagement include its remuneration (clause 4.2). It is information between the brokerage and its client.

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 brokerage 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 insurance brokerages.

Common questions

Do ChatGPT and Claude use the information in a broker transfer letter?
The whole letter 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. A broker transfer letter names a family trust and its directors, a current premium of $11,860 and the trust's plan to sell the property in 2027.
Is it safe to paste a broker transfer letter into ChatGPT or Claude if we take the names out?
No, because the letter still describes one family trust. 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 Brookvale building insured for $3,200,000, a hail claim of $41,500 and a complaint about the previous broker point to a single owner. The file note adds a director's dementia, which is sensitive information to the extent the brokerage is bound by 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.
What if staff use their own ChatGPT or Claude account for a broker transfer letter?
The brokerage then cannot see or manage what was sent. On a personal plan the user cannot choose where conversations are stored or processed. Some business plans let an organisation choose to store data at rest in Australia (OpenAI), which still leaves the content with the AI company. Both companies can also review content that is flagged for safety or policy reasons. A letter pasted from a personal account carries the policy number, the claims history, the reason for leaving the old broker and a file note about a director's diagnosis, and the brokerage cannot trace any of it.
How can a brokerage use AI for a broker transfer letter 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 letter is drafted from the client file and the brokerage's own letter of appointment template. The account manager checks the insurer's requirements and the signatures before lodging it.
What does an insurer need in a letter of appointment?
Requirements vary by insurer. One major insurer's published instructions for a business policy transfer require the words Letter of Appointment, an effective-from date, the policy number, and the signatory's name, title and signature. The brokerage should check each insurer's own requirements before it lodges a letter.
What can the new broker ask the insurer for?
That depends on what the client authorises. The same insurer's example lets the insurer give the new broker policy wordings, schedules, claim details and other information needed to review the client's insurance. The new brokerage should limit its request to what the client signed.
Does the Code of Practice cover the new relationship?
It covers the terms of engagement, which include the remuneration the brokerage will earn (clause 4.2). A new client should receive those terms in writing before the brokerage begins to act, or as soon as practical if the client wants immediate steps taken, so the fee and commission in the file are information between the brokerage and the client.

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