Renewal declarations and AI: what a client’s disclosures give away in ChatGPT or Claude.

The renewal declaration is where the Insurance Contracts Act lives in a brokerage. For consumer contracts, section 20B requires the insured to take reasonable care not to misrepresent; for business contracts, section 21 imposes the duty of disclosure. The answers on the form are the client’s most sensitive admissions: claims, convictions, insolvency, cancelled policies, changes in the risk. Brokers paste the form into ChatGPT or Claude to check it or to draft the covering note. This page marks every item on a standard declaration and shows how the same check happens on Ermos inside the brokerage.

The renewal declaration

Completed by the client before each renewal, with the broker’s help, to meet the disclosure duties under the Insurance Contracts Act.

Renewal declaration
· Business pack renewal 1 December 2026 · Completed with

Claims or circumstances in the last 5 years
Any director or principal declared bankrupt, or a director of an insolvent company, in the last 10 years
Any director or principal convicted of a criminal offence, or subject to a regulator’s action
Any insurance declined, cancelled or renewal refused
Changes in the business or the risk
Declaration
Broker note

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

What leaves the brokerage

  1. 1
    The client

    Named. Every admission below is attributed. Privacy Act guide.

  2. 2
    Claims and a circumstance

    Two claims and an allegation of defective work by a named customer that is not yet a claim. Disclosed to the insurer because section 21 requires it; a disclosure about a third party as well.

  3. 3
    A past insolvency

    That the director’s previous company was wound up owing creditors. Personal information about a named individual’s financial history, ten years old and still asked about on the form. Privacy Act guide.

  4. 4
    A conviction and a regulator notice

    A named person’s criminal record and a safety regulator’s action. Among the most sensitive personal information the Privacy Act contemplates. Privacy Act guide.

  5. 5
    Declined and lapsed cover

    That one insurer declined the client and another policy lapsed. Insurance history that follows a client from placement to placement.

  6. 6
    Changes in the risk

    The downturn, the new contracts, an insurer’s concern and a planned change. Commercial information, and the business’s plans.

  7. 7
    The signed declaration

    The client’s statement that the answers are complete, with the consequences acknowledged. The document the insurer relies on, and the client’s protection if it is accurate.

  8. 8
    The broker’s note on how the answers were obtained

    That the client first answered no, and was prompted. The record that protects the client and the brokerage if non-disclosure is alleged, and the one that would be most damaging to the client if read without its context.

  9. 9
    The broker

    Ties the declaration to a named account manager bound by the Code of Practice.

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. See how this works in practice: Renewal preparation on Ermos.

Common questions

Do ChatGPT and Claude use the information in a renewal declaration?
Both receive every answer on the AI company's servers once the form is pasted. 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 renewal declaration lists an allegation by a customer, a director's past insolvency and a declined cover.
Is it safe to paste a renewal declaration into ChatGPT or Claude?
It is not safe, because the form is a list of one client's admissions, each attributed to the client or a named director. It records a drink driving conviction, a safety regulator's improvement notice, a lapsed workers compensation policy and a cyber cover declined by another insurer. A conviction is among the most sensitive personal information the Privacy Act contemplates. 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 ChatGPT or Claude be trusted to draft a renewal declaration?
Not without a qualified person checking each answer against the client file. Language models write fluent text that can contain details that are not in the source, wrong figures and wrong dates. They can also refer to a notice or a claim that looks real but is not. On a declaration the costliest errors are a wrong claim amount, a wrong deficiency figure and a wrong date for the wind-up, the conviction or the lapse. The insurer relies on the signed answers as complete.
How can a brokerage use AI for a renewal declaration 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 broker asks Ermos to compare this year's answers with the client file, the claims register and previous declarations. The broker then checks each difference with the client before the client signs.
What are the disclosure duties under the Insurance Contracts Act?
For consumer insurance contracts, section 20B, in force since 5 October 2021, requires the insured to take reasonable care not to make a misrepresentation to the insurer. For other contracts, section 21 imposes a duty to disclose matters the insured knows, or a reasonable person would know, to be relevant to the insurer's decision. For a contract of general insurance, section 28 reduces the insurer's liability on a claim to what it would have been without the failure, which can be nil, and if the failure was fraudulent the insurer may avoid the contract. Section 28 does not apply if the insurer would have entered the contract on the same premium and terms anyway.
Why is the broker's note the most sensitive item?
Because it records that the client initially answered no to questions about insolvency and a conviction, and was prompted. In context it shows the broker doing the job properly. Out of context it reads as a client who tried to hide something. It belongs inside the brokerage.
How are declarations checked on Ermos?
The client file, the claims register and previous declarations are on your own unit, and the broker asks it to compare this year's answers against what the file shows, which is how the prompts in the note were found. Nothing about the client's history leaves the office.

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