Underwriting submissions and AI security: what liaising with an insurer gives away in ChatGPT or Claude.

A submission to an underwriter is the broker’s sales pitch for the client’s risk. It has to be complete, because the client’s duty of disclosure depends on it, and persuasive, because the premium depends on it, which is why brokers draft it in ChatGPT or Claude. It carries the business’s finances, its directors, its claims, its security and its contracts. This page marks every item in a typical submission that the Insurance Contracts Act, the Code of Practice and the Privacy Act bear on, and shows how the same submission is drafted on Ermos inside the brokerage.

The submission to an underwriter

Sent to an underwriter to obtain terms for a new placement or a renewal, with the client’s disclosures and the broker’s presentation of the risk.

To:
From:
Subject: Submission: , business pack and liability, 1 December

Alex, as discussed, the Harbourline risk for your consideration.

The business.

Claims.

Risk management.

Financials.

What we are seeking.

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

What leaves the brokerage

  1. 1
    The underwriter

    A named individual at a named insurer. A third party’s personal information, and the brokerage’s market relationships. Privacy Act guide.

  2. 2
    The client

    Named. Everything below is identifiable. Privacy Act guide.

  3. 3
    The business, its downturn and its officers

    Turnover and its fall, a lost customer named, forecasts, and the director and company secretary, with a date of birth. Commercial and personal information, including about a customer that is nobody’s client here. Privacy Act guide.

  4. 4
    The claims, including an open indemnity dispute

    Two claims and the fact that the current insurer may decline indemnity. Disclosed to this underwriter because the duty of disclosure requires it; disclosed to a frontier model because nobody thought about it.

  5. 5
    Risk management, security and a regulator notice

    Safety measures, alarm and sprinkler status, and a closed SafeWork notice. Operational and security information about a named premises.

  6. 6
    The financials

    Profit, lenders, balances and a director’s loan under repair, with the accountants named. A complete financial picture of the business and its director. Privacy Act guide.

  7. 7
    The ask

    What the broker wants from the insurer, including a candid note about the claim. Negotiating position.

  8. 8
    The off-the-record paragraph

    That the client will move for 10%, and the broker’s preference. The brokerage’s own negotiating hand, and the client’s, in two sentences nobody wanted written down.

  9. 9
    The broker

    Ties the submission 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 submission to an underwriter?
Both receive the whole submission on the AI company's servers once it 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 submission bundles the client's financials, a director's date of birth and the full claims history.
Is it safe to paste a submission to an underwriter into ChatGPT or Claude if we leave the client's name out?
Not safely, because the business details identify the client without the name. 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. An architectural joinery maker established in 2014, with six staff, a lost contract and a spouse as company secretary, describes one business and two people. 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 remember the details in a submission to an underwriter later?
Yes, where a memory feature is switched on. Both products also have memory features that can carry details from one conversation into later ones, and on a personal account each user decides whether they are switched on (ChatGPT, Claude). A submission holds a lost customer's name, a regulator's improvement notice, an open indemnity dispute and an off-the-record note that the client will move for a 10% saving. A broker who prepares many submissions has to decide whether any of those details should go near a memory feature at all.
How can a brokerage use AI for a submission to an underwriter 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 submission is drafted from the client file, the claims register, the financials and the brokerage's previous submissions. The broker shapes the pitch, checks every figure and signs it off before it goes to the underwriter.
The underwriter needs all of this. Isn't it going to an insurer anyway?
The underwriter is the party the client's duty of disclosure runs to, and insurers are bound by their own obligations in handling it. A frontier model provider used to draft the submission is a company with servers, for the major ones outside Australia, retaining the draft on its own terms, with the off-the-record paragraph included.
Does the duty of disclosure make the submission more sensitive?
It makes it more complete. Section 21 of the Insurance Contracts Act requires the insured to disclose matters relevant to the insurer's decision, and the broker's job is to present them fully. A complete submission is, by design, everything about the business that matters.
How is a submission drafted on Ermos?
From the client file, the claims register, the financials and the brokerage's previous submissions, all on your own unit. The broker shapes the pitch and sends it. Nothing about the client, the claim or the market leaves the brokerage to produce it.

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