Shift progress notes and AI data leakage: what a support worker’s note gives away in ChatGPT or Claude.

A progress note is written at the end of a shift by a tired worker, often on a phone, in the car park. It records how the participant slept, what he took, what upset him, what he said in confidence and who was told. It is also the record that backs the hours the service claims. That makes it the document most likely to be pasted into ChatGPT or Claude to be tidied into proper sentences. This page marks every item in one community-access shift note that the Practice Standards, the Code of Conduct and the Privacy Act bear on, and shows how the same note is written up on Ermos inside the service.

The shift progress note

Written by the support worker at the end of each shift and read by the team leader. NDIA guidance on invoicing and record keeping expects providers to keep records of the supports they deliver, such as case notes and rosters, to support their claims.

Progress note · · Community access
Monday 19 October 2026 · ·

Arrival.

Activity. We walked to the shopping centre at Charlestown for socks and lunch.

Conversation.

Follow up.

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

What leaves the service

  1. 1
    The participant

    A named man and the support he receives. Personal information, held by a registered provider under the Information Management standard. Privacy Act guide.

  2. 2
    Sleep and medication

    How he slept and when he took a named medication. Health information, which is sensitive information under the Privacy Act. Patient data guide.

  3. 3
    A self-injury episode

    What triggered it, what he did to himself and how long it took to settle. Health information. The service has to decide whether anything in a note is a reportable incident; the categories are death, serious injury, abuse or neglect, unlawful contact or assault, sexual misconduct and a restrictive practice used without authorisation. There was no injury here. Patient data guide.

  4. 4
    A confidence about bullying and a visitor

    Something a man told a worker and asked her to keep from his mother. The Code of Conduct requires workers to respect the privacy of people with disability and to act with respect for their self-determination. Privacy Act guide.

  5. 5
    Hours and kilometres

    The hours and travel recorded for one shift. The note is also the evidence behind the claim; NDIA guidance expects providers to keep records of supports delivered to support their claims. Hours alone identify no one, but this sits beside his name.

  6. 6
    What the family was and was not told

    A decision about which facts reached his mother, and a referral to a named support coordinator. A judgement the service has to be able to explain to the participant and the nominee. Privacy Act guide.

  7. 7
    The worker

    Ties the note to a named worker, bound by the Code of Conduct, and to her own judgement calls. Privacy Act guide.

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 service 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 participant 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 NDIS services.

Common questions

Do ChatGPT and Claude use the information in a shift progress note?
Yes. Whatever a worker types or pastes into ChatGPT or Claude goes to the AI company's servers and is processed there to produce the 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 note carries how Daniel slept, a self-injury episode with its trigger, and something he told the worker in the car park and asked her not to pass on to his mother.
Is it safe to paste a progress note into ChatGPT or Claude?
No, a shift note is exactly the kind of document the privacy regulator has in mind. 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. Daniel's note records his sleep, the time he took his medication and a self-injury episode, which are health information, plus a confidence he asked to keep from his mother. Tidying the sentences does not change what the note says about him.
What if staff use their own ChatGPT or Claude account for shift notes?
Then the service cannot see or manage what was sent from that account. 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 worker finishing a note on a phone in the car park could send Daniel's medication time and a confidence about bullying with no record in the service, even though the note backs the hours it claims for the shift.
How can an NDIS provider use AI for shift progress notes without sending them 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 tidied note is written up from the worker's own entries in the service's note format. The support worker checks it against what happened on the shift and signs it before the team leader reads it.
Are progress notes part of the records an NDIS provider keeps for claims?
NDIA guidance on invoicing and record keeping expects providers to keep records of the supports they deliver, such as case notes and rosters, to support the claims they make. A shift note is therefore both a care record and a payment record, and it should be accurate and written close to the shift. The Information Management standard asks for accurate, timely records.
Does a self-injury episode have to be reported to the NDIS Commission?
Not automatically. Reportable incidents are the death or serious injury of a person with disability, abuse or neglect, unlawful sexual or physical contact or assault, sexual misconduct, and a restrictive practice used other than in accordance with authorisation. A brief episode with no injury and no restrictive practice is generally handled under the service's own incident management system, though the service decides each case.
Why does a worker's note about something a participant confided matter?
The Code of Conduct requires workers to respect the privacy of people with disability and to act with respect for their right to self-determination. A participant who asks a worker to keep something from a family member has made a decision about his own information. Pasting that note into ChatGPT or Claude sends the confidence to a third party the participant never agreed to.

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