Client data and AI: a beginner’s guide
Most of the risk with AI isn’t the AI. It’s what gets typed into it. Here’s what happens to what you type, what’s safe to put in, and five steps to set your firm up.
For beginners · Checked 11 November 2026 · Not advice
In plain English
When you type into an AI chat, it goes to the AI company’s servers, usually overseas. Depending on your plan and settings, they may keep it for a while and may use it to improve their models.
Once it’s sent, you can’t take it back. So the safest habit is simple: client details stay out of the chat. A quick test: if you wouldn’t be happy to see it on the front page of a newspaper, don’t put it in.
What happens when you press enter
- You type or attach Your prompt and any file you add are sent over an encrypted connection to the AI provider.
- The provider processes it On its servers, often overseas, sometimes on other companies’ cloud services.
- It’s kept for a while Logs are kept for a period. Depending on your plan it may train models, and flagged chats can be reviewed by the provider’s staff.
What can go into an AI tool?
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Go: Fine to use
- Your own writing, templates and checklists with no client details
- Public information: ATO guidance, legislation, published rates
- Made-up examples and sample data
- Text with client details swapped for placeholders
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Take care: Only in an approved business tool
- Client work with names and identifiers removed
- Internal documents: procedures, pricing, staff guides
- Anything your AI policy allows, with training switched off
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Stop: Never in an AI chat
- TFNs, bank, Medicare, licence and passport numbers
- Client files, returns and financials with names on them
- Health, family or other sensitive details about a client
- Passwords, logins and API keys
Some firms approve an enterprise tool for more, such as an AI assistant that works inside the firm’s own Microsoft or Google account. That’s a firm decision with your IT provider, written into your AI policy, not one person’s call.
Does the AI learn from what I type?
- Free and personal plans
- Often yes, unless you switch it off. Look for a setting like “Improve the model” or “Help improve” in the privacy or data controls settings.
- Business and enterprise plans
- The big providers say they don’t train on business customers’ data by default. Read your plan’s terms to confirm it.
- A business plan doesn’t make you compliant
- Under a business plan’s data processing agreement, the provider handles data on your instructions, but your firm stays responsible for what goes in. Putting a TFN into a business plan is still your call, and your risk.
- Feedback buttons can share a chat
- On some tools, a thumbs up or down sends that conversation to the provider for review, even with training off. Give feedback in the chat instead.
- Training off doesn’t mean deleted
- Providers usually keep chats for a period for safety, abuse checks and legal reasons, even with training off.
Plans, names and settings change often. Check yours before you rely on this.
For beginners
Set your firm up in five steps
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Step 1: Choose one tool, on a business plan
Pick one AI tool for the firm and pay for business accounts. Free accounts are for no client work at all.
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Step 2: Switch training off everywhere
On every account, including the personal ones staff already use. Check chat history and memory settings while you’re there.
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Step 3: Write the rule down
Put the traffic lights above into your AI policy, and walk the team through it. Our free AI policy template is a starting point.
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Step 4: Strip client details before you paste
Swap names and numbers for placeholders first. Our redaction tool does it on your own computer.
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Step 5: Tell clients and keep a record
Say how you use AI in your engagement letter, and keep a list of the tools you use and what they’re approved for.
The rules you already follow
AI doesn’t change your obligations
An AI provider is a third party. The duties you already have still apply when you use one.
- ConfidentialityThe Code of Professional Conduct in the Tax Agent Services Act says not to disclose a client’s information to a third party without their permission, unless you have a legal duty to.
- PrivacyWhere the Privacy Act applies to your firm, the Australian Privacy Principles cover how you use and disclose personal information (APP 6), sending it overseas (APP 8) and keeping it secure (APP 11).
- The regulator’s viewThe OAIC’s guidance on commercially available AI products recommends not entering personal information, particularly sensitive information, into publicly available AI tools.
This is a plain-English summary, not legal advice. Check your own obligations with your professional body or adviser.
Before you approve a tool
Questions to ask any AI provider
Training is only one question. Most providers answer the rest in a trust or privacy centre and a data processing agreement. If they can’t answer, don’t approve the tool.
- Who can access our data, including your own staff?
- Where is it stored, and where is it processed? The two can differ.
- How long is it kept, and can we delete it?
- Is it used to train models on our plan, and can we switch that off for everyone?
- Which other companies handle it for you, and where are they?
- What admin controls and activity logs do we get?
- Which security certifications do you hold, such as ISO 27001 or SOC 2?
Keep the answers with your AI policy, so you can show how you stayed accountable for the data.
If client data has already gone in
- Don’t panic, and don’t hide it. Tell whoever handles privacy in your firm.
- Delete the chat, and note what was shared, when and in which tool.
- Check that tool’s terms for how long it keeps data and whether it trains on it.
- Treat it like any other possible privacy incident: follow your data breach response plan and assess whether it’s likely to cause serious harm.
- Fix the cause: training settings, the policy, or a quick refresher for the team.
Use these next
- Client data redaction tool → Swap client details for placeholders on your own computer before you use AI.
- AI policy template → Approved tools, client data rules, review, disclosure and sign-off.
- Client AI data checklist → What may go in, what must be stripped first, and what never goes in.
- Connecting AI to your systems → The beginner’s checklist for MCP connectors to Xero, practice software and email.
- Summit notes: Is it safe? → Billie Mcloughlin’s session on plans, settings, shadow AI and a three-step plan for your firm.
- Is AI safe for client data? → The accountant’s straight answer, in more depth.
- Client consent for AI → What to tell clients, when to ask, and a letter to send.
- AI notetakers on client calls → What to ask any notetaker vendor about your clients’ data.