At five o'clock, a mortgage adviser still has three meeting notes to write up. She pastes her notes from the intake meeting into ChatGPT and asks for a tidy version for the file. The notes contain the client's name, her date of birth, the household income, two IBANs and a remark that her partner has been unable to work since last year.
The task made sense: turning loose notes into a readable report is exactly what such a tool is good at. The data did not need to go in. That is the whole answer in one sentence: the task can usually go into an AI tool your firm has allowed for it, and the client should not be identifiable in it. What you need to take out depends on what you ask the tool to do.
Why does this matter more in financial services?
Because the text you handle on an ordinary day is almost always about a client, and because that client has told you things they tell few others. An income, a debt, an account number, the reason a mortgage does not add up after all. In a disability or claims file, there is medical information as well. That openness is the basis of the profession, and it is exactly what is at stake in a prompt.
The Dutch Data Protection Authority received several breach notifications in which employees had put personal data into an AI chatbot, and advises organisations to set clear rules on whether it is allowed, and with which data. For a firm under financial supervision, there is the added question of whether it handles client data with care, because that is part of sound business operations. What that means for a firm is covered in AI in financial services.
This is not about you being the risk. You use the tool because the note gets done faster and reads better. The only question is what goes into the tool with it.
Which ChatGPT are you using?
There is no single ChatGPT. A free or personal account runs under consumer terms: your input can be used to improve the model unless you switch that off yourself, and your firm has no data processing agreement with it. OpenAI states on its enterprise privacy page that the business environments do not use input for training by default. That is a different product on different terms, even though the screen looks the same. The difference is set out in free versus business AI accounts. Whether ChatGPT is safe for client work at all is covered in our article on whether ChatGPT is safe to use at work.
A meeting note with an IBAN in a personal account is therefore a data breach, even if you delete the conversation straight afterwards. Which variant you may use is a decision for your firm. Many firms have allowed Copilot and have decided nothing about ChatGPT yet. "No decision yet" does not mean it is allowed; it means nobody has looked at it. As long as that is the case, no text with client data belongs in it.
At firms that work with BeeSensible, the decision appears in the browser the moment you open an AI tool: allowed, limited use with a condition, no decision yet or not allowed, with the alternative named. Usually you can carry on; the only exception is a tool that is not allowed, where your firm may have set things up so that you cannot continue.
