Is it safe to use AI for NDIS case notes?
It can be, if the provider treats it as a privacy and accuracy decision and not a shortcut. The OAIC states that the Privacy Act applies to all uses of AI involving personal information, and recommends as best practice that organisations do not enter personal information, particularly sensitive information, into publicly available generative AI tools. The provider remains responsible for complete and accurate records.
Key takeaways
- Privacy obligations apply to personal information put into an AI system and to AI output that contains personal information.
- The OAIC recommends not entering personal information, particularly sensitive information, into publicly available generative AI tools.
- Incorrect or made-up information that AI produces about an identifiable person is still personal information.
- Records must be complete, truthful and accurate, so a worker should read and own every note.
Is it safe to use AI for NDIS case notes?
The answer depends on which tool, what goes into it and who checks the result. Case notes describe a named person’s health, behaviour and support needs, so they are likely to include sensitive information. Two sources set the frame: the Office of the Australian Information Commissioner on privacy and AI, and the NDIS on record keeping.
What does the OAIC say?
The OAIC guidance on commercially available AI products (published 21 October 2024, updated 17 January 2025) states:
- The Privacy Act applies to all uses of AI involving personal information.
- Privacy obligations apply to any personal information input into an AI system, as well as the output data generated by AI where it contains personal information.
- Inferred, incorrect or artificially generated information produced by AI models, such as hallucinations, is personal information where it is about an identified or reasonably identifiable individual, and must be handled in accordance with the Australian Privacy Principles.
- If personal information is input into an AI system, APP 6 requires an entity to use or disclose it only for the primary purpose it was collected for, unless it has consent or a permitted secondary use applies.
- As a matter of best practice, the OAIC recommends 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.
- Before adopting a commercially available product, an organisation should do due diligence, including whether the product has been tested for the intended use, how human oversight can be built into the process, the privacy and security risks, and who will have access to the personal information put in or generated.
What does the NDIS require of the record itself?
The NDIS states that a provider needs to keep complete and accurate records of NDIS supports delivered and that claims for payment must be complete, truthful and accurate. The Practice Standards outcome for information management is that each participant’s information is identifiable, accurately recorded, current and confidential. An AI tool does not move that responsibility away from the provider.
A checklist for using AI safely with case notes
This is practical guidance built on the OAIC points above, not a legal test.
- Do not paste participant details into a public chatbot. If you would not email it to a stranger, do not put it in a free tool.
- Ask where the data goes. Find out where it is processed and stored, who can see it, whether it is kept and whether it is used for training.
- Keep the worker as the author. The person who was there should write the note. Tools that check what the worker wrote reduce the risk of made-up detail, compared with tools that generate the note.
- Read every word. A worker who signs a note owns its accuracy.
- Remove identifiers where you can. Sending less personal information reduces the risk.
- Write it down. Record the tool, what it is used for, who approved it and how output is checked, and tell participants in your privacy notice.
What is the difference between a tool that writes notes and one that checks them?
A generator produces text the worker did not observe, which raises the accuracy and accountability risk above. A checker reads what the worker wrote and returns weak notes with specific guidance before they are saved. NoteGate is a checker: the worker is always the author, participant data is stored in Australia on AWS Sydney, and identifiers are tokenised before a third-party AI service checks a note, so that service sees de-identified text. See the security page for how it is handled, and the comparison guide for the difference in more detail.
This guide is general information, not legal advice. Check the OAIC guidance and your own obligations before adopting any tool.
Frequently asked questions
Can I put participant information into ChatGPT or another public AI tool?
The OAIC recommends, as best practice, 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.
Does the Privacy Act apply to AI?
The OAIC states that the Privacy Act applies to all uses of AI involving personal information, including information put in and output that contains personal information.
Who is responsible if AI writes something wrong in a case note?
The provider. The NDIS requires complete, truthful and accurate records, and the OAIC notes that incorrect information AI produces about an identifiable person is still personal information.
Is a note checker the same as an AI note writer?
No. A writer generates the note. A checker reviews what the worker wrote. NoteGate is a checker and never writes shift notes or incident reports.
Sources
- Guidance on privacy and the use of commercially available AI products (published 21 October 2024, updated 17 January 2025) (Office of the Australian Information Commissioner, retrieved 25 September 2026)
- What are the record keeping requirements (NDIS) (NDIA, retrieved 25 September 2026)
- Core module: Provider governance and operational management (Information management) (NDIS Quality and Safeguards Commission, retrieved 25 September 2026)
Related
Keep the worker as the author
See how NoteGate checks notes the worker wrote, with participant data held in Australia.
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