AI Disclaimer and Disclosure Wording for Brokers

When to Disclose AI Use

Disclose AI use when it changes what clients need to understand about your service or how you handle their information. Separate privacy notices from a label saying that AI helped write something.

The National AI Centre’s disclosure guidance says the approach depends on the content’s impact and AI’s contribution. Financial information calls for clearer disclosure when people could rely on it for decisions. Low-impact content with limited AI assistance can need minimal or no disclosure.

Required Privacy Information

If the Privacy Act covers your brokerage, the Australian Privacy Principles (APPs) govern how you explain personal-information handling. APP 5 requires reasonable steps to notify clients of specified collection matters, including purposes and usual disclosures. The Office of the Australian Information Commissioner (OAIC) explains these in its collection-notice guidance.

When AI changes those practices, make the notices match. A footer added to an email after you upload client information doesn’t perform the same job as an appropriate collection notice.

Scheduled automated-decision transparency rules cover personal information used in decisions significantly affecting someone’s rights or interests. They also cover computer assistance substantially and directly related to those decisions.

The OAIC’s APP 1 guidance gives their commencement and required policy details. Human review alone doesn’t remove a system from scope.

Expected Disclosure in Client Interactions

Tell clients when they’re speaking to an AI chatbot. The OAIC’s AI privacy takeaways recommend clearly identifying public-facing AI tools and explaining AI use in privacy policies and notices.

For a client document that AI substantially drafted, explain its contribution and the broker’s review beside that document. This is a practical transparency recommendation. Apply any additional wording your credit licensee requires.

Optional Labels for Minor Editing

A separate AI drafting label can be optional where the work is low impact and AI’s contribution is limited, such as correcting grammar. That doesn’t remove privacy duties or your licensee’s requirements.

For example, editing a generic appointment reminder differs from generating an explanation of a client’s loan options. The second task affects what the client understands about the recommendation and needs closer review.

AI Disclaimer Examples

Use an AI disclosure statement that names the task AI performed and explains the human review. The examples below are starting wording for the stated situations. Keep a review claim only if someone completed that review.

Email Drafted With AI

For a message that you personally checked, use this short line:

AI helped draft this email. I checked it before sending. Please contact me if anything needs explaining.

Put it near the end of the message where the client can read it. A generic signature on every email can imply AI involvement even in messages written entirely by you.

Website Content Reviewed by the Brokerage

For a website where AI helps draft educational content, this wording describes the process:

We use AI to help draft some website content. Our team reviews that content before publication. Contact us to discuss how the information applies to your circumstances.

Place the statement with the relevant content or in a clearly accessible explanation of your publishing process. If your site has a chatbot, label the chatbot itself before the conversation starts.

For a chatbot used only for general enquiries, a separate notice can say:

You’re chatting with an AI assistant for general enquiries. Please don’t enter personal or financial details. Contact our team for help with your circumstances.

Use that wording only for a chatbot whose purpose and collection design match it. An instruction not to enter personal details doesn’t replace controls for handling information people submit anyway.

Client Document With AI-Assisted Drafting

For a document a broker has checked against the client information, use this example:

AI helped prepare this document. Your broker checked it against the information you supplied before issuing it. Please tell your broker if any details are incorrect.

Keep the explanation with the document, including copies exported as PDFs. Explain the actual check instead of claiming that human review guarantees accuracy.

Warning About AI Errors

An “AI can make mistakes” disclaimer needs a useful next step. For general AI-generated information awaiting a broker’s assessment, wording can say:

AI-generated information can contain errors. Speak with your broker before relying on it for a lending decision.

For a completed recommendation, that sentence doesn’t replace the broker’s assessment. Under ASIC’s mortgage broker guidance, brokers must act in the consumer’s best interests when providing credit assistance. An AI disclaimer doesn’t transfer that duty to the client.

Tell Clients You Use AI

Explain AI use in the fact-find process before clients provide information, and keep the fuller account in your privacy policy. Describe the actual data flow so clients understand where their information goes.

Fact-Find Wording

When a provider prepares summaries from client information, you can explain that step on the fact-find form:

We use AI to help organise the information you give us and prepare draft summaries. Your broker checks the results against your information before using them. Our collection notice explains how we handle your information and disclose it to service providers. Ask your broker if you’d like to discuss this process.

Place the explanation beside a prominent link to your complete collection notice. The notice must accurately describe the purposes and disclosures relevant to the information collected. Use a privacy collection notice to cover those matters beyond the short AI statement.

Treat a request to discuss AI use as a conversation about the actual service. Don’t promise an AI-free option unless your brokerage can provide one. If a particular use needs consent, obtain the required informed consent separately from this explanation.

Privacy Policy Wording

For the same workflow, this paragraph describes the disclosure to your AI provider:

We disclose client information about employment, income and existing debts to an AI service provider to prepare draft summaries. Our brokers check those summaries against the source information before using them. We use the summaries to assist our work on your enquiry.

This paragraph is one part of the policy. Describe the actual information your provider receives and the purposes of that processing. Your full policy must also cover the applicable privacy matters, including access and correction, complaints and likely overseas disclosures.

Avoid claims such as “your data never leaves Australia” or “AI providers cannot access your information” unless your arrangements support them. If AI supports significant client decisions, assess the scheduled automated-decision transparency requirements as well as the general privacy-policy requirements.

Keep an internal record of the AI task, source material and the broker’s review where it helps explain the work on the file. Your AI policy template can assign responsibility for those checks. Before using any example statement, trace one real workflow and confirm that every sentence describes what your brokerage actually does.