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Module 0: Start here

Client data and confidentiality

20 minutes. Last checked 8 November 2026.

Lesson 2 of 3 in this module

Everything in this lesson is fictional: the practice (Harlow & Penn Accountants), its clients and their emails. Do not paste real client data to follow along.

What you will do

Anonymise a client email so the client cannot be identified, then turn it into a to-do list for the client file.

When to use it

A client sends a long email and you want help sorting it. This replaces pasting the whole email into a chat tool, name and all, or not using AI on client work at all because you are not sure what is allowed.

The seven PCRT bodies, including ICAEW, published guidance on using AI tools in tax work on 19 January 2026. On client data it says this:

  • The guidance says that putting client data into a publicly available AI tool is likely to breach client confidentiality, unless the client has consented.
  • Data you put into a publicly available AI tool should be anonymised and generic, so that the client cannot be identified.
  • Removing the client's name may not be enough: an unusual detail, such as an uncommon service they are known for, may still identify them.
  • The guidance suggests considering AI tools that are not made for public use, and anonymising any data where that is not possible.
  • Once you enter information into a publicly available AI tool, you lose control over how it is stored and kept.

The guidance says members also need to consider data protection law (GDPR and the Data Protection Act), and it points to the ICO website for more on AI and data protection.

So before you paste, pick one of two routes: anonymise it so the client cannot be identified, or use a tool not made for public use. Which tools count as not made for public use is a decision for your firm. Write it down in your AI policy (lesson 3.2).

The data settings. ChatGPT and Claude each have a setting that controls whether your chats are used to improve their models. The paths below are for the personal plans. Menus move, so check the path on the day.

ToolWhere the setting is
ChatGPT (Free, Plus or Pro)Settings, then Data controls, then turn off "Improve the model for everyone"
Claude (Free, Pro or Max)Settings, then Privacy, then turn off "Help Improve our AI models"

Check whether the setting is on before you start. Turning it off changes what the provider does with your chats. This course still treats the tool as publicly available, so anonymise as well. For any other tool, Copilot included, look for a data or privacy section in its settings, or ask whoever runs your firm's IT.

On your next working day, before you paste any client email:

  1. Choose the route: a tool not made for public use, or anonymise.
  2. To anonymise, copy the email into a plain document first, not into the AI tool.
  3. Replace every name, email address, phone number, postal address, UTR, National Insurance number, bank detail, company or trading name and named person with a placeholder in square brackets, such as [CLIENT] or [PROPERTY 1].
  4. Make any unusual detail generic. "The only alpaca-trekking business in Dorset" becomes "a small outdoor activities business".
  5. Read it once as a stranger would. If anyone could still work out who it is, make it more generic.
  6. Paste the prompt below with the anonymised email. Put the real details back yourself, outside the AI tool.

What step 4 changes, on one line of a client email:

Name removed only

"I'm still running the only alpaca-trekking business in Dorset, so I'm busy until October."

The name is gone, but anyone local could name this client.

Anonymised

"I'm still running a small outdoor activities business, so I'm busy for a few months."

No detail is left that points to one business or one person.

If a client asks you not to use AI on their work, the guidance says to acknowledge the request; you may need specialist advice, and you may consider discussing with the client which uses of AI they would find unacceptable.

The prompt

Prompt parts:

  • Role
  • Context
  • Task
  • Inputs
  • Constraints
  • Format
  • Questions first

  1. Part 1. Role: You are helping a UK accountant at a small practice organise a client email for the client file.

  2. Part 2. Context: The email below has been anonymised. Placeholders in square brackets, such as [CLIENT] and [PROPERTY 1], stand for details I have taken out.

  3. Part 3. Task: Turn the email into a to-do list for the client file.

  4. Part 4. Inputs: The anonymised client email, pasted below.

  5. Part 5. Constraints: Keep every placeholder exactly as written, and do not guess what it stands for. Do not answer the client's questions and do not give tax advice. Where the email does not give a fact we will need, write "not stated".

  6. Part 6. Format: Three headed lists: "The client is asking", "The client has told us" and "We need to find out or do". One line per item.

  7. Part 7. Questions first: If anything you need is missing, ask me before writing.

[paste the anonymised email here]

Why this prompt works

The Constraints part does the most work: telling the tool to keep every placeholder as written means the list comes back with [CLIENT] and [PROPERTY 1] where you left them, so you can put the real details back without the tool ever seeing them.

Sample input

Paste this under the prompt, in place of "[paste the anonymised email here]".

Sample input

FICTIONAL SAMPLE FOR COURSE PRACTICE. Not a real client.
Harlow & Penn Accountants, client email, anonymised before pasting

Hi,

Quick update before our meeting. I started letting out [PROPERTY 1], a flat I inherited from my aunt, from 1 September. The rent goes into my personal account. I also sold some shares in [COMPANY A] in October, which my partner and I owned jointly.

Do I need to tell HMRC about the flat straight away, or can it wait until my tax return? And will I pay tax on the shares?

My new phone number is [PHONE]. The business is going as usual: I still run a small outdoor activities business.

Thanks,
[CLIENT]

Example output

Example output. Yours will differ in wording.

(Fictional, written for this course.)

The client is asking

  • Whether they need to tell HMRC about the rent from [PROPERTY 1] now, or whether it can wait until their tax return
  • Whether they will pay tax on the shares in [COMPANY A] sold in October

The client has told us

  • They started letting out [PROPERTY 1], a flat they inherited from their aunt, from 1 September
  • The rent goes into their personal account
  • They sold shares in [COMPANY A] in October, owned jointly with their partner
  • Their phone number is now [PHONE]
  • Their outdoor activities business carries on as usual

We need to find out or do

  • Update the phone number on file to [PHONE]
  • Rent received and letting costs since 1 September: not stated
  • When the client inherited the flat: not stated
  • Sale date, sale proceeds and cost of the [COMPANY A] shares, and how the shares were split between the owners: not stated
  • Answer both questions at the meeting

What to check

  • Every placeholder, spelt as you wrote it. [PROPERTY 1] should not come back as [PROPERTY] or "the property". A changed placeholder is easy to put back wrongly.
  • No guessed details. No name, town, company or date in the list that was not in the email. A guess at what a placeholder stands for is a fault, even if it happens to be right.
  • Questions listed, not answered. The two questions should appear under "The client is asking" with no answer attached. The answers are yours to give.
  • The "not stated" items. Each is a real gap in the email. Add any it missed from your own knowledge of the job, and delete any that do not apply.
  • Your anonymised copy. Before you paste, read it once more for details that could still identify the client: an uncommon service, a rare job title, a well-known local business.
  • The real details, put back by you. Swap each placeholder back in the client file, outside the AI tool.

Variations

  1. A call note instead of an email. Change "client email" to "my notes from a phone call with the client" in the Role, Context and Inputs. Anonymise the notes first, the same way.
  2. Questions to send back. Change the Format to "a numbered list of the questions we need the client to answer, in plain English, one per line".
  3. Two clients in one email. For a couple who write jointly, use [CLIENT 1] and [CLIENT 2], and add to the Constraints: "Say which client each item is about."

Try it

About 10 minutes. The email below has not been anonymised. First, list what you would replace or make generic before pasting it into a publicly available tool. Then write the whole prompt for a new job: a numbered list of questions to send back to the director, so you can prepare the year-end accounts.

Fictional email to use:

Sample input

FICTIONAL SAMPLE FOR COURSE PRACTICE. Not a real client.
Harlow & Penn Accountants, client email, NOT anonymised

From: dan.okafor@brightwaterjoinery.example
Subject: Year end

Hi,

Our year end was 30 September. We finished the oak doors for St Aldhelm's Abbey in August, which was our biggest job ever, and we bought a new spindle moulder for it. Sales were up, but I have not sent the bank statements yet. Do you need the stock count? My mobile is 07700 900123.

Dan Okafor
Director, Brightwater Joinery Ltd

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