1. What This Policy Is About
This policy explains how Ascendancy Planning Pty Ltd ("the Firm", "we", "our" or "us") uses artificial intelligence ("AI") in our business operations and in providing services to our clients and persons who interact with us.
AI technology is now part of many everyday software tools. As a financial advisory firm, we want to be open about how AI is used across our business. This policy sets out the types of AI tools we may use, how we use them, and the steps we take to use them responsibly.
This policy is guided by Australia's AI Ethics Principles published by the Department of Industry, Science and Resources, and by the Guidance for AI Adoption published by the National AI Centre in October 2025. It also takes into account the findings and best practices set out in the Australian Securities and Investments Commission ("ASIC") Report 798: Beware the Gap — Governance Arrangements in the Face of AI Innovation (October 2024).
2. AI in the Software We Use to Operate
Many of the software platforms the Firm uses to operate its business now include AI features. These platforms are provided by third-party technology companies, and their AI features may be updated from time to time as those companies release new capabilities.
For example, we use Google Workspace, which provides our email, calendar, document collaboration, and data storage services. Google Workspace includes AI-powered features such as smart compose, grammar suggestions, and search functionality that may use AI to improve the relevance of results.
Other software systems we use for communication, data storage, security, file management, and business operations may also include AI features provided by their developers. We do not always have granular control over every AI feature built into the platforms we use, but we take reasonable care to review software updates and new features as they are released.
Where a new AI feature in a software platform could affect how client or personal information is processed, we assess the feature and its privacy implications. Where possible and appropriate, we adjust settings to align with our privacy obligations under the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs").
3. AI Tools and Models We May Use
In addition to the AI features built into our everyday software, the Firm may use one or more standalone AI tools and large language models ("LLMs") to support our operations and the delivery of our services. These may be used directly by our staff, or indirectly through the software platforms and systems we operate.
At the time of this policy, the AI tools and models we may use include, but are not limited to:
- OpenAI ChatGPT and other models
- Google Gemini models
- Anthropic Claude models
This list is not exhaustive. Other AI models and tools may also be used by the software providers that the Firm engages, or may be adopted by the Firm in the future as the technology landscape evolves. The Firm does not limit itself exclusively to the models named above.
We take care to ensure that any AI tool or model we use — directly or through a third-party platform — is used in a manner consistent with our privacy obligations and professional duties.
4. Where We May Use AI Across Our Business
The Firm may use AI across a range of areas in our business operations and in the provision of services to clients. The following is a description of the types of activities where AI may be used:
Emails and communications: AI features may assist with drafting, reviewing, or organising emails and other written communications. AI may also be present in our instant messaging and video conferencing platforms.
Data storage and security: AI may be used in our data storage and security systems to help detect threats, manage access, and protect information.
Processing unstructured data: We may use AI to process unstructured data sources, such as meeting recordings and other large video and audio files, and bundles of unstructured data files.
Supporting internal operational tasks: AI may be used to assist with scheduling, task management, document preparation, research, and other day-to-day operational activities.
Analysis of complex documents: AI may be used to support the analysis of complex financial documents, statements, product disclosures, and other technical materials.
Quality assurance: AI may be used to support internal quality assurance processes, such as reviewing documents for consistency, accuracy, or compliance with internal standards.
This list reflects how we currently use, or may use, AI. As AI technology develops, we may adopt additional uses for AI within our business. Any such adoption will be carried out in accordance with this policy and our broader professional
obligations.
5. How We Use AI and Agentic Systems
The Firm may use AI-powered tools that can carry out tasks with a degree of autonomy. These are sometimes called "agentic" systems. For example, an agentic tool might be used to extract and organise information from a set of documents, or to carry out a sequence of related steps as part of a workflow.
We use AI and agentic systems as tools to support the work of our staff and qualified professionals. AI does not make decisions on behalf of the Firm. It does not independently prepare, approve, or sign off on any client-facing documents or advice.
Our professionals use their own skills, training, and professional judgement in all casework. AI may be used to support them in gathering, organising, and reviewing information, but the final decisions, conclusions, and recommendations are always made by a qualified person.
6. Human Oversight and Professional Practices
A core principle of our approach to AI is that a qualified human professional is always involved in the work that matters. This is often referred to as a "human-in-the-loop" approach.
In practice, this means:
All casework is led by qualified professionals. Our financial advisers hold the qualifications and authorisations required under the Corporations Act and meet the professional standards set by ASIC. AI supports their work but does not replace their expertise.
All internal documents are reviewed by a person. Where AI has been used to assist in the preparation of an internal document, a staff member or professional reviews the output before it is relied upon.
All client-facing documents are prepared and signed off by a qualified professional. Statements of Advice, Records of Advice, and any other documents that are provided to clients are reviewed, approved, and signed off by an appropriately qualified person.
We are mindful of the findings in ASIC Report 798, which highlighted the importance of keeping governance frameworks aligned with the pace of AI adoption. We regularly review how AI is being used across our business to make sure our practices remain appropriate, reasonable, and safe.
This approach is consistent with Australia's AI Ethics Principles, which include the principles of accountability, transparency, and human oversight.
7. Protecting Your Information When We Use AI
We take care to ensure that personal and confidential information belonging to clients and other persons is not accessed by AI systems without appropriate consideration.
Where we use AI tools that process personal information, we do so in a way that is consistent with our Privacy Policy and the APPs. We do not enter personal information into AI tools without a legitimate purpose connected to the services we are providing or our professional obligations.
Before using a new AI tool or service, we assess its data handling practices. We consider where data is stored, who has access to it, and whether the provider's terms allow the data to be used to train AI models. Where we have concerns, we take steps to address them, such as using enterprise-grade versions of AI tools that offer enhanced privacy protections, or choosing not to use a particular tool.
We exercise our best care to review updates and new features released by our software and AI providers that may change how personal information is handled.
8. Keeping Up With Changes in AI
AI is a rapidly evolving technology. We are committed to staying informed about developments in AI and to updating our practices as needed.
This includes monitoring guidance from ASIC and other relevant regulators, reviewing changes to the software and AI tools we use, and maintaining awareness of best practices published by organisations such as the National AI Centre and the Office of the Australian Information Commissioner ("OAIC").
We also provide guidance and training to our staff and professionals on the responsible use of AI, so they understand how to use these tools safely and in line with our professional obligations.
9. Changes to This Policy
We may update this policy from time to time to reflect changes in the law, in the AI tools we use, or in industry best practices. Changes may be made without prior notice.
However, where changes are material, we will take reasonable steps to inform existing clients and persons we are engaged with, through common communication channels such as email.
The most current version of this policy will always be available on our website or upon request.
10. How to Contact Us
If you have any questions about how we use artificial intelligence, or if you would like to discuss any aspect of this policy, please contact us or call 1300 317 437.