Another aspect of 'agency records' is the concept of 'personal records'. In the leading case on this point, the court held that notes made by an agency employee could be his own and outside the FOIA concept of 'agency records' if they were made and kept

Another aspect of 'agency records' is the concept of 'personal records'. In the leading case on this point, the court held that notes made by an agency employee could be his own and outside the FOIA concept of 'agency records' if they were made and kept purely voluntarily and 'not circulated to nor used by anyone other than the authors, and are discarded or retained at author's sole discretion for their own individual purposes in their own personal files.' Porter County Chap., Etc. v. U.S.A.E.C., 380 F. Supp. 630, 633 (N.D. Ind. 1974).