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Records Authority
Category: Records Lifecycle Concepts

Personal Papers

Also known as: personal records
Simply put

Personal papers are documents and materials that belong to an individual and are not used to conduct the business of an organization or agency. They typically relate solely to a person's private affairs rather than official duties. Because they are not created or used in the course of organizational activity, they are generally treated as distinct from the organization's records.

Formal definition

Personal papers are documentary materials belonging to an individual that are not used to conduct agency or organizational business and that relate solely to an individual's private matters. In recordkeeping practice they are typically distinguished from records and from nonrecord materials, since they fall outside the scope of an organization's recordkeeping obligations and are not subject to its retention and disposition controls. The classification of a given item as a personal paper depends on how it was created and used and on applicable organizational policy and jurisdictional rules; materials created or received in the course of official duties would generally not qualify as personal papers even where they concern an individual. Note that 'personal papers' should not be conflated with personnel records or personnel files, which document an individual's employment relationship and are usually organizational records held under the employer's control.

Why it matters

The distinction between personal papers and organizational records carries practical consequences for retention, disposition, and legal exposure. Because personal papers are generally treated as falling outside an organization's recordkeeping obligations, they are typically not subject to the retention and disposition controls that govern official records. Misclassifying material can create risk in either direction: treating genuine records as personal papers may remove them from required retention and produce gaps in the evidentiary record, while treating personal materials as organizational records may extend controls and searches to items that were never within scope.

The classification also matters for discovery, access requests, and investigations. In many jurisdictions, whether a document is deemed a record created or received in the course of official duties, rather than a private matter, can affect whether it is subject to disclosure, legal holds, or freedom of information regimes. Because the boundary depends on how material was created and used, and on applicable organizational policy and jurisdictional rules, the same physical or digital item may be treated differently across contexts. Clear criteria for identifying personal papers help organizations apply their obligations consistently and defensibly.

A common source of confusion worth correcting is the conflation of personal papers with personnel records or personnel files. Personnel files document an individual's employment relationship and are usually organizational records held under the employer's control, subject to the organization's retention and access rules. Personal papers, by contrast, relate solely to an individual's private affairs and are not used to conduct organizational business. Keeping this distinction explicit prevents both the under-protection of employment records and the over-reach of organizational controls into private materials.

Who it's relevant to

Records managers
Records managers rely on the personal papers classification to scope what is and is not subject to the organization's retention and disposition controls. Establishing clear, policy-based criteria for distinguishing personal papers from records and nonrecord materials helps ensure that genuine records are not removed from required controls and that private materials are not swept into organizational recordkeeping unnecessarily.
Archivists
Archivists encounter the distinction when appraising and accessioning materials, since documentary materials belonging to an individual that relate solely to private matters are generally handled differently from an organization's official records. The classification affects whether items are treated within the organization's recordkeeping framework or as separate personal holdings.
Information governance and compliance leads
Because whether an item is a personal paper or an organizational record can affect exposure to disclosure requests, legal holds, and privacy obligations, governance and compliance leads have an interest in defensible classification criteria. The dependence of these determinations on jurisdiction and organizational policy means qualified, documented approaches are typically preferable to blanket rules.
HR and personnel administrators
HR staff should be aware that personnel files, which document an individual's employment relationship, are usually organizational records held under the employer's control and are distinct from personal papers relating to an individual's private affairs. Conflating the two risks either under-protecting employment records or misapplying organizational controls to private materials.

Inside Personal Papers

Private, non-official material
Personal papers typically consist of documents created or received by an individual in a private capacity rather than in the course of their official duties. This includes private correspondence, personal notes, diaries, and materials unrelated to the functions of the organization or public office the individual holds.
Material outside organizational recordkeeping obligations
Personal papers generally fall outside the scope of an organization's records management program because they do not provide evidence of the organization's business activities. As such, they are typically not subject to the organization's retention schedules, classification, or disposition controls, though this depends on organizational policy and applicable law.
Distinction from records of official activity
The defining boundary is capacity: material generated while performing the duties of a role is often an official record, whereas material of a purely personal nature is not. This distinction can be difficult to draw where individuals mix private and work-related content, and the classification often depends on context, jurisdiction, and organizational policy.
Potential archival or historical value
Personal papers, particularly those of individuals of public significance, may hold historical or research value and are sometimes acquired by archives or manuscript repositories. Where transferred to such an institution, they are typically managed under archival rather than corporate recordkeeping frameworks, subject to any agreed conditions of deposit.
Mixed or ambiguous holdings
In practice, personal collections may contain a blend of genuinely private items and material that is arguably an organizational record. Determining status often requires case-by-case assessment against the criteria for what constitutes a record, including whether the item provides evidence of business activity.

Common questions

Answers to the questions practitioners most commonly ask about Personal Papers.

Are personal papers the same as personal data under privacy law?
No, and conflating the two is a common source of confusion. "Personal papers" is a recordkeeping concept describing materials that relate to an individual's private affairs rather than to the conduct of organizational business, and that therefore typically fall outside the organization's recordkeeping system and its retention and disposition controls. "Personal data" is a distinct concept drawn from privacy and data protection law, referring to information relating to an identified or identifiable individual. A document can be personal papers but contain little or no personal data, and conversely an authoritative business record can contain substantial personal data while not being personal papers at all. The two terms address different questions: personal papers concerns whether the material is a business record subject to the organization's control, while personal data concerns privacy obligations that depend on jurisdiction and sector.
Does labeling something "personal" automatically exclude it from the organization's records?
Not necessarily. Whether material qualifies as personal papers generally depends on its substance and function rather than on how it is labeled or where it is stored. If a document was created or received in the course of organizational business and provides evidence of that activity, it may be an organizational record regardless of a "personal" designation, an individual's private folder, or storage in a personal account. Depending on organizational policy and applicable jurisdictional requirements, the presence of business content can bring material within the scope of recordkeeping obligations, legal holds, or access requests. Treating a label as decisive rather than examining the character of the content is a frequent misconception this distinction is meant to correct.
How can an organization distinguish personal papers from organizational records in practice?
In practice, organizations often apply criteria based on how and why the material was created or received. Material created or received in the conduct of organizational business, and that documents organizational activity, typically falls within the recordkeeping system, while material relating solely to an individual's private affairs typically does not. Because borderline cases arise, many organizations set out guidance in policy, provide examples, and establish a process for reviewing ambiguous items rather than relying on individual judgment alone. The appropriate boundary depends on organizational policy and, in some settings, on jurisdictional and sector-specific requirements.
How should personal papers be handled when they are mixed in with business records?
Commingling of personal papers with organizational records is a recurring practical challenge, particularly in shared drives, mailboxes, and collaboration tools. A common approach is to separate personal material from business records as early as practicable, so that records subject to retention and disposition controls can be managed appropriately and personal material can be dealt with according to policy. Where separation is not straightforward, organizations often rely on review at defined points, such as when an individual leaves or when a collection is transferred. Handling arrangements should be governed by organizational policy and may be affected by applicable jurisdictional obligations.
What happens to material claimed as personal papers when a legal hold applies?
A claim that material is personal papers does not by itself remove it from the reach of a legal hold. Whether specific material must be preserved generally depends on its relevance to the matter and on the applicable legal requirements, which vary by jurisdiction. If material contains business content relevant to a hold, it may need to be preserved even if it is stored among personal items or in a personal account. Because the interaction between personal papers and preservation obligations can be complex, organizations often address such items through their legal hold process rather than allowing a personal designation to determine the outcome.
What should happen to personal papers when an employee leaves the organization?
Departures are a common point at which personal papers and organizational records need to be distinguished. A typical approach is to review the departing individual's holdings so that organizational records are retained within the recordkeeping system and managed according to retention and disposition rules, while genuine personal papers can be returned, removed, or otherwise handled in line with policy. The specifics depend on organizational policy and may be shaped by applicable jurisdictional and sector requirements, so many organizations define a clear procedure and responsibility for this review rather than leaving it to the individual alone.

Common misconceptions

Anything an individual keeps at their desk or in their personal accounts counts as personal papers and is beyond the reach of records management or disclosure obligations.
Physical location or storage in a personal account does not, by itself, determine whether material is a personal paper or an organizational record. What often matters is whether the item was created or received in the course of official duties and whether it provides evidence of the organization's activities. Depending on jurisdiction and policy, work-related material held in personal locations may still be subject to recordkeeping, legal hold, or access requirements.
Personal papers are the same as transitory or working documents that can simply be discarded at will.
These are distinct concepts. Transitory information is short-lived material of limited value created in the course of work, whereas personal papers are private, non-official material. Whether either may be destroyed depends on its status and on organizational policy and applicable legal obligations; classifying something as personal does not automatically authorize its destruction, particularly where its status is contested or a legal hold may apply.
Labeling a document as personal removes it from any freedom of information, discovery, or accountability process.
The label an individual applies does not determine legal status. In many jurisdictions, whether material is subject to access requests or disclosure obligations turns on its content and the capacity in which it was created, not on how it is characterized by the holder. Genuinely private material may fall outside such obligations, but the assessment depends on the applicable regime and the specific facts.

Best practices

Establish and communicate a clear organizational policy that defines the boundary between personal papers and official records, using the capacity in which material is created or received as a primary criterion.
Encourage staff to keep genuinely personal material separate from work systems and accounts, reducing the likelihood of mixed holdings that complicate later assessment.
Assess ambiguous or mixed collections case by case against the criteria for what constitutes a record, rather than relying on storage location or self-applied labels to determine status.
Recognize that a personal designation does not by itself authorize destruction or exclude material from legal hold, disclosure, or access obligations, and check the applicable jurisdictional and sector requirements before acting.
Where personal papers may hold historical or research value, consider arrangements with an appropriate archive or repository and document any agreed conditions of deposit.
Seek advice from records, legal, or privacy specialists when the status of material is contested or where access, disclosure, or retention obligations may be engaged.