It was therefore his position that disclosure of the Governor's schedule would constitute a clearly unwarranted invasion of personal privacy. Kentucky's courts have found such is the case for preliminary notes, recommendations and investigations utilized by an agency as a part of a particular action. Once the agency takes final action, those materials which were once preliminary in nature lose their exempt status. In OAG 78-626, this Office carefully considered the practical implications of compelling release of a public official's appointment schedule and concluded that that document could properly be withheld from public inspection. Not every paper in the office of a public agency is a public record subject to public inspection.
Many papers are simply work papers which are exempted because they are preliminary drafts and notes.
Such preliminary drafts and notes and preliminary memoranda are part of the tools which a public employee or officer uses in hammering out official action within the function of his office. They are expressly exempted by the Open Records Law and may be destroyed or kept at will and are not subject to public inspection. We believe that the Mayor's appointment calendar is of such a nature. Although the appointment calendar contains a record of activities and contacts by the Mayor, a record which his office will probably want to keep on file for sometime, we nevertheless believe that it is nothing more than a work paper, a preliminary draft, notebook or memorandum. OAG 78-626 at p. 2.