A recent clarification to the definition of sole possession records is that this term is intended to cover memory aids or reference tools. It does not refer to records that contain information provided directly by a student or his/her records that are used to make decisions about the student. As such, this is a very limited exception. For example, personal notes from a committee meeting recommending students for a particular program would not be considered sole possession records if they are used to make a decision about the students.
Remember that even though a record is not protected by FERPA, it does not mean that the record can be freely released. Employment, medical/mental health, and law enforcement records are protected by other laws. Medical and law enforcement records should be kept separately from a student's "education records."