N.Y. Comp. Codes R. & Regs. tit. 21, § 505.2
(h) Record means any item, collection, or grouping of personal information about a data subject which is maintained and is retrievable by use of the name or other identifier of the data subject irrespective of the physical form or technology used to maintain such personal information. The term record shall not include personal information which is not used to make any determination about the data subject if it is:
(6) correspondence files.