(b)(2) EXEMPTION 2 Internal Personnel
Rules and Practices. This exemption exempts from mandatory disclosure
records "related solely to the internal personnel rules and practices of
an agency." Courts have interpreted the exemption to encompass two distinct
categories of information:
(a) internal matters of a relatively trivial nature--sometimes
referred to as "low2" information; and
(b) more substantial internal matters, the disclosure
of which would risk circumvention of a legal requirement--sometimes referred
to as "high 2" information.