Yes. That is right.
What you called a “non-kamma vinnana” is a namagotta. ALL our actions are recorded as namagotta, whether or not they may have kammic consequences.
– Those events with kammic consequences (i.e., kammic energy) are “dhammā“. In other words, namagotta with kammic energies are dhammā.
Now, dhammā can bring vipaka on their own, when conditions are right.
But if we need to recall anything (namagotta with or without kammic energy) we need to make an effort to recall them. The brain sends a “cittaja ray (kirana)” to the vinnana dhatu and it comes back (reflected) with that memory.
I hope you can get an idea. Ask questions if not clear. I think I wrote about this in one post, but I cannot remember which post.
P.S. The following analogy may help with how we recall namagoatta.
Suppose, there is a chair in a dark room. If we walk into the room, we would not see the chair. But if we direct a flashlight to it, the light will reflect off the chair and we will see it.
– In the same way, we need to send a “beam of light” to the vinnana dhatu (nama loka), and only then it will reflect back with the memory.
– Our nama loka is very different from the rupa loka. We can recall memories (in nama loka) from anywhere. More in the next post.