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Classified information

From Wikipedia, the free encyclopedia
Material that government claims requires confidentiality

A typical classified document. Page 13 of aU.S. National Security Agency report[1] on theUSSLiberty incident, partially declassified and released to the public in July 2004. The original overall classification of the page, "top secret", and the Special Intelligence code word "umbra", are shown at top and bottom. The classification of individual paragraphs and reference titles is shown in parentheses—there are six different levels on this page alone. Notations with leader lines at top and bottom cite statutory authority for not declassifying certain sections.

Classified information is confidential material that a government deems to besensitive information which must be protected from unauthorized disclosure that requires special handling and dissemination controls. Access is restricted bylaw or regulation to particular groups of individuals with both the necessarysecurity clearance and aneed to know.

A formalsecurity clearance is required to view or handle classified material. The clearance process requires a satisfactory background investigation. Documents and other information must be properly marked "by the author" with one of several (hierarchical) levels of sensitivity—e.g. Confidential (C), Secret (S), and Top Secret (S). All classified documents require designation markings on the technical file which is usually located either on the cover sheet, header and footer of page. The choice of level is based on an impact assessment; governments have their own criteria, including how to determine the classification of an information asset and rules on how to protect information classified at each level. This process often includes security clearances for personnel handling the information. Mishandling of the material can incur criminal penalties.

Somecorporations and non-government organizations also assign levels of protection to their private information, either from a desire to protecttrade secrets, or because of laws and regulations governing various matters such aspersonal privacy, sealed legal proceedings and the timing of financial information releases.

With the passage of time much classified information can become less sensitive, and may be declassified and made public. Since the late twentieth century there has beenfreedom of information legislation in some countries, whereby the public is deemed to have the right to all information that is not considered to be damaging if released. Sometimes documents are released with information still considered confidential obscured (redacted), as in the adjacent example.

The question exists among some political science and legal experts whether the definition of classified ought to be information that would cause injury to the cause of justice, human rights, etc., rather than information that would cause injury to the national interest; to distinguish when classifying information is in the collective best interest of a just society, or merely the best interest of a society acting unjustly to protect its people, government, or administrative officials from legitimate recourses consistent with a fair and justsocial contract.

Government classification

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The purpose of classification is to protect information. Higher classifications protect information that might endangernational security. Classification formalises what constitutes a "state secret" and accords different levels of protection based on the expected damage the information might cause in the wrong hands.

However, classified information is frequently "leaked" to reporters by officials for political purposes. Several U.S. presidents have leaked sensitive information to influence public opinion.[2][3]

Former government intelligence officials are usually able to retain their security clearance, but it is a privilege not a right, with the President being the grantor.[4]

Typical classification levels

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Although the classification systems vary from country to country, most have levels corresponding to the following British definitions (from the highest level to lowest).

Top Secret (TS)

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"Top Secret" redirects here. For other uses, seeTop Secret (disambiguation).
KGB's "List oftraitors to the Motherland, agents of foreign intelligence, and other wanted state criminals" (1979) seen in theMuseum of Genocide Victims,Vilnius: originally markedtop secret

Top Secret is the highest level of classified information.[5] Information is further compartmented so that specific access using a code word aftertop secret is a legal way to hide collective and important information.[6] Such material would cause "exceptionally grave damage" tonational security if made publicly available.[7] Prior to 1942, the United Kingdom and other members of the British Empire usedMost Secret, but this was later changed to match the United States' category name ofTop Secret in order to simplify Allied interoperability. The unauthorized disclosure of Top Secret (TS) information is expected to cause harm and be of grave threat to national security.

The Washington Post reported in an investigation entitled "Top Secret America" that, as of 2010, "An estimated 854,000 people ... hold top-secret security clearances" in the United States.[8]

Secret

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It is desired that no document be released which refers toexperiments with humans and might have adverse effect on public opinion or result in legal suits. Documents covering such work field should be classified "secret".

April 17, 1947 Atomic Energy Commission memo from Colonel O.G. Haywood, Jr. to Dr. Fidler at the Oak Ridge Laboratory in Tennessee.[9] As of 2010[update],Executive Order 13526 bans classification of documents simply to "conceal violations of law, inefficiency, or administrative error" or "prevent embarrassment to a person, organization, or agency".[10]

Secret material would cause "serious damage" to national security if it were publicly available.[11]

In the United States, operational "Secret" information can be marked with an additional "LimDis", to limit distribution.

Confidential

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Confidential material would cause "damage" or be prejudicial to national security if publicly available.[12]

Restricted

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Restricted material would cause "undesirable effects" if publicly available. Some countries do not have such a classification in public sectors, such as commercial industries. Such a level is also known as "Private Information".

Official

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Official (equivalent to U.S. DOD classificationControlled Unclassified Information or CUI) material forms the generality of government business, public service delivery and commercial activity. This includes a diverse range of information, of varying sensitivities, and with differing consequences resulting from compromise or loss. Official information must be secured against athreat model that is broadly similar to that faced by a large private company.

The Official Sensitive classification replaced the Restricted classification in April 2014 in the UK; Official indicates the previously used Unclassified marking.[13]

Unclassified

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"Unclassified" redirects here. For the albums, seeUnclassified (Robert Randolph and the Family Band album),Unclassified (Adult Swim album), andUnclassified (Derrick Hoh album).

Unclassified is technically not a classification level. Though this is a feature of some classification schemes, used for government documents that do not merit a particular classification or which have been declassified. This is because the information is low-impact, and therefore does not require any special protection, such as vetting of personnel.

A plethora of pseudo-classifications exist under this category.[citation needed]

Clearance

[edit]

Clearance is a general classification, that comprises a variety of rules controlling the level of permission required to view some classified information, and how it must be stored, transmitted, and destroyed. Additionally, access is restricted on a "need to know" basis. Simply possessing a clearance does not automatically authorize the individual to view all material classified at that level or below that level. The individual must present a legitimate "need to know" in addition to the proper level of clearance.

NOFORN (NF)

The classification markings NOFORN (NF) is information may not be disseminated to any foreign government, foreign national, foreigners, international organizations or any individuals that are not citizens of the United States of America.

FEDERAL EMPLOYEES ONLY (FED ONLY)

The document designation classification Federal Employees Only (FED ONLY) is a limited dissemination control established by the Controlled Unclassified Information (CUI) executive. FED ONLY dissemination controls are authorized only to U.S. Government official employees,executive branch agencies, orUnited States armed forces of the U.S.Active Guard Reserve.

Federal Employees and Contractors Only (FEDCON)

Federal Employees and Contractors Only (FEDCON) is a limited dissemination control for authorized individuals or employees who enter a contract with the United States to perform a specific job.

Sensitive But Unclassified (SBU)

The document designation marking indicator for Sensitive But Unclassified (SBU) is information that requires special handling and limited dissemination controls that falls under category of the CUI Policy.

Controlled Unclassified Information (CUI)

Controlled Unclassified Information (CUI) is information that falls within alaw, regulation, and government-wide policy that require safeguarding to be protected from unauthorized disclosure. No individual may have access to CUI information unless he or she has been granted an authorization.

Weapons of Mass Destruction (WMD)

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In addition to the general risk-based classification levels, additionalcompartmented constraints on access exist, such as (in the U.S.) Special Intelligence (SI), which protects intelligence sources and methods, No Foreign dissemination (NoForn), which restricts dissemination to U.S. nationals, and Originator Controlled dissemination (OrCon), which ensures that the originator can track possessors of the information. Information in these compartments is usually marked with specific keywords in addition to the classification level.

Government information aboutnuclear weapons often has an additional marking to show it contains such information (CNWDI).

Declassification

For originally classified documents, the date of the original classification is scheduled for an automatic declassification of 10 years or 25 years, from the date of original classification. "50X1-HUM" is information that reveals the identity of aconfidential human source or a human intelligence source which is exempt from scheduled automatic declassification.[14] "50X2-WMD" is classified information exempt from automatic declassification at 10 years and 25 years that reveal information that reveals key elements and design ofweapons of mass destruction assembly, production and deployment.

International

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When a government agency or group shares information between an agency or group of other country's government they will generally employ a special classification scheme that both parties have previously agreed to honour.

For example, the marking Atomal, is applied to U.S. Restricted Data or Formerly Restricted Data and United Kingdom Atomic information that has been released to NATO. Atomal information is marked COSMIC Top Secret Atomal (CTSA), NATO Secret Atomal (NSAT), or NATO Confidential Atomal (NCA). BALK and BOHEMIA are also used.

NATO classifications

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"Cosmic Top Secret" redirects here. For the video game, seeCosmic Top Secret (video game).

For example, sensitive information shared amongstNATO allies has four levels of security classification; from most to least classified:[15][16]

  1. COSMIC Top Secret (CTS)
  2. NATO Secret (NS)
  3. NATO Confidential (NC)
  4. NATO Restricted (NR)

  • ATOMAL: This designation is added to the NATO security classification when applicable. For example, COSMIC TOP SECRET ATOMAL (CTS-A). ATOMAL information applies to U.S. RESTRICTED DATA or FORMERLY RESTRICTED DATA or United Kingdom Atomic Information released to NATO.[17]

A special case exists with regard to NATO Unclassified (NU) information. Documents with this marking are NATO property (copyright) and must not be made public without NATO permission.

COSMIC is an acronym for "Control of Secret Material in an International Command".[18]

International organizations

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  • TheEuropean Union has four levels: EU Top Secret, EU Secret, EU Confidential, EU Restricted.[19] (Note that usually the French terms are used.[20])
    • Très Secret UE/EU Top Secret: information and material the unauthorised disclosure of which could cause exceptionally grave prejudice to the essential interests of the European Union or of one or more of the Member States;
    • Secret UE/EU Secret: information and material the unauthorised disclosure of which could seriously harm the essential interests of the European Union or of one or more of the Member States;
    • Confidentiel UE/EU Confidential: information and material the unauthorised disclosure of which could harm the essential interests of the European Union or of one or more of the Member States;
    • Restreint UE/EU Restricted: information and material the unauthorised disclosure of which could be disadvantageous to the interests of the European Union or of one or more of the Member States.
  • Organisation for Joint Armament Cooperation, a European defence organisation, has three levels of classification: OCCAR Secret, OCCAR Confidential, and OCCAR Restricted.[21]
  • TheUnited Nations has two classification levels: Confidential and Strictly Confidential.[22]

By country

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Facsimile of the cover page from anEast German operation manual for the M-125Fialkacipher machine. The underlined classification markings can be translated as "Cryptologic material! Secret restricted material"de:Verschlusssache.

Most countries employ some sort of classification system for certain government information. For example, inCanada, information that the U.S. would classify SBU (Sensitive but Unclassified) is called "protected" and further subcategorised into levels A, B, and C.

Australia

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On 19 July 2011, the National Security (NS) classification marking scheme and the Non-National Security (NNS) classification marking scheme inAustralia was unified into one structure.

As of 2018, the policy detailing howAustralian government entities handle classified information is defined in the Protective Security Policy Framework (PSPF). The PSPF is published by theAttorney-General's Department and covers security governance,information security, personal security, andphysical security. A security classification can be applied to the information itself or an asset that holds information e.g., aUSB orlaptop.[23]

The Australian Government uses four security classifications: OFFICIAL: Sensitive, PROTECTED, SECRET and TOP SECRET. The relevant security classification is based on the likely damage resulting from compromise of the information's confidentiality.

All other information from business operations and services requires a routine level of protection and is treated as OFFICIAL. Information that does not form part of official duty is treated as UNOFFICIAL.

OFFICIAL and UNOFFICIAL are not security classifications and are not mandatory markings.

Caveats are a warning that the information has special protections in addition to those indicated by the security classification of PROTECTED or higher (or in the case of the NATIONAL CABINET caveat, OFFICIAL: Sensitive or higher). Australia has four caveats:

  • Codewords (sensitive compartmented information)
  • Foreign government markings
  • Special handling instructions
  • Releasability caveats

Codewords are primarily used within the national security community. Each codeword identifies a special need-to-knowcompartment.

Foreign government markings are applied to information created by Australian agencies from foreign source information. Foreign government marking caveats require protection at least equivalent to that required by the foreign government providing the source information.

Special handling instructions are used to indicate particular precautions for information handling. They include:

  • EXCLUSIVE FOR (named person)
  • CABINET
  • NATIONAL CABINET

A releasability caveat restricts information based oncitizenship. The three in use are:

  • Australian Eyes Only (AUSTEO)
  • Australian Government Access Only (AGAO)
  • Releasable To (REL).[23]

Additionally, the PSPF outlines Information Management Markers (IMM) as a way for entities to identify information that is subject to non-security related restrictions on access and use. These are:

  • Legal privilege
  • Legislative secret
  • Personal privacy[23]

Brazil

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There are three levels ofdocument classification under Brazilian Law No. 12.527, theAccess to Information Act:[24]ultrassecreto (top secret),secreto (secret) andreservado (restricted).

A top secret (ultrassecreto) government-issued document may be classified for a period of 25 years, which may be extended up to another 25 years.[25] Thus, no document remains classified for more than 50 years. This is mandated by the 2011 Information Access Law (Lei de Acesso à Informação), a change from the previous rule, under which documents could have their classification time length renewed indefinitely, effectively shuttering state secrets from the public. The 2011 law applies retroactively to existing documents.

Canada

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Further information:Security clearance § Canada

Background and hierarchy

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The government of Canada employs two main types of sensitive information designation: Classified and Protected. The access and protection of both types of information is governed by theSecurity of Information Act, effective 24 December 2001, replacing theOfficial Secrets Act 1981.[26] To access the information, a person must have the appropriate security clearance and the need to know.

In addition, the caveat "Canadian Eyes Only" is used to restrict access to Classified or Protected information only to Canadian citizens with the appropriate security clearance and need to know.[27]

Special operational information

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SOI is not a classification of dataper se. It is defined under theSecurity of Information Act, and unauthorised release of such information constitutes a higher breach of trust, with a penalty of up to life imprisonment if the information is shared with a foreign entity or terrorist group.

SOIs include:

  • military operations in respect of a potential, imminent or present armed conflict
  • the identity of confidential source of information, intelligence or assistance to the Government of Canada
  • tools used for information gathering or intelligence
  • the object of a covert investigation, or a covert collection of information or intelligence
  • the identity of any person who is under covert surveillance
  • encryption and cryptographic systems
  • information or intelligence to, or received from, a foreign entity or terrorist group

In February 2025, the Department of National Defence announced a new category of Persons Permanently Bound to Security (PPBS). The protection would apply to some units, sections or elements, and select positions (both current and former), with access to sensitive Special Operational Information (SOI) for national defense and intelligence work. If a unit or organization routinely handles SOI, all members of that unit will be automatically bound to secrecy. If an individual has direct access to SOI, deemed to be integral to national security, that person may be recommended for PPBS designation. The designation is for life, punishable by imprisonment.[28]

Classified information

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Classified information can be designatedTop Secret,Secret orConfidential. These classifications are only used on matters of national interest.

  • Top Secret: applies when compromise might reasonably cause exceptionally grave injury to the national interest. The possible impact must be great, immediate and irreparable.
  • Secret: applies when compromise might reasonably cause serious injury to the national interest.
  • Confidential: disclosure might reasonably cause injury to the national interest.

Protected information

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Protected information is not classified. It pertains to any sensitive information that does not relate to national security and cannot be disclosed under the access and privacy legislation because of the potential injury to particular public or private interests.[29][30]

  • Protected C (Extremely Sensitive protected information): designates extremely sensitive information, which if compromised, could reasonably be expected to cause extremely grave injury outside the national interest. Examples include bankruptcy, identities of informants in criminal investigations, etc.
  • Protected B (Particularly Sensitive protected information): designates information that could cause severe injury or damage to the people or group involved if it was released. Examples include medical records, annual personnel performance reviews, income tax returns, etc.
  • Protected A (Low-Sensitive protected information): designates low sensitivity information that should not be disclosed to the public without authorization and could reasonably be expected to cause injury or embarrassment outside the national interest. Example of Protected A information include employee identification number, pay deposit banking information, etc.

Federal Cabinet (King's Privy Council for Canada) papers are either protected (e.g., overhead slides prepared to make presentations to Cabinet) or classified (e.g., draft legislation, certain memos).[31]

People's Republic of China

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A building inWuhan housing provincial offices for dealing with foreign countries, etc. The red slogan says, "Protection of national secrets is a duty of every citizen".

TheCriminal Law of thePeople's Republic of China (which is not operative in the special administrative regions ofHong Kong andMacau) makes it a crime to release a state secret. Regulation and enforcement is carried out by theNational Administration for the Protection of State Secrets.

Under the 1989 "Law on Guarding State Secrets",[32] state secrets are defined as those that concern:

  1. Major policy decisions on state affairs
  2. The building of national defence and in the activities of the armed forces
  3. Diplomatic activities and in activities related to foreign countries and those to be maintained as commitments to foreign countries
  4. National economic and social development
  5. Science and technology
  6. Activities for preserving state security and the investigation of criminal offences
  7. Any other matters classified as "state secrets" by the national State Secrets Bureau[33]

Secrets can be classified into three categories:

  • Top Secret (Chinese:绝密;pinyin:Juémì), defined as "vital state secrets whose disclosure would cause extremely serious harm to state security and national interests"
  • Highly Secret (Chinese:机密;pinyin:Jīmì), defined as "important state secrets whose disclosure would cause serious harm to state security and national interests"
  • Secret (Chinese:秘密;pinyin:Mìmì), defined as "ordinary state secrets whose disclosure would cause harm to state security and national interests"[33]

France

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In France, classified information is defined by article 413-9 of the Penal Code.[34] The three levels of military classification are

  • Très Secret Défense (Very Secret Defence): Information deemed extremely harmful to national defence,[citation needed] and relative to governmental priorities in national defence. No service or organisation can elaborate, process, stock, transfer, display or destroy information or protected supports classified at this level without authorization from the Prime Minister or the national secretary for National Defence. Partial or exhaustive reproduction is strictly forbidden.
  • Secret Défense (Secret Defence): Information deemed very harmful to national defence. Such information cannot be reproduced without authorisation from the emitting authority, except in exceptional emergencies.
  • Confidentiel Défense (Confidential Defence) - in effect until 2021[35]: Information deemed potentially harmful to national defence, or that could lead to uncovering some information classified at a higher level of security.

Less sensitive information is "protected". The levels are

  • Confidentiel personnels Officiers ("Confidential officers")
  • Confidentiel personnels Sous-Officiers ("Confidential non-commissioned officers")
  • Diffusion restreinte ("restricted information")
  • Diffusion restreinte administrateur ("administrative restricted information")
  • Non Protégé (unprotected)

A further caveat,spécial France (reserved France) restricts the document to French citizens (in its entirety or by extracts). This is not a classification level.

Declassification of documents can be done by theCommission consultative du secret de la défense nationale (CCSDN), an independent authority. Transfer of classified information is done with double envelopes, the outer layer being plastified and numbered, and the inner in strong paper. Reception of the document involves examination of the physical integrity of the container and registration of the document. In foreign countries, the document must be transferred through specialised military mail ordiplomatic bag. Transport is done by an authorised conveyor or habilitated person for mail under 20 kg. The letter must bear a seal mentioning "Par Valise Accompagnee-Sacoche". Once a year, ministers have an inventory of classified information and supports by competent authorities.

Once their usage period is expired, documents are transferred to archives, where they are either destroyed (by incineration, crushing, or overvoltage), or stored.

In case of unauthorized release of classified information, competent authorities are theMinistry of Interior, the 'Haut fonctionnaire de défense et de sécurité ("high civil servant for defence and security") of the relevant ministry, and the General secretary for National Defence. Violation of such secrets is an offence punishable with seven years of imprisonment and a 100,000-euro fine; if the offence is committed by imprudence or negligence, the penalties are three years of imprisonment and a 45,000-euro fine.

Hong Kong

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TheSecurity Bureau is responsible for developing policies in regards to the protection and handling of confidential government information. In general, the system used in Hong Kong is very similar to the UK system, developed from thecolonial era of Hong Kong.

Four classifications exists in Hong Kong, from highest to lowest in sensitivity:[36]

  • Top Secret (絕對機密)
  • Secret (高度機密)
  • Confidential (機密)
    • Temporary Confidential (臨時保密)
  • Restricted (限閱文件/內部文件)
    • Restricted (staff) (限閱文件(人事))
    • Restricted (tender) (限閱文件 (投標))
    • Restricted (administration) (限閱文件 (行政))

Restricted documents are not classifiedper se, but only those who have a need to know will have access to such information, in accordance with thePersonal Data (Privacy) Ordinance.[37]

New Zealand

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New Zealand uses the Restricted classification, which is lower than Confidential. People may be given access to Restricted information on the strength of an authorisation by their Head of department, without being subjected to the backgroundvetting associated with Confidential, Secret and Top Secret clearances. New Zealand's security classifications and the national-harm requirements associated with their use are roughly similar to those of the United States.

In addition to national security classifications there are two additional security classifications, In Confidence and Sensitive, which are used to protect information of a policy and privacy nature. There are also a number of information markings used within ministries and departments of the government, to indicate, for example, that information should not be released outside the originating ministry.

Because of strict privacy requirements around personal information, personnel files are controlled in all parts of the public and private sectors. Information relating to the security vetting of an individual is usually classified at the In Confidence level.

Romania

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InRomania, classified information is referred to as "state secrets" (secrete de stat) and is defined by the Penal Code as "documents and data that manifestly appear to have this status or have been declared or qualified as such by decision of Government".[38] There are three levels of classification: "Secret" (Secret/S), "Top Secret" (Strict Secret/SS), and "Top Secret of Particular Importance" (Strict secret de interes deosebit/SSID).[39] The levels are set by theRomanian Intelligence Service and must be aligned with NATO regulations—in case of conflicting regulations, the latter are applied with priority. Dissemination of classified information to foreign agents or powers is punishable by up to life imprisonment, if such dissemination threatens Romania's national security.[40]

KGB regulation seen in Museum of Genocide Victims Vilnius

Russia

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Main article:Classified information in Russia

In theRussian Federation, a state secret (Государственная тайна) is information protected by the state on its military, foreign policy, economic, intelligence, counterintelligence, operational and investigative and other activities, dissemination of which could harm state security.

Sweden

[edit]
Some Swedish examples of markings attached to documents that are to be kept secret. A single frame around the text indicatesHemlig, which can be equal to either Secret, Confidential or Restricted. Double frames meansKvalificerat hemlig; that is, Top Secret.

The Swedish classification has been updated due to increased NATO/PfP cooperation. All classified defence documents will now have both a Swedish classification (Kvalificerat hemlig,Hemlig,Konfidentiell orBegränsat Hemlig), and an English classification (Top Secret, Secret, Confidential, or Restricted).[citation needed] The termskyddad identitet, "protected identity", is used in the case of protection of a threatened person, basically implying "secret identity", accessible only to certain members of the police force and explicitly authorised officials.

Switzerland

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At the federal level, classified information in Switzerland is assigned one of three levels, which are from lowest to highest: Internal, Confidential, Secret.[41] Respectively, these are, in German,Intern,Vertraulich,Geheim; in French,Interne,Confidentiel,Secret; in Italian,Ad Uso Interno,Confidenziale,Segreto. As in other countries, the choice of classification depends on the potential impact that the unauthorised release of the classified document would have on Switzerland, the federal authorities or the authorities of a foreign government.

According to the Ordinance on the Protection of Federal Information, information is classified as Internal if its "disclosure to unauthorised persons may be disadvantageous to national interests."[41] Information classified as Confidential could, if disclosed, compromise "the free formation of opinions and decision-making ofthe Federal Assembly orthe Federal Council," jeopardise national monetary/economic policy, put the population at risk or adversely affect the operations of theSwiss Armed Forces. Finally, the unauthorised release of Secret information could seriously compromise the ability of either the Federal Assembly or the Federal Council to function or impede the ability of the Federal Government or the Armed Forces to act.

Turkey

[edit]

According to the related regulations inTurkey, there are four levels of document classification:[42]çok gizli (top secret),gizli (secret),özel (confidential) andhizmete özel (restricted). The fifth istasnif dışı, which means unclassified.

United Kingdom

[edit]
Security classifications in the UK
Main article:Classified information in the United Kingdom

Until 2013, theUnited Kingdom used five levels of classification—from lowest to highest, they were: Protect, Restricted, Confidential, Secret and Top Secret (formerly Most Secret). TheCabinet Office provides guidance on how to protect information, including thesecurity clearances required for personnel. Staff may be required to sign to confirm their understanding and acceptance of theOfficial Secrets Acts 1911 to 1989, although the Act applies regardless of signature. Protect is not in itself a security protective marking level (such as Restricted or greater), but is used to indicate information which should not be disclosed because, for instance, the document contains tax, national insurance, or other personal information.

Government documents without a classification may be marked as Unclassified or Not Protectively Marked.[43]

This system was replaced by theGovernment Security Classifications Policy, which has a simpler model: Top Secret, Secret, and Official from April 2014.[13] Official Sensitive is a security marking which may be followed by one of three authorised descriptors: Commercial, LocSen (location sensitive) or Personal. Secret and Top Secret may include a caveat such as UK Eyes Only.

Also useful is that scientific discoveries may be classified via theD-Notice system if they are deemed to have applications relevant to national security. These may later emerge when technology improves so for example the specialised processors and routing engines used in graphics cards are loosely based on top secret military chips designed for code breaking and image processing.They may or may not have safeguards built in to generate errors when specific tasks are attempted and this is invariably independent of the card's operating system.[citation needed]

United States

[edit]
Main article:Classified information in the United States

The U.S. classification system is currently established underExecutive Order 13526 and has three levels of classification—Confidential, Secret, and Top Secret. The U.S. had a Restricted level duringWorld War II but no longer does. U.S. regulations state that information received from other countries at the Restricted level should be handled as Confidential. A variety of markings are used for material that is not classified, but whose distribution is limited administratively or by other laws, e.g.,For Official Use Only (FOUO), orsensitive but unclassified (SBU). The Atomic Energy Act of 1954 provides for the protection of information related to the design of nuclear weapons. The term "Restricted Data" is used to denote certain nuclear technology. Information about the storage, use or handling of nuclear material or weapons is marked "Formerly Restricted Data". These designations are used in addition to level markings (Confidential, Secret and Top Secret). Information protected by the Atomic Energy Act is protected by law and information classified under the Executive Order is protected by Executive privilege.

The U.S. government insists it is "not appropriate" for a court to question whether any document is legally classified.[44] In the1973 trial of Daniel Ellsberg for releasing the Pentagon Papers, the judge did not allow any testimony from Ellsberg, claiming it was "irrelevant", because the assigned classification could not be challenged. The charges against Ellsberg were ultimately dismissed after it was revealed that the government had broken the law in secretly breaking into the office of Ellsberg's psychiatrist and in tapping his telephone without a warrant. Ellsberg insists that the legal situation in the U.S. in 2014 is worse than it was in 1973, andEdward Snowden could not get a fair trial.[45] TheState Secrets Protection Act of 2008 might have given judges the authority to review such questionsin camera, but the bill was not passed.[44]

When a government agency acquires classified information through covert means, or designates a program as classified, the agency asserts "ownership" of that information and considers any public availability of it to be a violation of their ownership—even if the same information was acquired independently through "parallel reporting" by the press or others. For example, although theCIA drone program has been widely discussed in public since the early 2000s, and reporters personally observed and reported on drone missile strikes, the CIA still considers the very existence of the program to be classified in its entirety, and any public discussion of it technically constitutes exposure of classified information. "Parallel reporting" was an issue in determining what constitutes "classified" information during theHillary Clinton email controversy whenAssistant Secretary of State for Legislative AffairsJulia Frifield noted, "When policy officials obtain information from open sources, 'think tanks,' experts, foreign government officials, or others, the fact that some of the information may also have been available through intelligence channels does not mean that the information is necessarily classified."[46][47][48]

Table of equivalent classification markings in various countries

[edit]
(State)Top SecretSecretConfidentialRestricted
AlbaniaTeper SekretSekretKonfidencialI Kufizuar
ArgentinaEstrictamente Secreto y Confidencial

Strictly Secret and Confidential

Secreto

Secret

Confidencial

Confidential

Reservado

Reserved

ArmeniaՀատուկ կարևորության
Of Special Importance
Հույժ գաղտնի
Top Secret
Գաղտնի
Secret[49]
Ծառայողական օգտագործման համար
For Service Use
AustraliaTop SecretSecret[23]Retired 2018. No equivalent level for historical classification

US, French, EU, Japan "Confidential" marking to be handled as SECRET.[50]

Protected
AustriaStreng GeheimGeheimVertraulichEingeschränkt
BelgiumZeer Geheim /Très SecretGeheim /SecretVertrouwelijk /ConfidentielBeperkte Verspreiding /Diffusion restreinte
BoliviaSupersecreto
orMuy Secreto
SecretoConfidencialReservado
Bosnia and HerzegovinaVrlo tajnoTajnoPovjerljivoInterno
BrazilUltrassecretoSecretono equivalent (formerlyConfidencial)Reservado
BulgariaStrògo sèkretno
Строго секретно
Sèkretno
Секретно
Poveritèlno
Поверително
Za služebno polzvàne
За служебно ползване
CambodiaSam Ngat BamphotSam Ngat RoeungArt KambangHam Kom Psay
CanadaTop Secret/Très secretSecret/SecretConfidential/ConfidentielProtected A, B or C/Protégé A, B ou C
ChileSecretoSecretoReservadoReservado
ChinaJuémì (绝密)

Top Secret

Jīmì (机密)

Highly Secret

Mìmì (秘密)

Secret

Nèibù (内部)

Internal

ColombiaUltrasecretoSecretoConfidencialReserva del sumario
Costa RicaAlto SecretoSecretoConfidencial 
CroatiaVrlo tajnoTajnoPovjerljivoOgraničeno
Czech RepublicPřísně tajnéTajnéDůvěrnéVyhrazené
DenmarkYderst Hemmeligt (YHM)Hemmeligt (HEM)Fortroligt (FTR)Til Tjenestebrug (TTJ)

Foreign Service:Fortroligt
(thin black border)

EcuadorSecretisimoSecretoConfidencialReservado
EgyptSirriy lil-Ġāyah
سري للغاية
Sirriy Ǧiddan
سري جداً
Khāṣ
خاص
Maḥzūr
محظور
El SalvadorUltra SecretoSecretoConfidencialReservado
EstoniaTäiesti salajaneSalajaneKonfidentsiaalnePiiratud
Ethiopiaብርቱ ምስጢርምስጢርጥብቅክልክል
European Union (EU)Tres Secret UE / EU Top SecretSecret UE / EU SecretConfidentiel UE / EU ConfidentialRestreint UE / EU Restricted
European Union (Western) (WEU)Focal top secretWEU SecretWEU ConfidentialWEU Restricted
EuratomEURA Top SecretEURA SecretEURA ConfidentialEURA Restricted
Finland[a]Erittäin salainen (TL I)Salainen (TL II)Luottamuksellinen (TL III)Käyttö rajoitettu (TL IV)
FranceTrès secretSecretSecretDiffusion restreinte
GermanyStreng Geheim

Top Secret

Geheim

Secret

VS-Vertraulich

Confidential

VS-Nur Für Den Dienstgebrauch

For Official Use Only

GreeceΆκρως Απόρρητον

Top Secret

Απόρρητον

Secret

Εμπιστευτικόν

Confidential

Περιορισμένης
Χρήσης

Limited Use

GuatemalaAlto SecretoSecretoConfidencialReservado
HaitiTop SecretSecretConfidentialReserve
HondurasSuper SecretoSecretoConfidencialReservado
Hong KongTop Secret,高度機密Secret,機密Confidential,保密Restricted,內部文件/限閱文件
HungarySzigorúan Titkos

Top Secret

Titkos

Secret

Bizalmas

Confidential

Korlátozott Terjesztésű

Restricted Distribution

India (Hindi)परम गुप्त (Param Gupt)गुप्त (Gupt)गोपनीय (Gopniya)प्रतिबंधित/सीमित (Pratibandhit/seemit)
India (English)Top SecretSecretConfidentialRestricted
IndonesiaSangat RahasiaRahasiaRahasia DinasTerbatas
IranBekoli-Serriبکلی سریSerriسریKheili-Mahramanehخیلی محرمانهMahramanehمحرمانه
IraqSirriy lil-Ġāyah
سري للغاية
Sirriy
سري
Khāṣ
خاص
Maḥdūd
محدود
IcelandAlgert Leyndarmál

Absolute Secret

Leyndarmál

Secret

Trúnaðarmál

Confidential

Þjónustuskjal

Service Document

Ireland (Irish language)An-sicréideachSicréideachRúndaSrianta
IsraelSodi Beyoter
סודי ביותר
Sodi
סודי
Shamur
שמור
Mugbal
מוגבל
ItalySegretissimoSegretoRiservatissimoRiservato
JapanKimitsu (機密)Gokuhi (極秘)Hi ()Toriatsukaichuui (取り扱い注意)
JordanMaktūm Ǧiddan
مكتوم جداً
Maktūm
مكتوم
Sirriy
سري
Maḥdūd
محدود
South Korea1(Il)-geup Bimil,1급 비밀, 一級秘密

Class 1 Secret

2(I)-geup Bimil,2급 비밀, 二級秘密

Class 2 Secret

3(Sam)-geup Bimil,3급 비밀, 三級秘密

Class 3 Secret

Daeoebi,대외비, 對外秘

Confidential

LaosLup Sood GnodKuam LupKuam LapChum Kut Kon Arn
LatviaSevišķi slepeniSlepeniKonfidenciāliDienesta vajadzībām
LebanonTres SecretSecretConfidentiel 
LithuaniaVisiškai SlaptaiSlaptaiKonfidencialiaiRiboto Naudojimo
MalaysiaRahsia BesarRahsiaSulitTerhad
MexicoUltra SecretoSecretoConfidencialRestringido
MontenegroStrogo TajnoTajnoPovjerljivoInterno
Netherlands[51]STG. Zeer GeheimSTG. GeheimSTG. ConfidentieelDepartementaal Vertrouwelijk
New ZealandTop SecretSecretConfidentialRestricted
NicaraguaAlto SecretoSecretoConfidencialReservado
NorwaySTRENGT HEMMELIGHEMMELIGKONFIDENSIELTBEGRENSET
Pakistan (Urdu)Intahai Khufia
انتہائی خفیہ
Khufia
خفیہ
Sigh-e-Raz
صیخہ راز
Barai Mahdud Taqsim
محدود تقسیم
Pakistan (English)Top SecretSecretConfidentialRestricted
ParaguaySecretoSecretoConfidencialReservado
PeruEstrictamente SecretoSecretoConfidencialReservado
Philippines (English)

Philippines (Tagalog)

Top Secret

Matinding Lihim

Secret

Mahigpit na Lihim

Confidential

Lihim

Restricted

Ipinagbabawal

PolandŚciśle tajneTajnePoufneZastrzeżone
PortugalMuito SecretoSecretoConfidencialReservado
RomaniaStrict Secret de Importanță Deosebită

Strict Secret of Special Importance

Strict SecretSecretSecret de serviciu

Secret for Service Use

RussiaОсобой важности
(вариант: Совершенно Секретно (Sovershenno Sekretno))

Of Special Importance (variant: Completely Secret)

Совершенно секретно
(вариант: Секретно (Sekretno))

Completely Secret (variant: Secret)

Секретно
(вариант: Не подлежит оглашению
(Конфиденциально) (Ne podlezhit oglasheniyu (Konfidentsial'no))

Secret (variant: Not To Be Disclosed (Confidential))

Для Служебного Пользования (ДСП)
(Dlya Sluzhebnogo Pol'zovaniya)

For Official Use

Saudi ArabiaSaudi Top SecretSaudi Very SecretSaudi SecretSaudi Restricted
SerbiaCyrillic:Државна тајна
Latin:Državna tajna

State Secret

Cyrillic:Строго поверљиво
Latin:Strogo poverljivo

Strictly Confidential

Cyrillic:Поверљиво
Latin:Poverljivo

Confidential

Cyrillic:Интерно
Latin:Interno

Internal

SingaporeTop SecretSecretConfidentialRestricted
SomaliaSir Muhiim ahSir GooniyaXog QarsoonQarsoon
Slovak RepublicPrísne tajnéTajnéDôvernéVyhradené
SloveniaStrogo tajnoTajnoZaupnoInterno
SpainSecretoReservadoConfidencialDifusión Limitada
Sri Lankaඅති රහස්‍යරහස්‍යරහසිගතසීමාන්විත
SwedenKvalificerat hemlig (KH);Hemlig/Top Secret (H/TS)Hemlig (H);Hemlig/Secret (H/S)Konfidentiell;Hemlig/Confidential (H/C)Begränsat hemlig;Hemlig/Restricted (H/R)
SwitzerlandGeheim /SecretVertraulich /ConfidentielIntern /Interne
Taiwan (Republic of China)[52]Top Secret (絕對機密)Secret (極機密)Confidential (機密)no direct equivalent
Tanzania (Swahili)Siri KuuSiriStiriImezuiliwa
ThailandLap thi sut (ลับที่สุด)

Most Secret

Lap mak (ลับมาก)

Very Secret

Lap (ลับ)

Secret

Pok pit (ปกปิด)

Restricted

TurkeyÇok Gizli

Top Secret

Gizli

Secret

Özel

Confidential

Hizmete Özel

Restricted

South Africa (English)Top SecretSecretConfidentialRestricted
South Africa (Afrikaans)Uiters GeheimGeheimVertroulikBeperk
UkraineЦілком таємноТаємноКонфіденційноДля службового користування
United KingdomTop Secret (until 1942: Most Secret)Secret(formerly Confidential) abolished in 2014[53]Official-Sensitive (formerly Restricted)
United StatesTop SecretSecretConfidentialno direct equivalent
UruguayUltra SecretoSecretoConfidencialReservado
VietnamTuyệt mậtTối mậtTài liệu mậtHạn chế phổ biến
Table notes:
  1. ^Finland uses also uses the labelSalassa pidettävä, "to be kept secret" for information that is not classified but must not be revealed on some other basis than national security. (E.g. privacy, trade secrets etc.)

Table source:US Department of Defense (January 1995)."National Industrial Security Program - Operating Manual (DoD 5220.22-M)"(PDF). pp. B1 - B3 (PDF pages:121–123 ).Archived(PDF) from the original on 27 July 2019. Retrieved27 July 2019.

Corporate classification

[edit]

Privatecorporations often require writtenconfidentiality agreements and conductbackground checks on candidates for sensitive positions.[54] In the U.S., theEmployee Polygraph Protection Act prohibits private employers from requiring lie detector tests, but there are a few exceptions. Policies dictating methods for marking and safeguarding company-sensitive information (e.g. "IBM Confidential") are common and some companies have more than one level. Such information is protected undertrade secret laws. New product development teams are often sequestered and forbidden to share information about their efforts with un-cleared fellow employees, the originalApple Macintosh project being a famous example. Other activities, such asmergers andfinancial report preparation generally involve similar restrictions. However, corporate security generally lacks the elaborate hierarchical clearance and sensitivity structures and the harsh criminal sanctions that give government classification systems their particular tone.

Traffic Light Protocol

[edit]

TheTraffic Light Protocol[55][56] was developed by theGroup of Eight countries to enable the sharing of sensitive information between government agencies and corporations. This protocol has now been accepted as a model for trusted information exchange by over 30 other countries. The protocol provides for four "information sharing levels" for the handling of sensitive information.

See also

[edit]

References

[edit]
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  10. ^Section 1.7 (1) and (2).
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External links

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