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Classified information is confidential material that a government deems to be sensitive information which must be protected from unauthorized disclosure that requires special handling and dissemination controls. Access is restricted by
law Law is a set of rules that are created and are enforceable by social or governmental institutions to regulate behavior, with its precise definition a matter of longstanding debate. It has been variously described as a science and as the ar ...
or regulation to particular groups of individuals with the necessary
security clearance A security clearance is a status granted to individuals allowing them access to classified information (state or organizational secrets) or to restricted areas, after completion of a thorough background check. The term "security clearance" is ...
with a
need to know The term "need to know" (alternatively spelled need-to-know), when used by governments and other organizations (particularly those related to military or intelligence), describes the restriction of data which is considered very confidential and ...
. A formal
security clearance A security clearance is a status granted to individuals allowing them access to classified information (state or organizational secrets) or to restricted areas, after completion of a thorough background check. The term "security clearance" is ...
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. Some
corporation A corporation or body corporate is an individual or a group of people, such as an association or company, that has been authorized by the State (polity), state to act as a single entity (a legal entity recognized by private and public law as ...
s and non-government organizations also assign levels of protection to their private information, either from a desire to protect
trade secret A trade secret is a form of intellectual property (IP) comprising confidential information that is not generally known or readily ascertainable, derives economic value from its secrecy, and is protected by reasonable efforts to maintain its conf ...
s, or because of laws and regulations governing various matters such as
personal privacy Privacy (, ) is the ability of an individual or group to seclude themselves or information about themselves, and thereby express themselves selectively. The domain of privacy partially overlaps with security, which can include the concepts of ...
, 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 been
freedom of information legislation Freedom of information laws allow access by the general public to data held by national governments and, where applicable, by state and local governments. The emergence of freedom of information legislation was a response to increasing dissatis ...
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 just
social contract In moral and political philosophy, the social contract is an idea, theory, or model that usually, although not always, concerns the legitimacy of the authority of the state over the individual. Conceptualized in the Age of Enlightenment, it ...
.


Government classification

The purpose of classification is to protect information. Higher classifications protect information that might endanger
national security National security, or national defence (national defense in American English), is the security and Defence (military), defence of a sovereign state, including its Citizenship, citizens, economy, and institutions, which is regarded as a duty of ...
. 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. 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.


Typical classification levels

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)

''Top Secret'' is the highest level of classified information. Information is further compartmented so that specific access using a code word after ''top secret'' is a legal way to hide collective and important information. Such material would cause "exceptionally grave damage" to
national security National security, or national defence (national defense in American English), is the security and Defence (military), defence of a sovereign state, including its Citizenship, citizens, economy, and institutions, which is regarded as a duty of ...
if made publicly available. Prior to 1942, the United Kingdom and other members of the British Empire used ''Most Secret'', but this was later changed to match the United States' category name of ''Top 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.


Secret

''Secret'' material would cause "serious damage" to national security if it were publicly available. In the United States, operational "Secret" information can be marked with an additional "LimDis", to limit distribution.


Confidential

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


Restricted

''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

''Official'' (equivalent to U.S. DOD classification
Controlled Unclassified Information Controlled Unclassified Information (CUI) is a category of unclassified information within the U.S. Federal government. The CUI program was created by President Obama’s Executive Order 13556 to create a streamlined method for information sharing ...
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 a
threat model Threat modeling is a process by which potential threats, such as structural vulnerabilities or the absence of appropriate safeguards, can be identified and enumerated, and countermeasures prioritized. The purpose of threat modeling is to provide d ...
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.


Unclassified

''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.


Clearance

''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 The term "need to know" (alternatively spelled need-to-know), when used by governments and other organizations (particularly those related to military or intelligence), describes the restriction of data which is considered very confidential and ...
" 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 The executive branch is the part of government which executes or enforces the law. Function The scope of executive power varies greatly depending on the political context in which it emerges, and it can change over time in a given country. In ...
agencies, or
United States armed forces The United States Armed Forces are the Military, military forces of the United States. U.S. United States Code, federal law names six armed forces: the United States Army, Army, United States Marine Corps, Marine Corps, United States Navy, Na ...
of the U.S.
Active Guard Reserve The Active Guard and Reserve (AGR) is a United States Army and United States Air Force federal military program which places Army National Guard and Army Reserve soldiers and Air National Guard and Air Force Reserve airmen on federal active duty ...
. 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 a
law Law is a set of rules that are created and are enforceable by social or governmental institutions to regulate behavior, with its precise definition a matter of longstanding debate. It has been variously described as a science and as the ar ...
, 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)

In addition to the general risk-based classification levels, additional compartmented 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 about
nuclear weapon A nuclear weapon is an explosive device that derives its destructive force from nuclear reactions, either fission (fission or atomic bomb) or a combination of fission and fusion reactions (thermonuclear weapon), producing a nuclear exp ...
s often has an additional marking to show it contains such information (
CNWDI Critical Nuclear Weapon Design Information (CNWDI, often pronounced ''SIN-widdy'' or ''SIN-wuh-dee'') is a U.S. Department of Defense (DoD) category of Top Secret Restricted Data or Secret Restricted Data that reveals the theory of operation or ...
). 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 a
confidential human source An informant (also called an informer or, as a slang term, a "snitch", "rat", "canary", "stool pigeon", "stoolie", "tout" or "grass", among other terms) is a person who provides privileged information, or (usually damaging) information inten ...
or a human intelligence source which is exempt from scheduled automatic declassification. "50X2-WMD" is classified information exempt from automatic declassification at 10 years and 25 years that reveal information that reveals key elements and design of
weapons of mass destruction A weapon of mass destruction (WMD) is a Biological agent, biological, chemical weapon, chemical, Radiological weapon, radiological, nuclear weapon, nuclear, or any other weapon that can kill or significantly harm many people or cause great dam ...
assembly, production and deployment.


International

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

For example, sensitive information shared amongst
NATO The North Atlantic Treaty Organization (NATO ; , OTAN), also called the North Atlantic Alliance, is an intergovernmental organization, intergovernmental Transnationalism, transnational military alliance of 32 Member states of NATO, member s ...
allies has four levels of security classification; from most to least classified: # COSMIC Top Secret (CTS) # NATO Secret (NS) # NATO Confidential (NC) # 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. A special case exists with regard to NATO Unclassified (NU) information. Documents with this marking are NATO property (
copyright A copyright is a type of intellectual property that gives its owner the exclusive legal right to copy, distribute, adapt, display, and perform a creative work, usually for a limited time. The creative work may be in a literary, artistic, ...
) and must not be made public without NATO permission. COSMIC is an acronym for "Control of Secret Material in an International Command".


International organizations

* The
European Union The European Union (EU) is a supranational union, supranational political union, political and economic union of Member state of the European Union, member states that are Geography of the European Union, located primarily in Europe. The u ...
has four levels: EU Top Secret, EU Secret, EU Confidential, EU Restricted. (Note that usually the French terms are used.) **''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 The Organisation for Joint Armament Cooperation (French: ''Organisation Conjointe de Coopération en matière d'ARmement''; OCCAR) is a European intergovernmental organisation that facilitates and manages collaborative armament programmes throu ...
, a European defence organisation, has three levels of classification: OCCAR Secret, OCCAR Confidential, and OCCAR Restricted. * The
United Nations The United Nations (UN) is the Earth, global intergovernmental organization established by the signing of the Charter of the United Nations, UN Charter on 26 June 1945 with the stated purpose of maintaining international peace and internationa ...
has two classification levels: Confidential and Strictly Confidential.


By country

Most countries employ some sort of classification system for certain government information. For example, in
Canada Canada is a country in North America. Its Provinces and territories of Canada, ten provinces and three territories extend from the Atlantic Ocean to the Pacific Ocean and northward into the Arctic Ocean, making it the world's List of coun ...
, information that the U.S. would classify SBU (Sensitive but Unclassified) is called "protected" and further subcategorised into levels A, B, and C.


Australia

On 19 July 2011, the National Security (NS) classification marking scheme and the Non-National Security (NNS) classification marking scheme in
Australia Australia, officially the Commonwealth of Australia, is a country comprising mainland Australia, the mainland of the Australia (continent), Australian continent, the island of Tasmania and list of islands of Australia, numerous smaller isl ...
was unified into one structure. As of 2018, the policy detailing how
Australian government The Australian Government, also known as the Commonwealth Government or simply as the federal government, is the national executive government of Australia, a federal parliamentary constitutional monarchy. The executive consists of the pr ...
entities handle classified information is defined in the Protective Security Policy Framework (PSPF). The PSPF is published by the Attorney-General's Department and covers security governance,
information security Information security is the practice of protecting information by mitigating information risks. It is part of information risk management. It typically involves preventing or reducing the probability of unauthorized or inappropriate access to data ...
, personal security, and
physical security Physical security describes security measures that are designed to deny unauthorized access to facilities, equipment, and resources and to protect personnel and property from damage or harm (such as espionage, theft, or terrorist attacks). Physi ...
. A security classification can be applied to the information itself or an asset that holds information e.g., a
USB Universal Serial Bus (USB) is an industry standard, developed by USB Implementers Forum (USB-IF), for digital data transmission and power delivery between many types of electronics. It specifies the architecture, in particular the physical ...
or
laptop A laptop computer or notebook computer, also known as a laptop or notebook, is a small, portable personal computer (PC). Laptops typically have a Clamshell design, clamshell form factor (design), form factor with a flat-panel computer scree ...
. 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 Code word may refer to: * Code word (communication), an element of a standardized code or protocol * Code word (figure of speech), designed to convey a predetermined meaning to a receptive audience, while remaining inconspicuous to others ** Proce ...
(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-know compartment. 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 on
citizenship Citizenship is a membership and allegiance to a sovereign state. Though citizenship is often conflated with nationality in today's English-speaking world, international law does not usually use the term ''citizenship'' to refer to nationalit ...
. The three in use are: * Australian Eyes Only (AUSTEO) * Australian Government Access Only (AGAO) * Releasable To (REL). 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


Brazil

There are three levels of
document classification Document classification or document categorization is a problem in library science, information science and computer science. The task is to assign a document to one or more Class (philosophy), classes or Categorization, categories. This may be do ...
under Brazilian Law No. 12.527, the ''Access to Information Act'': (top secret), (secret) and (restricted). A top secret () government-issued document may be classified for a period of 25 years, which may be extended up to another 25 years. Thus, no document remains classified for more than 50 years. This is mandated by the 2011 Information Access Law (), 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


Background and hierarchy

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 the ''
Security of Information Act The ''Security of Information Act'' (, R.S.C. 1985, c. O-5), formerly known as the ''Official Secrets Act'', is an Act of the Parliament of Canada that addresses national security concerns, including threats of espionage by foreign powers and L ...
'', effective 24 December 2001, replacing the ''Official Secrets Act 1981''. 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.


Special operational information

SOI is not a classification of data ''per se''. It is defined under the ''Security 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.


Classified information

Classified information can be designated ''Top Secret'', ''Secret'' or ''Confidential''. 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

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. * 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 The King's Privy Council for Canada (), sometimes called His Majesty's Privy Council for Canada or simply the Privy Council (PC), is the full group of personal advisors to the monarch of Canada on State (polity), state and constitutional affair ...
) papers are either protected (e.g., overhead slides prepared to make presentations to Cabinet) or classified (e.g., draft legislation, certain memos).


People's Republic of China

The
Criminal Law Criminal law is the body of law that relates to crime. It proscribes conduct perceived as threatening, harmful, or otherwise endangering to the property, health, safety, and Well-being, welfare of people inclusive of one's self. Most criminal l ...
of the
People's Republic of China China, officially the People's Republic of China (PRC), is a country in East Asia. With population of China, a population exceeding 1.4 billion, it is the list of countries by population (United Nations), second-most populous country after ...
(which is not operative in the special administrative regions of
Hong Kong Hong Kong)., Legally Hong Kong, China in international treaties and organizations. is a special administrative region of China. With 7.5 million residents in a territory, Hong Kong is the fourth most densely populated region in the wor ...
and
Macau Macau or Macao is a special administrative regions of China, special administrative region of the People's Republic of China (PRC). With a population of about people and a land area of , it is the most List of countries and dependencies by p ...
) makes it a crime to release a state secret. Regulation and enforcement is carried out by the
National Administration for the Protection of State Secrets The National Administration of State Secret Protection is an institution of the State Council of the People's Republic of China that is responsible for the protection of classified information. It is under the Chinese Communist Party's Central ...
. Under the 1989 "Law on Guarding State Secrets", state secrets are defined as those that concern: # Major policy decisions on state affairs # The building of national defence and in the activities of the armed forces # Diplomatic activities and in activities related to foreign countries and those to be maintained as commitments to foreign countries # National economic and social development # Science and technology # Activities for preserving state security and the investigation of criminal offences # Any other matters classified as "state secrets" by the national State Secrets BureauTranslation per Human Rights in China,
State Secrets: China's Legal Labyrinth
,'' (2007).
Secrets can be classified into three categories: * Top Secret (), defined as "vital state secrets whose disclosure would cause extremely serious harm to state security and national interests" * Highly Secret (), defined as "important state secrets whose disclosure would cause serious harm to state security and national interests" * Secret (), defined as "ordinary state secrets whose disclosure would cause harm to state security and national interests"


France

In France, classified information is defined by article 413-9 of the Penal Code. The three levels of military classification are * (Very Secret Defence): Information deemed extremely harmful to national defence, 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 Defence): Information deemed very harmful to national defence. Such information cannot be reproduced without authorisation from the emitting authority, except in exceptional emergencies. * (Confidential Defence): 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 * ("Confidential officers") * ("Confidential non-commissioned officers") * ("restricted information") * ("administrative restricted information") * (unprotected) A further caveat, (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 the (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 or
diplomatic bag A diplomatic bag, also known as a diplomatic pouch, is a container with certain legal protections used for carrying official correspondence or other items between a diplomatic mission and its home government or other diplomatic, consular, or other ...
. Transport is done by an authorised conveyor or habilitated person for mail under 20 kg. The letter must bear a seal mentioning "". 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 the
Ministry of Interior An interior ministry or ministry of the interior (also called ministry of home affairs or ministry of internal affairs) is a government department that is responsible for domestic policy, public security and law enforcement. In some states, th ...
, the ' ("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

The Security 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 the colonial era of Hong Kong. Four classifications exists in Hong Kong, from highest to lowest in sensitivity: * Top Secret () * Secret () * Confidential () ** Temporary Confidential () * Restricted () ** Restricted (staff) () ** Restricted (tender) () ** Restricted (administration) () Restricted documents are not classified ''per se'', but only those who have a need to know will have access to such information, in accordance with the ''Personal Data (Privacy) Ordinance''.


New Zealand

New Zealand New Zealand () is an island country in the southwestern Pacific Ocean. It consists of two main landmasses—the North Island () and the South Island ()—and List of islands of New Zealand, over 600 smaller islands. It is the List of isla ...
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 background
vetting Vetting is the process of performing a background check on someone before offering them employment, conferring an award, or doing fact-checking prior to making any decision. In addition, in intelligence gathering, assets are vetted to determin ...
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

In
Romania Romania is a country located at the crossroads of Central Europe, Central, Eastern Europe, Eastern and Southeast Europe. It borders Ukraine to the north and east, Hungary to the west, Serbia to the southwest, Bulgaria to the south, Moldova to ...
, classified information is referred to as "state secrets" () 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". 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''). The levels are set by the
Romanian Intelligence Service The Romanian Intelligence Service (, abbreviated SRI) is Romania's main domestic intelligence service. Its role is to gather information relevant to national security and hand it over to relevant institutions, such as Romanian Government, presid ...
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.


Russia

In the
Russian Federation Russia, or the Russian Federation, is a country spanning Eastern Europe and North Asia. It is the list of countries and dependencies by area, largest country in the world, and extends across Time in Russia, eleven time zones, sharing Borders ...
, 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

The Swedish classification has been updated due to increased NATO/PfP cooperation. All classified defence documents will now have both a Swedish classification (, , or ), and an English classification (Top Secret, Secret, Confidential, or Restricted). The term , "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

At the federal level, classified information in Switzerland is assigned one of three levels, which are from lowest to highest: Internal, Confidential, Secret. Respectively, these are, in German, , , ; in French, , , ; in Italian, , , . 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." Information classified as Confidential could, if disclosed, compromise "the free formation of opinions and decision-making of the Federal Assembly or the Federal Council," jeopardise national monetary/economic policy, put the population at risk or adversely affect the operations of the
Swiss Armed Forces The Swiss Armed Forces (; ; ; ; ) are the military and security force of Switzerland, consisting of land and air service branches. Under the country's militia system, regular soldiers constitute a small part of the military and the rest are ...
. 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

According to the related regulations in
Turkey Turkey, officially the Republic of Türkiye, is a country mainly located in Anatolia in West Asia, with a relatively small part called East Thrace in Southeast Europe. It borders the Black Sea to the north; Georgia (country), Georgia, Armen ...
, there are four levels of document classification: (top secret), (secret), (confidential) and (restricted). The fifth is , which means unclassified.


United Kingdom

Until 2013, the
United Kingdom The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom (UK) or Britain, is a country in Northwestern Europe, off the coast of European mainland, the continental mainland. It comprises England, Scotlan ...
used five levels of classification—from lowest to highest, they were: Protect, Restricted, Confidential, Secret and Top Secret (formerly Most Secret). The
Cabinet Office The Cabinet Office is a Departments of the Government of the United Kingdom, ministerial department of the Government of the United Kingdom. It is responsible for supporting the Prime Minister of the United Kingdom, prime minister and Cabinet ...
provides guidance on how to protect information, including the security clearances required for personnel. Staff may be required to sign to confirm their understanding and acceptance of the Official 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. This system was replaced by the
Government Security Classifications Policy The Government Security Classifications Policy (GSCP) is a system for classifying Classified information in the United Kingdom, sensitive government data in the United Kingdom. GPMS Historically, the Government Protective Marking Scheme was used b ...
, which has a simpler model: Top Secret, Secret, and Official from April 2014. 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 the
D-Notice In the United Kingdom, D-Notices, officially known since 2015 as DSMA-Notices (Defence and Security Media Advisory Notices), are official requests to news editors not to publish or broadcast items on specified subjects for reasons of national sec ...
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.


United States

The U.S. classification system is currently established under
Executive Order 13526 Executive Order 13526 was issued on December 29, 2009, by United States President Barack Obama.
and has three levels of classification—Confidential, Secret, and Top Secret. The U.S. had a Restricted level during
World War II World War II or the Second World War (1 September 1939 – 2 September 1945) was a World war, global conflict between two coalitions: the Allies of World War II, Allies and the Axis powers. World War II by country, Nearly all of the wo ...
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 For Official Use Only (FOUO) is an information security designation used by some governments. United States Among U.S. government information, FOUO was primarily used by the U.S. Department of Defense as a handling instruction for C ...
(FOUO), or
sensitive but unclassified Sensitive But Unclassified (SBU) is a designation of information in the Federal government of the United States, United States federal government that, though unclassified, often requires FIPS 140-2#Level 2, strict controls over its distribution ...
(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. In the 1973 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, and
Edward Snowden Edward Joseph Snowden (born June 21, 1983) is a former National Security Agency (NSA) intelligence contractor and whistleblower who leaked classified documents revealing the existence of global surveillance programs. Born in 1983 in Elizabeth ...
could not get a fair trial. The State Secrets Protection Act of 2008 might have given judges the authority to review such questions
in camera ''In camera'' (; Latin: "in a chamber"). is a legal term that means ''in private''. The same meaning is sometimes expressed in the English equivalent: ''in chambers''. Generally, ''in-camera'' describes court cases, parts of it, or process wh ...
, but the bill was not passed. 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 the CIA 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 the
Hillary Clinton email controversy During Hillary Clinton's tenure as Secretary of State, her tenure as the United States secretary of state, Hillary Clinton drew controversy by using a private email server for official public communications rather than using official State Depa ...
when
Assistant Secretary of State for Legislative Affairs The assistant secretary of state for legislative affairs is the head of the Bureau of Legislative Affairs within the United States Department of State. List of assistant secretaries of state for legislative affairs References External links ...
Julia 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."


Table of equivalent classification markings in various countries


Corporate classification

Private
corporation A corporation or body corporate is an individual or a group of people, such as an association or company, that has been authorized by the State (polity), state to act as a single entity (a legal entity recognized by private and public law as ...
s often require written confidentiality agreements and conduct
background check A background check is a process used by an organisation or person to verify that an individual is who they claim to be, and check their past record to confirm education, employment history, and other activities, and for a criminal record. The fr ...
s on candidates for sensitive positions. In the U.S., the
Employee Polygraph Protection Act The Employee Polygraph Protection Act of 1988 (EPPA) is a United States federal law that generally prevents employers from using polygraph (lie detector) tests, either for pre-employment screening or during the course of employment, with certain ...
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 under
trade secret A trade secret is a form of intellectual property (IP) comprising confidential information that is not generally known or readily ascertainable, derives economic value from its secrecy, and is protected by reasonable efforts to maintain its conf ...
laws. New product development teams are often sequestered and forbidden to share information about their efforts with un-cleared fellow employees, the original
Apple Macintosh Mac is a brand of personal computers designed and marketed by Apple Inc., Apple since 1984. The name is short for Macintosh (its official name until 1999), a reference to the McIntosh (apple), McIntosh apple. The current product lineup inclu ...
project being a famous example. Other activities, such as
merger Mergers and acquisitions (M&A) are business transactions in which the ownership of a company, business organization, or one of their operating units is transferred to or consolidated with another entity. They may happen through direct absorpt ...
s and
financial report Financial statements (or financial reports) are formal records of the financial activities and position of a business, person, or other entity. Relevant financial information is presented in a structured manner and in a form which is easy to un ...
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

The Traffic Light Protocol was developed by the
Group of Eight The Group of Eight (G8) was an intergovernmental political forum from 1997 to 2014, formed by incorporating Russia into the G7. The G8 became the G7 again after Russia was expelled in 2014 after the Russian annexation of Crimea. The forum ...
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

*
Cloak and dagger "Cloak and dagger" was a fighting style common by the time of the Renaissance involving a knife hidden beneath a cloak. The term later came into use as a metaphor, referring to situations involving intrigue, secrecy, espionage, or mystery. Over ...
*
Economic Espionage Act of 1996 The Economic Espionage Act of 1996 () was a 6 title Act of Congress dealing with a wide range of issues, including not only industrial espionage (''e.g.'', the theft or misappropriation of a trade secret and the National Information Infrastructu ...
(U.S.) *
Espionage Espionage, spying, or intelligence gathering, as a subfield of the intelligence field, is the act of obtaining secret or confidential information ( intelligence). A person who commits espionage on a mission-specific contract is called an ...
*
Espionage Act of 1917 The Espionage Act of 1917 is a United States federal law enacted on June 15, 1917, shortly after the United States entered World War I. It has been amended numerous times over the years. It was originally found in Title 50 of the U.S. Code ( ...
(U.S.) * Eyes only *
Five Eyes The Five Eyes (FVEY) is an Anglosphere intelligence alliance comprising Australia, Canada, New Zealand, the United Kingdom, and the United States. These countries are party to the multilateral UKUSA Agreement, a treaty for joint cooperat ...
*
Golden Shield Project The Golden Shield Project (), also named National Public Security Work Informational Project, is the Chinese nationwide network-security fundamental constructional project by the e-government of the People's Republic of China. This project i ...
*
Government Security Classifications Policy The Government Security Classifications Policy (GSCP) is a system for classifying Classified information in the United Kingdom, sensitive government data in the United Kingdom. GPMS Historically, the Government Protective Marking Scheme was used b ...
(UK) *
Illegal number An illegal number is a number that represents information which is illegal to possess, utter, propagate, or otherwise transmit in some legal jurisdiction. Any piece of digital information is representable as a number; consequently, if communicatin ...
*
Information security Information security is the practice of protecting information by mitigating information risks. It is part of information risk management. It typically involves preventing or reducing the probability of unauthorized or inappropriate access to data ...
*
Official Secrets Act An Official Secrets Act (OSA) is legislation that provides for the protection of Classified information, state secrets and official information, mainly related to national security. However, in its unrevised form (based on the UK Official Secret ...
(UK, India, Ireland, Malaysia, New Zealand) *
Security of Information Act The ''Security of Information Act'' (, R.S.C. 1985, c. O-5), formerly known as the ''Official Secrets Act'', is an Act of the Parliament of Canada that addresses national security concerns, including threats of espionage by foreign powers and L ...
(Canada) * State Secrets Privilege (US) *
Wassenaar Arrangement The Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies, also known simply as the Wassenaar Arrangement, is a multilateral export control regime governing the international transfer of conventional ...
*
WikiLeaks WikiLeaks () is a non-profit media organisation and publisher of leaked documents. It is funded by donations and media partnerships. It has published classified documents and other media provided by anonymous sources. It was founded in 2006 by ...
*
UKUSA Agreement The United Kingdom – United States of America Agreement (UKUSA, ) is a multilateral agreement for cooperation in signals intelligence between Australia, Canada, New Zealand, the United Kingdom, and the United States. The alliance of intellig ...


References


External links


Defence Vetting Agency
Carries out national security checks in the UK. *
Peter Galison Peter Louis Galison (born May 17, 1955) is an American historian and philosopher of science. He is the Joseph Pellegrino University Professor in history of science and technology, history of science and physics at Harvard University. Biography G ...

Removing Knowledge
in ''
Critical Inquiry ''Critical Inquiry'' is a quarterly peer-reviewed academic journal in the humanities published by the University of Chicago Press on behalf of the Department of English Language and Literature (University of Chicago). While the topics and historica ...
'' n°31 (Autumn 2004). * Goldman, Jan, & Susan Maret. ''Intelligence and information policy for national security: Key terms and concepts.'' Rowman & Littlefield, 2016. * Lerner, Brenda Wilmoth, & K. Lee Lerner, eds. ''Terrorism: Essential primary sources.'' Thomson Gale, 2006.
Los Alamos table of equivalent US and UK classifications
* Maret, Susan. ''On their own terms: A lexicon with an emphasis on information-related terms produced by the U.S. federal government''

FAS, 6th ed., 2016.
Marking Classified National Security Information
ISOO booklet.
The National Security Archive
– a collection of declassified documents acquired through the Freedom of Information Act (United States), FOIA.
Parliament of Montenegro
Law on confidentiality of data. .
Parliament of Serbia
Law on confidentiality of data. .

explaining rules and policies for handling classified information. {{DEFAULTSORT:Classified Information Information sensitivity