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Nội dung chính - Government classification[edit]Typical classification
levels[edit]Top Secret
(TS)[edit]Secret[edit]Confidential[edit]Restricted[edit]Official[edit]Unclassified[edit]Clearance[edit]Compartmented information[edit]International[edit]NATO
classifications[edit]International
organizations[edit]By
country[edit]Australia[edit]Brazil[edit]Canada[edit]People's Republic of
China[edit]France[edit]Hong Kong[edit]New
Zealand[edit]Romania[edit]Russia[edit]Sweden[edit]Switzerland[edit]Turkey[edit]United Kingdom[edit]United States[edit]Table of equivalent
classification markings in various countries[edit]Corporate classification[edit]Traffic Light Protocol[edit]See also[edit]References[edit]External
links[edit]Who is responsible for classifying information?Who provides implementation guidance for the information security program?What information do security classification guides SCG provide?What is the security classification guide?
A typical classified document. Page 13 of a U.S. National Security Agency report[1] on the USS Liberty 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 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 top and bottom cite statutory authority for not declassifying certain sections.
Classified information is material that a government body toàn thân deems to be sensitive information that must be protected. Access is restricted by law or regulation to particular groups of people with the necessary security clearance and need to know, and mishandling of the material can incur criminal penalties.
A formal security clearance is required to view or handle classified documents or to access classified data. 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. restricted, confidential, secret, and top secret. 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 each level. This process often includes security clearances for personnel handling the information.
Some corporations and non-government organizations also assign levels of protection to their private information, either from a desire to protect trade secrets, or because of laws and regulations governing various matters such as personal 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 been freedom 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 just social contract.
Government classification[edit]
The purpose of classification is to protect information. Higher classifications protect information that might endanger national 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]
Typical classification levels[edit]
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)[edit]
Top Secret is the highest level of classified information.[4] 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.[5] Such material would cause "exceptionally grave damage" to national security if made publicly available.[6] 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 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.[7]
Secret[edit]
It is desired that no document be released which refers to experiments 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 the Oak Ridge Laboratory in Tennessee.[8] As of 2010, 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".[9]
Secret material would cause "serious damage" to national security if it were publicly available.[10]
In the United States, operational "Secret" information can be marked with an additional "LimDis", to limit distribution.
Confidential[edit]
Confidential material would cause "damage" or be prejudicial to national security if publicly available.[11]
Restricted[edit]
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[edit]
Official (equivalent to US DOD classification FOUO – For Official Use Only) 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 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.[12]
Unclassified[edit]
Unclassified is technically not a classification level, but 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 that level or below that level. The individual must present a legitimate "need to know" in addition to the proper level of clearance.
Compartmented information[edit]
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 weapons often has an additional marking to show it contains such information (CNWDI).
International[edit]
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).
NATO classifications[edit]
For example, sensitive information shared amongst NATO allies has four levels of security classification; from most to least classified:[13][14]
COSMIC Top Secret (CTS)NATO Secret (NS)NATO Confidential (NC)NATO Restricted (NR)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 abbreviation for "Control Of Secret Material in an International Command".[15]
International organizations[edit]
- The European Union has four levels: EU Top Secret, EU Secret, EU Confidential, EU
Restricted.[16] (Note that usually the French terms are used.[citation needed])
- 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.
By country[edit]
Most countries employ some sort of classification system for certain government information. For example, in Canada, information that the U.S. would classify SBU (Sensitive but Unclassified) is called "protected" and further subcategorised into levels A, B, and C.
Australia[edit]
On 19 July 2011, the National Security (NS) classification marking scheme and the Non-National Security (NNS) classification marking scheme in Australia was unified into one structure.
As of 2022, the policy detailing how Australian government 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, personal security, and physical security. A security classification can be applied to the information itself or an asset that holds information e.g., a USB or máy tính.[19]
The PSPF outlines three categories of sensitive information, Unofficial, Official and Official: Sensitive. Additionally, the PSPF defines three levels of security classified information, Protected, Secret and Top Secret. Although not identical, the definitions of each classification broadly fit the British definitions.
A caveats is a warning that the information has special protections in addition to those indicated by the security classification. Australia has four categories of caveats:
- Codewords (sensitive compartmented information)Foreign government markingsSpecial handling instructionsReleasability caveats
Special handling instructions are used to indicate particular precautions for information handling. They include Exclusive For, Cabinet and National Cabinet. A releasability caveat restricts information based on citizenship. The three in use are: Australian Eyes Only (AUSTEO), Australian Government Access Only (AGAO) and Releasable To (REL).[19]
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, and personal privacy.[19]
Brazil[edit]
There are three levels of document classification under Brazilian Information Access Law: ultrassecreto (top secret), secreto (secret) and reservado (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. 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[edit]
Background and hierarchy[edit]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, effective 24 December 2001, replacing the Official Secrets Act 1981.[20] 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.[21]
Special operational information[edit]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 conflictthe identity of confidential source of information, intelligence or assistance to the Government of Canadatools used for information gathering or intelligencethe object of a covert investigation, or a covert collection of information or intelligencethe identity of any person who is under covert
surveillanceencryption and cryptographic systemsinformation or intelligence to, or received from, a foreign entity or terrorist group
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 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.[22][23]
- 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 (Queen'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).[24]
People's Republic of China[edit]
A building in Wuhan housing provincial offices for dealing with foreign countries etc. The red slogan says, "Protection of national secrets is a duty of every citizen".
The Criminal Law of the People's Republic of China (which is not operative in the special administrative regions of Hong Kong and Macau) 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.
Under the 1989 "Law on Guarding State Secrets",[25] state secrets are defined as those that concern:
Major policy decisions on state affairsThe building of national defence and in the activities of the armed forcesDiplomatic activities and in activities related to foreign countries and those to be maintained as commitments to foreign countriesNational economic and social developmentScience and technologyActivities for preserving state security and the investigation of criminal offencesAny other matters classified as "state secrets" by the national State Secrets Bureau[26]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"[26]
France[edit]
In France, classified information is defined by article 413-9 of the Penal Code.[27] 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 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): Information deemed potentially harmful to national defence, or that could lead to uncovering some information classified 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 the Commission 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 or diplomatic 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 the Ministry 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[edit]
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 Hong Kong era.
Four classifications exists in Hong Kong, from highest to lowest in sensitivity:[28]
- Top Secret (絕對機密)Secret (高度機密)Confidential (機密)
- Temporary Confidential
(臨時保密)
- 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 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.[29]
New Zealand[edit]
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 background vetting 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 the In Confidence level.
Romania[edit]
In Romania, 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".[30] There are three levels of classification—Secret, Top Secret, and Top Secret of Particular Importance.[31] The levels are set by the Romanian 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.[32]
KGB regulation seen in Museum of Genocide Victims Vilnius
Russia[edit]
In the Russian 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 indicates Hemlig, which can be equal to either Secret, Confidential or Restricted. Double frames means Kvalificerat 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 or Begränsat Hemlig), and an English classification (Top Secret, Secret, Confidential, or Restricted).[citation needed] The term skyddad 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[edit]
At the federal level, classified information in Switzerland is assigned one of three levels, which are from lowest to highest: Internal, Confidential, Secret.[33] 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."[33] Information classified as Confidential could, if disclosed, compromise "the không lấy phí formation of opinions and decision-making of the Federal Assembly or the Federal Council," jeopardise national monetary/economic policy, put the population risk or adversely affect the operations of the Swiss 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 in Turkey, there are four levels of document classification:[34] çok gizli (top secret), gizli (secret), özel (confidential) and hizmete özel (restricted). The fifth is tasnif dışı, which means unclassified.
United Kingdom[edit]
Security classifications in the UK
Until 2013, the United Kingdom used five levels of classification—from lowest to highest, they were: Protect, Restricted, Confidential, Secret and Top Secret (formerly Most Secret). The Cabinet Office 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.[35]
This system was replaced by the Government Security Classifications Policy, which has a simpler model: Top Secret, Secret, and Official from April 2014.[12] 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 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[edit]
The U.S. classification system is currently established under Executive Order 13526 and has three levels of classification—Confidential, Secret, and Top Secret. The U.S. had a Restricted level during World War II but no longer does. U.S. regulations state that information received from other countries 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), or Sensitive 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.[36] 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. today is worse than it was in 1973, and Edward Snowden could not get a fair trial.[37] The State Secrets Protection Act of 2008 might have given judges the authority to review such questions in camera, but the bill was not passed.[36]
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 when Assistant Secretary of State for Legislative Affairs 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.”[38][39][40]
Table of equivalent classification markings in various countries[edit]
(State) Top Secret Secret Confidential Restricted Albania Teper Sekret Sekret Konfidencial I Kufizuar Argentina Estrictamente Secreto y Confidencial Secreto Confidencial Reservado Armenia Հատուկ կարևորությանOf Special Importance Հույժ գաղտնի
Top Secret Գաղտնի
Secret[41] Ծառայողական օգտագործման համար
For Service Use Australia Top Secret Secret Retired. Treat as Secret.[19][42] Protected Austria Streng Geheim Geheim Vertraulich Eingeschränkt Belgium Zeer Geheim / Très Secret Geheim / Secret Vertrouwelijk / Confidentiel Beperkte Verspreiding / Diffusion restreinte Bolivia Supersecreto
or Muy Secreto Secreto Confidencial Reservado Bosnia and Herzegovina Vrlo tajno Tajno Povjerljivo Interno Brazil Ultrassecreto Secreto no equivalent (formerly Confidencial) Reservado Bulgaria Strògo sèkretno
Строго секретно Sèkretno
Секретно Poveritèlno
Поверително Za služebno polzvàne
За служебно ползване Cambodia Sam Ngat Bamphot Sam Ngat Roeung Art Kambang Ham Kom Psay Canada Top Secret/Très secret Secret/Secret Confidential/Confidentiel Protected A, B or C/Protégé A, B ou C Chile Secreto Secreto Reservado Reservado China Juémì (绝密) Jīmì (机密) Mìmì (秘密) Nèibù (内部) Colombia Ultrasecreto Secreto Confidencial Reserva del sumario Costa Rica Alto Secreto Secreto Confidencial Croatia Vrlo tajno Tajno Povjerljivo Ograničeno Czech Republic Přísně tajné Tajné Důvěrné Vyhrazené Denmark Yderst Hemmeligt (YHM) Hemmeligt (HEM) Fortroligt (FTR) Til Tjenestebrug (TTJ)
Foreign Service: Fortroligt
(thin black border)
سري للغاية Sirriy Ǧiddan
سري جداً Khāṣ
خاص Maḥzūr
محظور El Salvador Ultra Secreto Secreto Confidencial Reservado Estonia Täiesti salajane Salajane Konfidentsiaalne Piiratud Ethiopia ብርቱ ምስጢር ምስጢር ጥብቅ ክልክል European Union (EU) Tres Secret UE / EU Top Secret Secret UE / EU Secret Confidentiel UE / EU Confidential Restreint UE / EU Restricted European Union (Western) (WEU) Focal top secret WEU Secret WEU Confidential WEU Restricted Euratom EURA Top Secret EURA Secret EURA Confidential EURA Restricted Finland[a] Erittäin salainen (ST I) Salainen (ST II) Luottamuksellinen (ST III) Käyttö rajoitettu (ST IV) France Très secret Secret Secret Diffusion restreinte Germany Streng Geheim Geheim VS-Vertraulich VS-Nur Für Den Dienstgebrauch Greece Άκρως Απόρρητον Απόρρητον Εμπιστευτικόν Περιορισμένης
Χρήσης Guatemala Alto Secreto Secreto Confidencial Reservado Haiti Top Secret Secret Confidential Reserve Honduras Super Secreto Secreto Confidencial Reservado Hong Kong Top Secret, 高度機密 Secret, 機密 Confidential, 保密 Restricted, 內部文件/限閱文件 Hungary Szigorúan Titkos Titkos Bizalmas Korlátozott Terjesztésű India (Hindi) परम गुप्त (Param Gupt) गुप्त (Gupt) गोपनीय (Gopniya) प्रतिबंधित/सीमित (Pratibandhit/seemit) India (English) Top Secret Secret Confidential Restricted Indonesia Sangat Rahasia Rahasia Rahasia Dinas Terbatas Iran Bekoli-Serri بکلی سری Serri سری Kheili-Mahramaneh خیلی محرمانه Mahramaneh محرمانه Iraq Sirriy lil-Ġāyah
سري للغاية Sirriy
سري Khāṣ
خاص Maḥdūd
محدود Iceland Algert Leyndarmál Leyndarmál Trúnaðarmál Þjónustuskjal Ireland (Irish language) An-sicreideach Sicreideach Runda Srianta Israel Sodi Beyoter
סודי ביותר Sodi
סודי Shamur
שמור Mugbal
מוגבל Italy Segretissimo Segreto Riservatissimo Riservato Nhật bản Kimitsu (機密) Gokuhi (極秘) Hi (秘) Toriatsukaichuui (取り扱い注意) Jordan Maktūm Ǧiddan
مكتوم جداً Maktūm
مكتوم Sirriy
سري Maḥdūd
محدود South Korea 1(Il)-geup Bimil, 1급 비밀, 一級秘密 2(I)-geup Bimil, 2급 비밀, 二級秘密 3(Sam)-geup Bimil, 3급 비밀, 三級秘密 Daeoebi, 대외비, 對外秘 Laos Lup Sood Gnod Kuam Lup Kuam Lap Chum Kut Kon Arn Latvia Sevišķi slepeni Slepeni Konfidenciāli Dienesta vajadzībām Lebanon Tres Secret Secret Confidentiel Lithuania Visiškai Slaptai Slaptai Konfidencialiai Riboto Naudojimo Malaysia Rahsia Besar Rahsia Sulit Terhad Mexico Ultra Secreto Secreto Confidencial Restringido Montenegro Strogo Tajno Tajno Povjerljivo Interno Netherlands[43] STG. Zeer Geheim STG. Geheim STG. Confidentieel Departementaal Vertrouwelijk New Zealand Top Secret Secret Confidential Restricted Nicaragua Alto Secreto Secreto Confidencial Reservado Norway Strengt Hemmelig Hemmelig Konfidensielt Begrenset Pakistan (Urdu) Intahai Khufia
انتہائی خفیہ Khufia
خفیہ Sigh-e-Raz
صیخہ راز Barai Mahdud Taqsim
محدود تقسیم Pakistan (English) Top Secret Secret Confidential Restricted Paraguay Secreto Secreto Confidencial Reservado Peru Estrictamente Secreto Secreto Confidencial Reservado Philippines (English)
Philippines (Tagalog)
Top SecretMatinding Lihim
Mahigpit na Lihim
Lihim
Ipinagbabawal
(вариант: Совершенно Секретно (Sovershenno Sekretno))
Of Special Importance
Совершенно секретно(вариант: Секретно (Sekretno))
Completely Secret
Секретно(вариант: Не подлежит оглашению
(Конфиденциально) (Ne podlezhit oglasheniyu (Konfidentsial'no))
Secret
Для Служебного Пользования (ДСП)(Dlya Sluzhebnogo Pol'zovaniya)
For Official Use
Saudi Arabia Saudi Top Secret Saudi Very Secret Saudi Secret Saudi Restricted Serbia Cyrillic: Државна тајнаLatin: Državna tajna Cyrillic: Строго поверљиво
Latin: Strogo poverljivo Cyrillic: Поверљиво
Latin: Poverljivo Cyrillic: Интерно
Latin: Interno Singapore Top Secret Secret Confidential Restricted Somalia Sir Muhiim ah Sir Gooniya Xog Qarsoon Qarsoon Slovak Republic Prísne tajné Tajné Dôverné Vyhradené Slovenia Strogo tajno Tajno Zaupno Interno Spain Secreto Reservado Confidencial Difusión Limitada Sri Lanka අති රහස්ය රහස්ය රහසිගත සීමාන්විත Sweden Kvalificerat hemlig (KH); Hemlig/Top Secret (H/TS) Hemlig (H); Hemlig/Secret (H/S) Konfidentiell; Hemlig/Confidential (H/C) Begränsat hemlig; Hemlig/Restricted (H/R) Switzerland Geheim / Secret Vertraulich / Confidentiel Intern / Interne Taiwan (Republic of China)[44] Top Secret (絕對機密) Secret (極機密) Confidential (機密) no direct equivalent Tanzania (Swahili) Siri Kuu Siri Stiri Imezuiliwa Thailand Lap thi sut ลับที่สุด) Lap mak ลับมาก) Lap ลับ) Pok pit ปกปิด) Turkey Çok Gizli Gizli Özel Hizmete Özel South Africa (English) Top Secret Secret Confidential Restricted South Africa (Afrikaans) Uiters Geheim Geheim Vertroulik Beperk Ukraine Цілком таємно Таємно Конфіденційно Для службового користування United Kingdom Top Secret Secret Official-Sensitive (formerly Confidential) Official (formerly Restricted) United States Top Secret Secret Confidential no direct equivalent Uruguay Ultra Secreto Secreto Confidencial Reservado Vietnam Tuyệt Mật, 絕密 Tối Mật, 最密 Mật, 密 Phổ Biến Hạn Chế, 普遍限制 Table notes:^ Finland uses also uses the label Salassa 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 2022. Retrieved 27 July 2022.
Corporate classification[edit]
Private corporations often require written confidentiality agreements and conduct background checks on candidates for sensitive positions.[45] In the U.S. the Employee 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 under trade secret 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 project being a famous example. Other activities, such as mergers and financial 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]
The Traffic Light Protocol[46][47] was developed by the Group 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]
- Economic Espionage Act of 1996 (U.S.)EspionageEspionage Act of 1917 (U.S.)Eyes
onlyFive EyesGolden Shield ProjectGovernment Security Classifications Policy (UK)Illegal numberInformation securityOfficial Secrets Act (UK, India, Ireland, Malaysia, New Zealand)Security of Information Act (Canada)State Secrets Privilege (US)Wassenaar ArrangementWikiLeaksUKUSA Agreement
References[edit]
^ "United States Cryptologic History: Attack on a Sigint Collector, the U.S.S. Liberty" (PDF). NSA.gov. Archived from the original (PDF) on 30 October 2012. Retrieved 14 November 2012.^ Turner, Stansfield (2005). Burn Before Reading: Presidents, CIA Directors and Secret Intelligence. New York: Hyperion. ISBN 9780786867820. ^ Goldsmith, Jack (29 September 2010). "Classified Information in Woodward's 'Obama's Wars'". Lawfare. Retrieved 5 September 2015.^ Random House Webster's Unabridged Dictionary (2. ed., [Nachdr.] ed.). Tp New York [u.a.]: Random House. 2004. ISBN 0375425993.^ Defense Technical Information Center (April 1997). "DoD Guide to Marking Classified Documents". dtic.mil. Archived from the original on 24 May 2022.^ Federation of American Scientists (8 June 2013). "Chapter 7. Classification Levels". fas.org.^ Priest, Dana; Arkin, William (19 July 2010). "A hidden world, growing beyond control". The Washington Post. Archived from the original on 20 July 2010. Retrieved 5 September 2015.^ Atomic Energy Commission's Declassification Review of Reports on Human Experiments and the Public Relations and Legal Liability Consequences Archived 6 June 2013 the Wayback Machine, presented as evidence during the 1994 ACHRE hearings.^ Section 1.7 (1) and (2).^ "E-PME Enlisted Professional Military Education Reporting Unsecured and Securing Classified Material 4.G.03" (PDF). United States Coast Guard. Archived from the original (PDF) on 29 October 2013.^ George Washington University. "Attachment 2 AR 320-5, Classification of OFC. Army Regulations (1936)". gwu.edu. Archived from the original on 13 July 2013. Retrieved 16 June 2013.^ a b Government Security Classifications April 2014. HMG Cabinet Office. October 2013.^ Internet, JSK. "Ochrona Informacji Niejawnych Międzynarodowych W Sferze Cywilnej I Wojskowej – Ochrona informacji niejawnych międzynarodowych w sferze cywilnej i wojskowej – BIP – Agencja Bezpieczeństwa Wewnętrznego". www.bip.abw.gov.pl. ^ "NATO Security Indoctrination" (PDF).^ Government of Canada, Public Services and Procurement Canada (30 August 2022). "Chapter 9: Security requirements for the North Atlantic Treaty Organization – Industrial Security Manual – Security requirements for contracting with the Government of Canada – Canada.ca". www.tpsgc-pwgsc.gc.ca. Retrieved 10 September 2022. ^ "Decision of 23 September 2013 on the security rules for protecting EU classified information". Official Journal of the European Union. 15 October 2013. Retrieved 5 September 2015.^ "306652_CM6554" (PDF). Archived from the original (PDF) on 25 May 2005. Retrieved 14 November 2012.^ "European Centre for Information Policy and Security (ECIPS)" (PDF). p. 7. Archived (PDF) from the original on 6 July 2022.^ a b c d "Policy 8: Sensitive and classified information". Protective Security Policy Framework. Retrieved 17 April 2022.^ Security of Information Act, Archived 16 January 2008 Archive-It^ "Industrial Security Services – Frequently Asked Questions". Public Works and Government Services Canada. Government of Canada. Archived from the original on 20 November 2013. Retrieved 8 November 2012.^ "Archived – Non-Insured Health Benefits Program: Privacy Code, 2005 (Appendix II)". Health Canada, First Nations and Inuit Health Branch. 2015. Archived from the original on 24 September 2015. Retrieved 5 September 2015. ^ "Security Policy – Manager's Handbook". Archived from the original on 1 June 2005.^ "Archived – Access to Information Guidelines – Confidences of the Queen's Privy Council for Canada". Treasury Board of Canada Secretariat. 2015. Archived from the original on 17 October 2015. Retrieved 5 September 2015.^ Standing Committee of the National People's Congress, "Law on Guarding State Secrets". Archived 27 September 2010 the Wayback Machine (中华人民共和国保守国家秘密法), promulgated 1988 and effective 1989.^ a b Translation per Human Rights in China, State Secrets: China's Legal Labyrinth, (2007).^ "Code pénal – Article 413-9". Legifrance. 2009. Retrieved 5 September 2015.^ [1] Archived 1 December 2006 the Wayback Machine ^ "LCQ3: Equal Opportunities Commission". Archived from the original on 27 December 2008.^ "Penal Code of Romania, art. 150". Retrieved 28 January 2013.^ "Law no. 182/2002 on protection of classified information". Retrieved 28 January 2013.^ "Penal Code of Romania, art. 157". Retrieved 28 January 2013.^ a b "Ordinance on the Protection of Federal Information". Swiss Federal Government. 1 January 2022. Retrieved 29 January 2022.^ Diri, Mustafa; Gülçiçek, Mirac (2012). "Türkiye'de Kamu Hizmetinin Görülmesinde Kullanılmakta Olan Gizlilik Derecesi Tanımları : Uygulamadaki Sorunlar ve Çözüm Önerileri" (PDF). Maliye Dergisi (in Turkish) (162): 497–537. ^ "Understanding the Security Policy Framework & frequently asked questions". Cabinet Office. 1 April 2013. Retrieved 5 September 2015.^ a b Aftergood, Steven (27 August 2014). "Gov't Resists Court Review of State Secrets". Secrecy News. Federation of American Scientists. Retrieved 26 September 2014.^ Ellsberg, Daniel (30 May 2014). "Daniel Ellsberg: Snowden would not get a fair trial – and Kerry is wrong". The Guardian. Retrieved 26 September 2014. ^ "DoD Warns Employees of Classified Info in Public Domain – Federation Of American Scientists".^ Myers, Steven Lee; Mazzetti, Mark (5 February 2022). "Agencies Battle Over What Is 'Top Secret' in Hillary Clinton's Emails". The Tp New York Times. ^ "Secrecy defines Obama's drone war". Washington Post.^ Republic of Armenia Law on State and Service Secrets (in Armenian). Yerevan: National Assembly of Armenia. 23 December 1996. pp. 1123–1124.^ "Policy 7: Security governance for international sharing". Protective Security Policy Framework. Retrieved 17 April 2022.^ "Wet- en regelgeving – Besluit voorschrift informatiebeveiliging rijksdienst – bijzondere informatie – BWBR0016435" (in Dutch). Wetten.overheid.nl. Retrieved 4 July 2013.^ "The Classified National Security Information Protection Act". 6 February 2003. Retrieved 26 March 2014.^ "Employment Background Checks: A Jobseeker's Guide | Privacy Rights Clearinghouse". Privacyrights.org. Archived from the original on 9 January 2012. Retrieved 12 December 2011.^ "Development of Policies for Protection of Critical Information Infrastructures" (PDF). Cecd.ord. Retrieved 14 November 2012.^ "'Re: OpenSSH security advisory: cbc.adv' – MARC". Marc.info. Retrieved 12 December 2011.External links[edit]
- Defence Vetting Agency. Carries out national security checks in the UK.Peter Galison, Removing Knowledge in Critical Inquiry n°31 (Autumn 2004).Goldman, Jan, & Susan Maret. Intelligence and information policy for national security: Key
terms and concepts. Rowman & Littlefield, 2022.Lerner, Brenda Wilmoth, & K. Lee Lerner, eds. Terrorism: Essential primary sources. Thomson Gale, 2006.Los Alamos table of equivalent US and UK classificationsMaret, Susan. On their own terms: A lexicon with an emphasis on information-related terms produced by the
U.S. federal government. [2], FAS, 6th ed., 2022.Marking Classified National Security Information ISOO booklet.The National Security Archive – a collection of declassified documents acquired through the
FOIA.Parliament of Montenegro, Law on confidentiality of data. (in Serbian).Parliament of
Serbia, Law on confidentiality of data. (in Serbian).U.S. Department of Defense National Industrial Security Program - Operating Manual (DoD 5220.22-M), explaining rules and policies for handling classified information.
Who is responsible for classifying information?
In most cases, the asset owner is responsible for classifying the information – and this is usually done based on the results of the risk assessment: the higher the value of information (the higher the consequence of breaching the confidentiality), the higher the classification level should be.Who provides implementation guidance for the information security program?
13526 and further defines what the Executive Branch agencies must do to comply with E.O. requirements. The Undersecretary of Defense for Intelligence, or USD(I), provides implementation guidance for the Information Security Program within the DoD.What information do security classification guides SCG provide?
SCGs provide detailed classification guidance on program-specific information for use by derivative classifiers in applying appropriate classification markings and facilitate the proper and uniform derivative classification of information.What is the security classification guide?
A security classification guide is the written record of an original classification decision or series of decisions regarding a system, plan, program, project, or mission. Tải thêm tài liệu liên quan đến nội dung bài viết Who references information from security classification guides in order to classify information
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