International Security Clearances: How Other Countries Protect Their Secrets and Screen Their Spies

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Anyone who’s ever applied for a security clearance in the United States is familiar with the SF-86 “Questionnaire for National Security Positions” and the hell that is tracking down ten years of mailing addresses. The security screening process is in many ways a measurement of how interesting your life has been. (Only the most fascinating of people can fill out all four boxes in Section 5, which asks for a list of the applicant’s aliases.) The security clearance system isn’t perfect, but it’s the best we’ve got, and there’s a remarkable overlap in structure and process by other nations. Here are the classification and clearance processes of a few countries around the world.

Israel

The Shin Bet, whose mission roughly parallels the FBI and U.S. Secret Service, handles the security screening process in Israel. The first step in obtaining a clearance involves completing an eighteen-page application. The form doesn’t deviate much from the SF-86, though it really drills down on overthrowing the government. It asks if you’ve ever tried to; it asks if you’ve been part of group that wanted to; and it asks if you know anyone who’s tried to. After the form is submitted, investigators will contact character references, and the applicant will be interviewed in person. (This process often involves a polygraph.) The levels of clearance are Shamur, Sodi, and Sodi Beyoter, or confidential, secret, and top secret, respectively.

Soviet Union

The Soviet Union is a nice historical touchstone for all matters covert. According to the Encyclopedia of Soviet Life by Ilya Zemtsov, the Soviets had four tiers of classification. At the lowest level, individuals were cleared to access files marked “DSP,” short for Dlya Sluzhebnogo Pol’zovaniya (roughly: “For official use only”). Such documents could not be published, reproduced, or disseminated. Basic material considered sensitive to national security were given the DSP treatment, but so too were any foreign books, periodicals, or other media that contradicted the party line.

The next level was called “form number two,” or Sekretno, and generally involved access to materials related to infrastructure projects and military research. The third level—Sovershenno Sekretno, marked “SS”—involved advanced research projects and space research, strategic planning, and extremely sensitive government proceedings. The very top tier of clearance concerned the inner-workings of the Politburo. Considering the size of that body—a mere fourteen vested members with eight candidates waiting in the wings—it’s safe to say that very few people held such a clearance. As Ilya Zemtsov notes, though government classification authority was used to protect state secrets, it was more often used to keep hidden the backwardness of the Soviet state. Today, the nomenclature, at least, of Russian classification remains largely unchanged.

Canada

The starting point for a security clearance in Canada is the SCT 330-60E, which asks the usual questions about relatives, friends, houses, jobs, and arrests. The form is notably disinterested in the applicant’s attempts to overthrow the government. (But then, it’s Canada. Why would anyone bother?) Once filed, the form is passed to the Mounties and the Canadian Security Intelligence Service (CSIS) for investigation. Those applying for Confidential or Secret clearances will agree to a “criminal records name check.” Applicants for Top Secret will also have to cough up a fingerprint check and a credit history. The whole process is detailed here.

People’s Republic of China

To a certain extent, the administration and legal framework of state secrecy in China is itself a secret. Two laws provide the foundation for the entirety of its secrecy apparatus: the Law on the Protection of State Secrets, and the Measures for Implementing the Law on the Protection of State Secrets. A third law enumerates the consequences of leaking classified material. This law is called—deep breath—the Supreme People’s Court’s Interpretation of Certain Issues Regarding the Specific Application of the Law When Trying Cases of Stealing, Gathering, Procuring or Illegally Providing State Secrets or Intelligence Outside of the Country. (Really. In fairness, the Chinese are probably laughing at us for the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act. Somehow it all made sense at the time.)

Until very recently, the actual definition of “secret” as codified by Chinese statute basically included everything, and the punishment for “serious” violations of state secrecy could be anything. “Serious,” like “secret,” was undefined, and the result was an easy, legal way for officials to stifle dissent. (The lack of a clear definition of a state secret isn’t inconceivable per se. The U.S. intelligence community, for example, has yet to agree on a clear, unified definition of intelligence.) 2010 proved a landmark year for sunlight laws in China, as several important reforms were implemented. Classification authority was eliminated at the lowest levels of government, a result of local officials abusing the red stamp as a means of avoiding public inquiry. Standards were put into place to formalize what types of information might be eligible for classification, and mechanisms for accountability in classification authority were implemented. Secrets were even given an expiration date: “top secret” (or juémì) material goes public after thirty years; “highly secret” (jí jī mì) material lasts twenty years; and “secret” (mìmì) information is available for declassification after ten years. Most importantly, perhaps, is that some effort was made to define a “secret.” (This is all relative, of course. It’s silly to pretend that a Chinese Bradley Manning would still be alive.)

France

Obtaining a security clearance in France is pretty much by-the-numbers. The petitioner first completes a Modèle 94 screening form [doc], which again asks the standard questions (though only five years of addresses, jobs, and international travel are required). The questionnaire takes a special interest in foreign travel, and asks specifically about international incidents and personal relationships by the applicant or his or her spouse outside of French soil. (Like its Canadian counterpart, the French form doesn’t ask about overthrowing the government, which is curious considering how often French citizens take to the streets with banners and Molotov cocktails.)

The Haut Fonctionnaire de Défense et de Sécurité (HFDS) carries out the investigative portion of the screening, and grants clearances accordingly. (The defense secretary is the approving authority for top-secret clearances.) The three levels of clearance are Très Secret-Défense, which expires every three years; Secret-Défense, which expires every five years; and Confidentiel-Défense, which expires every ten years. (Need-to-know, as always is paramount in accessing classified material.) Sensitive documents are so marked with a red stamp, and double enveloped when mailed. To destroy said documents, they must be logged, and then burned or shredded.

Foreigners employed in sensitive positions are ineligible for top-secret clearances, and are specifically forbidden from accessing any document marked Spécial-France, even if the appropriate clearance is held. So clearly the French are up to something.

David Brown is a regular contributor to Clearance Jobs. He is currently at work on his next book, One Inch From Earth, which tells the story of scientists who study the outer planets of the solar system. He can be found online at http://dwb.io.