Secret registry in Poland – technical, construction and organisational requirements

When a secret registry is mandatory

Under the Polish Act of 5 August 2010 on the protection of classified information, the head of an organisation that creates, processes, transmits or stores information classified as „tajne” (SECRET) or „ściśle tajne” (TOP SECRET) must establish a secret registry: a separate organisational unit reporting to the classified information protection officer and responsible for registering, storing, circulating and issuing materials to authorised persons.

For CONFIDENTIAL and RESTRICTED information a secret registry is not mandatory, but the materials must still be registered and protected with physical security measures appropriate to the classification.

Legal basis

• Act of 5 August 2010 on the protection of classified information (Journal of Laws 2025, item 1209, consolidated text),
• Council of Ministers Regulation of 7 December 2011 on the organisation and operation of secret registries and the processing of classified information (Journal of Laws No. 276, item 1631),
• Council of Ministers Regulation of 29 May 2012 on physical security measures for classified information (Journal of Laws item 683, as amended).

Technical and construction requirements

There is no single fixed list of construction requirements. The registry must be located in security zone I or II, and the measures are selected based on the threat level (low, medium or high) and the classification of the stored materials. Minimum storage requirements are:

• SECRET – a cabinet of at least class S1 under EN 14450 or a strongroom,
• TOP SECRET – a cabinet of at least class S2 under EN 14450 or a strongroom, plus constant supervision or an intrusion and hold-up alarm system combined with video surveillance.

How measures are selected – the points method

The physical security regulation uses a points method. Each measure scores points and the total must reach a minimum depending on the classification and threat level – 16, 19 or 20 points for SECRET and 20, 23 or 25 points for TOP SECRET. Points are scored for cabinets, rooms (walls, doors and windows under EN 1627, locks under EN 12209), the building, access control, security staff and alarm systems, and the site perimeter.

Organisation, staff and records

The registry is run by a registry manager and staffed only by members of the security unit holding an appropriate personnel security clearance and current training. It keeps the required registers (register of logbooks and files, logbook, local delivery book, list of dispatched items, register of issued items), which may be kept electronically. SECRET and TOP SECRET documents carry an access record sheet, and items marked „personal” are not opened in the registry. The reading room must be under constant staff supervision, but video surveillance of the reading room itself is not allowed.

Security plan and the industrial security certificate

Before the registry starts operating, the threat level must be determined and a classified information security plan approved by the head of the organisation. A company that wants to store and process SECRET or TOP SECRET materials on its own premises needs a level I or II industrial security certificate – and therefore a secret registry – and must organise its protection system within 6 months of the start of the industrial security proceedings. Registries handling NATO and EU information follow additional procedures.

Other services

• Secret registries
• Documentation
• Industrial Security Certificate