What Is the Definition of Paraphrasing in the Context of Derivative Classification: The 2020 NISPOM Rule and Three Failure Cases

In derivative classification, paraphrasing means restating classified source information in your own words without changing its classified meaning. Under the National Industrial Security Program Operating Manual, 32 CFR Part 117, issued May 18, 2021, a paraphrase that conveys the same national security information is still derivative classification. You must mark it at the source's level, apply the source's duration, and carry the source's control markings forward. Removing the original sentences does not remove the classification.

The definition matters because the National Declassification Center at the National Archives handled 95.7 million pages in fiscal year 2023, and every one of those pages propagated through some mix of copying, paraphrasing, and restating. Restatement is where errors creep in quietly. This article gives you the plain-English definition, the three scenarios that trip people up, the terms people confuse with paraphrasing, and a computed check that shows what a single miswrapped paragraph costs a cleared contractor.

The Official Definition: Restatement That Preserves Classified Meaning

The controlling text sits in 32 CFR 117.3, the definitions section of the National Industrial Security Program Operating Manual, which the Department of Defense issued on May 18, 2021, replacing the 2006 NISPOM. That section defines derivative classification as incorporating, paraphrasing, restating, or generating information already classified. The four verbs are listed side by side on purpose.

Paraphrasing is the second verb in that list, and it carries a specific burden. You substitute your own sentence structure and vocabulary while the national security information the source conveyed stays intact. If the meaning survives, so does the classification. If the paraphrase adds an inference the source did not state, you have created new content, and derivative authority does not cover it.

The manual also tells you who can work this way. Only a person with derivative classification authority, or one trained and designated under 32 CFR 117.13 for original classification authority, may derive. Clearance alone does not confer that authority. An uncleared writer who paraphrases classified details into a draft has committed a spill, not a derivative act.

Practical definition, then: paraphrasing is a permitted derivative technique only when the restated meaning maps back to a specific classified source, the level and duration match, and the mark names the source document. Strip any of those three and the paraphrase becomes a marking violation first and a security incident second.

What Paraphrasing Is Not: Three Scenarios That Test the Boundary

The cleanest way to learn the definition is to run scenarios against it. The table below maps common moves against the regulatory test. Each row is something a cleared analyst, technical writer, or program manager might do on an ordinary Tuesday.

The word-swap row is the everyday case, and it is where most violations live. Contractors routinely treat a rewritten sentence as a fresh sentence. The regulation does not. The National Archives' Information Security Oversight Office, which oversees the executive branch's classified marking system, treats substitution of synonyms as derivative the moment the underlying fact is recognizable.

The detail-stripping row is the edge case that trips people. Cutting a number can declassify a sentence only when the remaining statement is genuinely unclassified, and that judgment belongs to the classifier who wrote the guidance, not the writer. If you cannot point to a line in the source's classification guide that says the trimmed statement is unclassified, you have not declassified anything.

The inference row is the failure with the longest tail. An inference that a cleared analyst draws from classified material is still classified by definition, but only an original classifier can assign its level. Derivative classifiers who assemble new conclusions are acting outside their authority even when every input fact was properly marked.

The Four Verbs of 32 CFR 117.3 and How Paraphrasing Differs From Each

Paraphrasing differs from the other three derivative verbs in a way that matters at the desk. Copying keeps the words. Restating keeps the structure. Generating produces new material from classified knowledge. Paraphrasing keeps the meaning while changing the words, which makes it the verb most dependent on the writer's judgment.

Restating and paraphrasing are close cousins, and the manual puts them next to each other. Restating typically recasts a passage's organization, pulling a paragraph into a bullet list or moving a conclusion to the front. Paraphrasing swaps vocabulary sentence by sentence. Both preserve meaning, and both require the same marking treatment, so the distinction is more useful for training than for compliance.

Generating is the outlier. Deriving through generation means drawing on classified knowledge you already hold to produce new sentences, and it still counts as derivative because the substance came from classified sources. The regulatory line falls between generating from what you know and creating a new assessment. The first is derivative. The second needs original authority.

Common confusion arrives from the unclassified side of the house. Writers who have used paraphrase in academic writing to avoid plagiarism import the habit and assume paraphrasing is neutral. In classification work, the technique is neutral and the content is not. A perfectly original sentence can be a perfectly derivable one.

Copy, Paraphrase, or Generate: A Comparison for the Person at the Keyboard

The person holding a draft and a classified source needs a decision rule, not theory. The comparison below reduces the four derivative verbs to the three you will actually face in a working day, since most people never touch restating as a distinct technique.

The table makes the source-citation row look identical across all three, and that is the point most writers miss. Paraphrasing does not loosen the citation. The mark on a paraphrased paragraph must name the same source document the copied paragraph would have named.

Verdict rule: if the sentence would embarrass you when laid beside the source in a security review, treat it as a copy and mark accordingly. If the sentence draws a conclusion neither source states, stop and route it to an original classification authority.

Applying the Definition: Five Steps From Source Page to Marked Draft

This is the action sequence that keeps a paraphrased paragraph compliant. It assumes you hold derivative classification authority, you have completed the training required by 32 CFR 117.13 within the past two years, and the source document sits in front of you.

1: Locate the classification guide or source marking. Find the specific paragraph, banner line, and portion markings for the material you intend to restate. Note the level, the reason, the declassify-on date or event, and every dissemination control such as NOFORN or REL TO. 2: Draft the paraphrase with the source visible. Keep the source open beside the draft. Write your version, then read both side by side and confirm the national security information conveyed is the same. 3: Run the derivation check. Ask whether a reader who saw only your sentence could reconstruct the classified fact. If yes, the paraphrase has preserved meaning and inherits the marking. 4: Apply portion markings and the classification authority block. Mark the paraphrased portion at the source level, then build the "Classified By" line naming the source document, the "Derived From" line, the "Declassify On" line, and any control markings the source carried. 5: Compare marks against the source once more before release. Control markings are the first casualty of rewording. NOFORN survives a synonym swap exactly as it survives a copy.

Failure handling follows the same order. If step 3 reveals you added an inference, stop and return the draft to an original classification authority rather than guessing a level. If step 5 reveals a missing control marking, treat the draft as a potential unauthorized disclosure and route it through your facility security officer's incident channel before any further distribution.

The Two Failure Cases That Produce Most Paraphrase Violations

Failure one is the lost control marking. A writer paraphrases a paragraph marked NOFORN, keeps the SECRET banner, and drops the dissemination control because the rewritten sentence no longer looks like the source. The paragraph is now marked for a wider audience than the information allows. The Information Security Oversight Office has flagged derivative marking quality as a recurring finding in its annual reports to the President, and control markings are consistently the weak row.

Failure two is the smuggled inference. An analyst paraphrases a source describing a sensor's detection range and, in the rewording, adds the phrase "which covers the northern approach." The source never said that. The added clause is an inference drawn from classified knowledge, and under 32 CFR 117.3 it is classified, but the analyst assigned no level because the sentence did not feel new. This failure scales. A single inferred clause in a widely circulated program document can propagate into briefings for years.

Both failures share a root cause. The writer treated paraphrasing as a writing task and stopped consulting the source once the draft read smoothly. The regulation's four verbs exist to prevent exactly that drift, and the marking conventions exist so a reviewer can catch it.

Cost makes the point concrete. A single unauthorized disclosure requires an incident report, a damage assessment, and a classification review that, by the timelines in DoD Instruction 5200.01, consumes staff hours across security, legal, and program offices. The arithmetic is not published as a standard figure, so compute it from your own office's incident log rather than trusting a number from an article.

Derivative Authority, Training Cycles, and Who May Paraphrase

Derivative classification authority is not the same as a clearance. Under 32 CFR 117.13, contractors must provide derivative classification training before a person may derive, and refresher training follows at least every two years. Original classification authority is different again and rests with officials designated in writing, a much smaller population.

The training requirement exists because paraphrasing depends on judgment. A cleared engineer with no derivation training may recognize classified content but has no mandate to restate it. Once trained, that engineer may paraphrase, copy, restate, and generate, provided each act maps back to a classified source and the source's markings are carried forward.

Training cycles interact with document life. A paraphrase marked with a 25-year declassify-on date will outlive the writer's refresher cycle by more than a decade. That is why the "Declassify On" line must be derived from the source's instruction rather than invented at the keyboard. The mark is the durable record; the writer is temporary.

Contractors holding facility clearances should confirm their derivation training records against the current 32 CFR 117.13 requirement, since the 2021 manual replaced the 2006 NISPOM and changed the training provisions. Facility security officers control those records, and a lapsed record is a finding waiting to happen.

Paraphrasing Versus Plagiarism, Summary, and Rewriting: Terms People Confuse

Plagiarism is an attribution offense against authorship. Derivative classification is a protection offense around national security information. A writer can avoid plagiarism completely and still commit a derivative violation, because the harm protected against is disclosure, not credit.

Summary is a length operation. It compresses a source, and in compression it often drops classified details, which is why summaries sometimes grade as unclassified. The test is not word count. The test is whether the national security information survives. A two-sentence summary that names a program's capability is a derivative paragraph wearing a shorter coat.

Rewriting for style is the confusion closest to home. Editors rewrite sentences for clarity all day without security consequences when the text is unclassified. Move the same habit onto a classified draft and the editor has performed derivative classification, whether or not they hold authority. Editorial changes to classified text need the same marking discipline as original drafting.

Academic paraphrase training, which teaches students to change structure and vocabulary to avoid copying, actively pushes writers toward the error. It trains the exact substitution behavior that 32 CFR 117.3 defines as derivative. The fix is a habit swap: in classified work, consult the source after rewording, not before.

What a Paraphrase Mark Actually Contains: Portion Marks, Source Lines, and Controls

A compliant paraphrase carries three layers of marking. The portion marking sits at the start of the paragraph or bullet, in parentheses, at the source's level. The classification authority block sits at the document level and names who classified the document, the source it derives from, and when it declassifies. The dissemination controls ride alongside, in the same place the source put them.

The "Derived From" line is where paraphrasing shows its paperwork. It names the source document, not the writer's memory. "Derived From: [source document title and date]" tells a reviewer exactly which classified source the restated sentence came from. Without it, the document cannot be reviewed and cannot be declassified on schedule.

Declassify-on instructions deserve their own attention. If the source says "Declassify on: 20450301," the paraphrase carries the same date. If the source says "Declassify on: OADR," the paraphrase carries OADR. Writers sometimes substitute a round number that feels safer, and the substitution breaks the declassification record.

Portion marking of paraphrased bullets in a list is a frequent gap. Each bullet that conveys classified information needs its own portion mark even when the banner covers the page. Reviewers scanning a page see the banner first and the portion marks second, and a missing bullet mark is the finding.

Why the Definition Survives Technology Change and Where to Verify It

The definition in 32 CFR 117.3 has survived every drafting technology from carbon paper to collaborative editing platforms because it attaches to meaning, not medium. A paraphrase typed into a shared document, pasted into a briefing slide, and restated in a meeting all carry the same classification. Technology changes the surface and leaves the test intact.

Verification follows a fixed path. The current manual is published in the Code of Federal Regulations as 32 CFR Part 117, and the Department of Defense's counterintelligence and security directorate maintains the official copy. Contractors should also consult their facility's classification guide and the source document's own markings, since the guide can be more restrictive than the regulation's floor.

Stable knowledge has an expiration habit worth noting. The manual was reissued in 2021, and revisions arrive through the Federal Register. A paraphrase marked today under the 2021 text stays valid if the source stays valid, and the declassify-on line records which rules applied. Do not refresh old marks because the regulation changed.

When in doubt, route the question to your facility security officer before release. That sentence is the practical version of the whole definition: paraphrasing is permitted, valuable, and routine, and it stops being any of those things the moment the source leaves your sight.

FAQ

Does changing every word still count as derivative classification? Yes, when the national security information survives the rewording. The four verbs in 32 CFR 117.3 include paraphrasing and restating alongside copying, and the test is meaning rather than vocabulary. A sentence rebuilt from synonyms still inherits the source's level, duration, and control markings. Writers who swap words to avoid copying markings have misread the regulation.

Who is allowed to paraphrase classified information? Only a person with derivative classification authority, which requires training before deriving and refresher training at least every two years under 32 CFR 117.13. A security clearance by itself does not confer that authority. An uncleared editor or writer who restates classified details has committed a spill rather than a derivative act.

What happens if I paraphrase a NOFORN paragraph and drop the control marking? The draft becomes a reportable marking error at minimum and a potential unauthorized disclosure if it circulates. Control markings are the most frequently lost element during rewording, because the rewritten sentence stops resembling the source visually. Route the draft to your facility security officer before distribution, and expect a damage assessment if it already went out.

Is paraphrasing in derivative classification the same as plagiarism? No. Plagiarism concerns attribution and authorship, while derivative classification concerns protecting national security information from unauthorized disclosure. A writer can avoid plagiarism entirely and still violate derivative marking rules. The two regimes run in parallel, and academic paraphrase habits actively work against the classification habit.

Can I paraphrase two unclassified facts into one classified conclusion? Only an original classification authority can assign a level to a newly drawn inference. If you combine unclassified facts and the combination reveals something classified, you have generated new analysis rather than derived from a source. Stop and route the conclusion to an original classification authority instead of assigning a level yourself.

How long does a paraphrased paragraph stay classified? Exactly as long as its source instruction says, no longer and no shorter. The "Declassify On" line carries forward from the source, whether that is a specific date, an event, or OADR. Writers who substitute a rounder or safer-looking date break the declassification record, and reviewers will catch the mismatch against the source.

Does the 2021 NISPOM change how paraphrasing is treated? No. The May 18, 2021 reissue of the National Industrial Security Program Operating Manual kept the four-verb definition, including paraphrasing and restating, and moved the training requirements in 32 CFR 117.13. Contractors who trained under the 2006 manual should confirm their records meet the current refresher cycle. The definition itself is stable across both editions.

What do I do if I cannot find the source a paraphrase came from? Treat the paragraph as orphaned and hold it out of circulation until a reviewer resolves it. Without a source document to name on the "Derived From" line, the document cannot be properly marked or declassified on schedule. Facility security officers handle orphaned derivations as review items, and the sooner the paragraph surfaces the smaller the exposure.

This article is general educational information about classification marking practice. It is not a legal opinion, a security determination, or a substitute for your facility's classification guide or your facility security officer's direction. Classified marking decisions belong with trained derivative classifiers and the authorities named in 32 CFR Part 117, and any question about a specific document should go to those officials before release.