I am fully aware that this is an unpleasent critique.

However when facts become less important than appearance and non-questioned assumptions, we end up with bad regulation and bad actions.

When we have a report that assume that security and privacy is taken care of (without any assertion as to the realism or how to do it), it is not MY consideration of what is important, but the report that focus on issues but fail to include the key aspects with impact on what is analysed.

I have pointed out several key points for EU policy to be included. Examples

a) eSignature has to be extended to eIdentity - the primary purpose is to AVOID identification serverside (never adding value and always dis-empowering) - for security reasons - companies CANNOT secure their customer relationships from system profiling and abuse by commercial infrastructure. Instead we should validate the specific aspects of identity and create transaction-specific proofs (e.g. accountability involves a mechanims where e.g. a judge post-transaction COULD link data to the accouutnable citizen without anyone else CAN - this is necesary in all transactions where one stakeholder has risks from other stakeholder failling to abide to an agreement).

b) SEPA - Digital Cash must be enabled and be legal tender to prevent the systemic lock-in and lack of data security in payments.

c) Data Retention, Anti-money laundering, etc. are BAD one-size-fits-nothing regulation without security or economic nuances.

d) Net Neutrality. Communication standards are abused by industry associstions to create kartel structures in order to prevent competion and enforce a kommercial gatekeeper in control and thus systemic dis-empowerment - e.g. GSM. NFC, EMV, PKI, SAML, Car-to-car etc. Even worse with bad proriteary structures with de facto control such as Facebook, Iphone, Google profiling etc.
Technology as BAD and ENFORCED kartel regulation is a new problem, that urgently require attention.

e) We need to move bioemtrics to chip-on-card instead of destroying the use of biometrics and passport with the security destructive passport designs presently being inforced BY EU on citizens. There is not revocation or recovery mechanisms, when authorities realise that this structure create all the elements for Biomtrics-based identity theft. etc.

f) EU needs to stop dis-empowering citizens through regulation and bad security while trying to "appease" or create "confidance" with some soft addon regulation like Data protection regulation that cannot be enforced. There MUST be an allignment that focus on prevention instead of trying to manage the abuse following the dis-empowerment of mis-understood "security" in the form of surviallance of citizens and companies.

It is not a simple question - we have manu kinds of problems and many who benefit from these distortions in both commercial infrastructure, bureaucratic government and of course criminals whose life is made easier by all the unsecure systems.