Position paper european commission




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Article 3 (1)) would signify, that Member States that have not yet achieved the ideal circumstances concerning e.g. internet connection in some regions, can be held legally accountable for this, even if the cause of the issue is lack of resources. We do not believe that such a regulation reflects the goals of the Union, nor does it effectively protect the autonomy of individuals.

While Article 4 mentions a central point and source of concern for the Union nowadays, that being the internal and external security of the EU and its Member States, we wish to point out that this issue was discussed and resolved with the so-called NIS Directive2, aimed at strengthening Europe’s cyber resilience, which was adopted in July 2016 and will come into full force in November 2018. We believe that the Directive, by proposing specific measures and providing access to expertise to the Member States, will be significantly more effective in this regard.

Additionally,


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Position paper european commission

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