Yes, it is important to be aware that security is always relative to a threat model, and at times it can lead to confusion when threat models are not made explicit. That does not mean, though, that it's necessarily wrong to imply a sensible threat model in a given context, and to just call something "insecure" without any further explicit qualifications if it does not protect against a reasonable minimal threat model that essentially everyone essentially always has to face.
Also, it's questionable whether you can call the NSA's mass surveillance a passive attack, given that QUANTUM INSERT exists and was used, in order to attack foreign communications infrastructure.