3 Routine and systematic violence against migrants held in formal detention centres or under a de facto detention regime We assert that acts of violence against migrants held in Greek immigration detention is systemic, amounting to widespread human rights violations which in many cases may amount to torture or cruel, inhuman or degrading treatment. Testimonies collected by BVMN in 2022 show that 65% of respondents reported that they had been subjected to violence by authorities or witnessed violence by the authorities in formal detention facilities [18], while IHR testimonies collected report incidents of police brutality and dehumanising treatment by police within CCACs, including forced undressing and beating, insults and taunting language [19]. Lack of access to legal counselling, information and translation and legal services We assert that there is a widespread and systematic lack of access to legal counselling, information and translation and legal services within PRDCs on the mainland and in the Samos CCAC, which leaves people unable to complete their asylum procedure or appeal rejection decisions, thus endangering their access to human rights and fundamental freedoms, and appropriate protection and assistance [20]. Recommendations Ensure that the deprivation of liberty or use of detention for people on the move is only used as a measure of last resort, and in line with international and European human rights standards. Guarantee an individualised assessment is carried out to ensure that all alternative measures are exhausted prior to detaining people on the move. End the use of detention for third country nationals and asylum seekers on grounds of public order and national security and in cases where there is no reasonable prospect of removal to avoid arbitrary detention. End the formal and de facto detention of minors. Guarantee effective access to the asylum procedure without delay in detention and establish adequate access to free legal aid and translation assistance for all people in detention to challenge the legality of their detention decisions. Establish an independent detention monitoring mechanism with the mandate to independently investigate allegations of human rights violations in formal detention centres and sites where people are held in de facto detention. Ensure a clear distinction in policy and practice between reception and identification procedures and forms of administrative detention.