depending on the time period. As a result, and since they cannot access private lawyers due to their detention and lack of financial means, “low profile” detainees often do not have access to an effective legal remedy. Concerning new legislation on international protection On 15 October 2019, the Ministry of Citizen Protection published a new draft legislative proposal on International Protection, which was submitted for public consultation until 21 October 2019, and adopted by the Greek Parliament on 1 November 2019. The new Law 4636/2019,21 which will enter into force on 1 January 2020, introduces a series of worrying changes that are of particular relevance to the “low profile detention scheme.” In particular, it allows for the expansion of the detention of asylum seekers and the extension of the detention periods, while, at the same time, removing existing procedural safeguards. The new Law foresees the detention of applicants for international protection, even if they have applied for asylum while still at liberty. At the same time, it abolishes the automatic judicial review of the detention decision, which continues to be issued by the Police authorities, and foresees that only the decisions of prolongation of the detention will be subject to automatic judicial review. However, the asylum seekers and their legal representatives will not have the right to be heard in court in the framework of the automatic judicial review proceedings. The need for a prior recommendation for the detention by the Asylum Service is also abolished. The Law extends the maximum period of both the initial detention and the prolongation of detention to 50 days respectively. Although the maximum detention limit of 18 months is maintained in the new law, pre-removal detention periods will not be taken into account when calculating the maximum asylum detention time. Considering that the maximum limit of the pre-removal detention is also 18 months,22 this risks extending the maximum detention period to 36 months. 21 Greece: Law 4636/2019 on International Protection and other provisions, 1 November 2019, https://www.asylumineurope.org/sites/default/files/resources/internationalprotectionact.pdf 22 L. 3907/2011, Art. 30(6), transposing Art. 15(6) of Directive 2008/115/EC of the European Parliament and of the Council of 16 December 2008 on common standards and procedures in Member States for returning illegally staying third-country nationals. Welcome the stranger. Protect the refugee. | 20 20