unaccompanied and separated children, families with small children and notably single mothers
with children, pregnant women or persons with serious health conditions, as well as survivors of
torture or other forms of ill-treatment, trafficking in human beings or sexual and gender-based
violence. It appears that far too little is being done by the Greek authorities to identify such
persons”. 114
______ (2) Mainland
Greek law provides that healthcare units in mainland camps must carry out vulnerability
assessments. 115 In practice, however, the staff at mainland camps are not able to record a
vulnerability or change the vulnerability status of a resident where this has previously been done
by authorities in a RIC or CCAC. Thus, if vulnerability is not properly assessed during reception
and identification procedures, it cannot be subsequently recorded by camp authorities and
applicants cannot update their Foreigner’s Health Card or their case file in the asylum system
database.
MIT and RLS’s 2023 research showed that all interviewed people who underwent screening in a
RIC without being represented by a lawyer were inadequately informed of their right to
specialised support due to a vulnerability.116 71% of respondents said that they were not asked if
they had a vulnerability. As a result, vulnerabilities without obvious physical indicators were more
likely to go undetected. 117
The lack of a uniform vulnerability procedure has also been raised by lawyers, effectively leading
to a two-tier system where applicants who are represented by a lawyer receive preferential
treatment. 118 In two cases, one concerning a single pregnant woman with a child, and another
case of a single mother with mental health challenges, where both were represented by a lawyer,
this resulted in the prioritisation of their case. Their registration happened either on the same day
as entry to the RIC or the following day, and the applicant was released immediately following
registration. 119
b) Provisions for vulnerable people
______ (1) Samos
In 2023 and 2024, the European Court of Human Rights granted Interim Measures in three cases
concerning the inhuman and degrading treatment of vulnerable applicants in the Samos CCAC.120
For example, in the case of H.T. and M.T v. Greece, the applicants, a highly vulnerable single
mother and newborn baby, were de facto detained in inhuman and degrading conditions. They
were forced to share a bunk bed with an unrelated adult male. The mother was made to wear the
same clothes she went into labour in for several weeks. Additionally, they did not receive any
medical treatment and relied on others to collect food on their behalf due to fears for their safety
in the food queues where fights are frequent.
In 2023, IHR published a report on the neglectful treatment of survivors of human trafficking in the
CCAC.121 As Samos is a significant point of first entry to the EU, the CCAC is at a key site for
________________________________
114. Council of Europe. 2024. Report to the Greek Government on the visit to Greece carried out by the European Committee for the
Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 20 November to 1 December 2023. Para 138.
Available at: https://rm.coe.int/1680b0e4e1
115. Article 5(2)(a), MD 23/13532/2020, Available at: https://www.kodiko.gr/nomothesia/document/681974/yp.-apofasi-23-13532-2020.
116. Mobile Info Team. 2023. Protection Unavailable: Dysfunctional Practices and Restrictions on the Right to Asylum. Available at:
https://www.mobileinfoteam.org/ric.
117. Ibid.
118. Ibid.
119. Ibid.
120. App No. 2368/24 granted 05.02.2024, App No. 34712/23 granted 19.09.2023 and App No. 2868/24 granted 05.02.2024.
121. I Have Rights. 2023. Unidentified, unrecognised and denied support: survivors of human trafficking in the Samos Closed
Controlled Access Centre. Available here: https://ihaverights.eu/survivors-of-human-trafficking-in-the-samos-closed-controlled-accesscentre/.
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