C. Safeguarding human rights The challenge of the refugee crisis and not of all the administratively detained third-country nationals who are also held in police station cells.174 • T he living conditions of the detainees vary depending on the sites. The usual shortcomings are identified in cleanliness, heating, quality and quantity of food and personal hygiene products. Open air exercise (as well as entertainment activities) is very short in certain Pre-removal Centers and non-existent in police station cells. At the hotspots there are also structural problems (sewerage, etc.), while a general matter is the lack of security in their interior.175 • T here is provision for the basic services of doctor, psy- chologist, social worker and interpreter in the Detention Centers, but they are not provided because they depend on tenders which have long time gaps. • It should be noted that in every detention site, the detain- ees were deprived of basic interpretation services. The lack of providing adequate and consistent information to the detainees, in a language they understand, on the legal basis, development of the detention process and their rights is one of the biggest problems in each detention facility. At the same time, it is a basic infringement of the fundamental rights of the detainees and a factor of legal uncertainty, which causes a chain reaction both for them and the detention services. • T he facilities for detention during the process of forced removal from the country are mostly inappropriate when it comes to the specifications of the Return Directive, a typical example being the cells of the Aliens Division of Attica, in the case of returns, or the police station cells of 174 The frequent use of Police Stations of Attica is notifiable, due to the overcrowding of the Aliens Police Division of Attica in the Pre-removal Center of Tavros (characteristically, on 7.6.2016 there were 114 men held in Police Stations of Attica). The fact that the alimentation costs of the Pre-removal Centers have no sufficient funding also appears to lead to the practice of the administrative detention of third-country nationals in police station cells, despite the Hellenic Police’s commitment to the contrary. On the day of the Ombudsman’s visit to the Aliens Police Division of Thessaloniki (21.10.15) there were 95 people in total held, 69 of which at the Cells of the Division and the others in the 4 “Illegal Immigration Prosecution Departments” of the Division, given the inability of the Pre-removal Center in Paranesti to receive these third-country nationals. The Ombudsman insists on the Hellenic Police’s commitment for detention in the Pre-removal Centers with the specifications of Law 3907/2011. It further observes that the period of detention in the cells of the Aliens Police Division of Thessaloniki - which lasts on average 2-3 months (while there are cases of detention exceeding 6 months, e.g. 5 people on 21.10.15) for most third-country nationals, except those with Albanian origin - is not short, in combination with their number which has the characteristics of a mass detention (69 people in the Division’s cells). In 2016 as well, the cells of the Aliens Division of Thessaloniki were regularly used for the detention of the thirdcountry nationals to be returned (case 216963/2016). 175 In more detail, as regards the living conditions, see Annual Report of the Greek Ombudsman 2015, pg. 151 et seq. 58 the islands in the case of readmissions into Turkey. •M  inors continue to be held in Pre-removal Centers or po- lice stations - although for shorter periods in 2016 - waiting for the National Center for Social Solidarity (EKKA) to find places in guest houses.176 • T he lack of a constant financing flow from the relevant EU fund creates problems in the provision of the necessary goods and services at the detention centers (see Chapter E1.2.). The problem of the management of mixed flows, consisting of migrants and asylum seekers, on the south-east borders of the EU, is what is underlying and overshadows the issue of detention through time. However, the Ombudsman had noted up to 2015, that administrative detention contributes to the problem and not the solution, considering the large number of detainees who were deprived of their liberty for a series of months, in combination with the insecurity of the third-country nationals about their future.177 This finding was in fact reinforced by the fact that the maximum limit of 18 months of detention in view of a return, which was imposed by law, was not observed (Article 30(5) to (6) of Law 3907/2011) and Directive 2008/115/EC (Article 15(5) to (6)). The Ombudsman had noted that under no circumstances is the circumvention of this limit178 legal, and the relevant internal instructions of the Ministry of Public Order had to be amended, with the repeal of the acceptance of opinion No. 44/2014 of the Legal Council of the Hellenic State.179 1.2. Developments in the implementation of administrative detention in practice 2015 as milestone year for the change of the policy on administrative detention In 2015 there were two very important developments in relation to the procedures of detention of third-country nationals to be returned: 176 See op. cit., Chapter A3 regarding the treatment of minors. 177 “The Hellenic Police does not have the facilities and the know-how to ensure adequate guarantees for the deprivation of personal liberty in mass spaces, despite its continuous efforts for improvement of the conditions at the pre-removal centers” (http://www.synigoros.gr/?i=human-rights.el.maziki-kratisi-allodapon.118221). 178 CJEU Katzoev C-457/09, Bashir Mohammed Ali Mahdi C-146/14. 179 See Greek Obmudsman’s Annual Report 2014, pg. 153.