blurring the line between detention and the limited restriction on freed movement allowed in the Directive.22
In addition, the government is soon to adopt legislation that will codify the typology of “closed controlled”
camps.23 Instead of channelling funds for the protection of people, the EU is spending millions of euros to fund
these camps, not just condoning but enabling a model that forces people applying for protection to live behind
walls and under constant surveillance.
OBSTACLES TO IDENTIFYING AND PROTECTING VULNERABLE PEOPLE
The individual needs of applicants for international protection should be immediately assessed at the time of
arrival24 and taken into consideration by authorities determining next steps in their reception.25 In the Greek
context, “vulnerable groups” comprise children, both unaccompanied and in families; direct relatives of victims of
shipwrecks; persons with disabilities; older persons; pregnant women; single parents with minor children; victims
of human trafficking; persons with serious illnesses; persons with cognitive or mental disabilities; and survivors
of torture, rape, or other severe forms of psychological, physical, or sexual violence.26 Notably, the IPA excludes
post-traumatic stress disorder (PTSD) from the list of conditions that qualify an asylum seeker as “vulnerable.”
Over the last few years, the process for conducting vulnerability assessments has been plagued by a persistent
shortage of qualified staff27 and resources.28 The result—unreliable or incomplete examinations of individuals’
potential risks and special needs—leaves many vulnerable persons unidentified and thus without access to the
procedural guarantees and assistance they need.29 This problem is exacerbated by the use of accelerated screening and interview procedures on the islands, which risk being expanded under the proposed EU Pact on Migration
and Asylum. 30 In the past, many victims of torture, rape, or other forms of psychological, physical, and sexual
violence and abuse were only recognised as such after a second re-examination performed months after their
arrival. The same was true for women submitted to female genital mutilation and persons with severe mental
health issues.31
The new reception facilities are likely to further undermine the protection of vulnerable individuals by impeding
access to necessary services even for those who are properly identified. As described below, nongovernmental organisations (NGOs) that provide essential services will have limited access to the MPRICs and walled-off
camps.32 In addition, the remote location of MPRICs on the islands and restrictions on camp residents’ movement
will create obstacles to accessing specialised services outside of reception facilities in nearby communities.
22. Visit of Ylva Johansson, European Commissioner, to Samos and Lesbos, Greece: press conference with Notis Mitarachi, Greek Minister for Migration and
Asylum (European Commission, 29 February 2021) <link> accessed 24 August 2021, minutes 50:30 - 52:50
23. Σχέδιο Νόμου «Αναμόρφωση διαδικασιών απελάσεων και επιστροφών πολιτών τρίτων χωρών, ζητήματα αδειών διαμονής και διαδικασιών χορήγησης
διεθνούς προστασίας και άλλες διατάξεις αρμοδιότητας Υπουργείου Μετανάστευσης και Ασύλου και Υπουργείου Προστασίας του Πολίτη» (Ministry of
Migration and Asylum, 18 June 2021) <link> accessed 1 September 2021
24. Hellenic Republic Law No. 4636/2019 (1 November 2019) Article 58(2)
25. Hellenic Republic Law No. 4636/2019 (1 November 2019) Article 58(4)
26. Hellenic Republic Law No. 4636/2019 (1 November 2019) Articles 39(5) and 58(1)
27. RSA, HIAS, et al ‘The Workings of the Screening Regulation Juxtaposing proposed EU rules with the Greek reception and identification procedure’
(January 2021)
28. Country Report Greece - Identification (AIDA, 10 June 2021) <link> accessed 24 August 2021
29. MSF, RSA and Pro Asyl ‘Border procedures on the Greek islands violate asylum seekers’ right to special procedural guarantees’ (RSA, 25 February 2021)
<link> accessed 24 August 2021
30. For A Europe That Truly Protects: Joint NGO Policy Brief on the Screening Regulation Proposal (IRC, 6 May 2021) <link> accessed 24 August 2021
31. Country Report Greece - Identification (AIDA, 10 June 2021) <link> accessed 24 August 2021; Observed by practitioners of Fenix Aid (2020-June 2021)
32. Choosing Love and Justice Limited ‘Under Pressure – How Greece is Closing in on Civil Society Organisations Working with Refugees’ (27 February 2021)
page 17-20
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