None of the decisions made under the “low profile detention scheme” include an individualized assessment and sufficient reasoning. In particular, as mentioned above, the first, temporary detention order contains, at best, vague and stereotypical wording stating that the detention is ordered because the alien is "based on the general circumstances, considered a flight risk.” Similarly, the deportation decision “in view of a readmission procedure” repeats the same generic phrase, despite explicit reference to L. 3907/2011 (the Law that transposes the EU Return Directive), which provides that the “detention decision must contain factual and legal reasoning” and that for a third-country national to be considered a flight risk, “there must exist reasons based on objective criteria” (Art. 30(2) and Art. 18(g) of L. 3907/2011 respectively). Further, the “asylum detention” decision refers to the recommendation of the Head of Lesvos RAO for the continuation of the detention of the asylum seeker. However, in 34 of the 40 cases we have represented, this recommendation was not included in the applicant's detention file. Consequently, the migrant's legal representatives cannot obtain knowledge of the content of this recommendation when they request copies of the detention file from the Police, but they must also apply for access to the administrative file held by Lesvos RAO. Although the recommendation of the Head of Lesvos RAO for the continuation of the asylum seeker’s detention states that “there are reasonable grounds to believe that the applicant is making the application for international protection merely in order to delay or frustrate the enforcement of a return decision,” these grounds are not specified in the recommendation. What is more, in many of the cases represented by our organization, the applicants, as can be seen in their asylum registration forms, had articulated, during their registration with Lesvos RAO, clear grounds for international protection (such as persecution on the basis of their sexual orientation or political activities). In addition, the recommendation of the Head of Lesvos RAO, expressly states that the continuation of detention is recommended only "if it is considered that alternative measures such as those referred to in Article 22 (3) of Law 3907/2011 cannot be applied” and "provided that possible lack of suitable space and the difficulties of securing decent living conditions are taken into consideration.” However, the detention decision issued on the basis of this recommendation lacks reasoning, as it does not consider any alternatives to detention nor does it assess the appropriateness of the detention facilities in light of the obligation to ensure decent living conditions. Welcome the stranger. Protect the refugee. | 12