Immediately after the reception and identification procedures, these persons are placed in detention in the Lesvos PRDC. If, during the reception and identification procedures, these persons are found to belong to a vulnerable group - pursuant to their medical and vulnerability screening by the National Public Health Organisation (“NPHO”, formerly “KEELPNO”, and hereinafter referred to as “EODY”)8 – they are exempted from the “low profile detention scheme.” This is because, as per Art. 60(4)(f) of L. 4375/2016, vulnerable applicants are exempted from the border procedure and, according to the prevailing interpretation of this article,9 they are therefore also exempted from the EUTurkey Statement. Thus, because the “low profile detention” is ordered with a view to expulsion, and the only return proceedings taking place on Lesvos are the readmission proceedings under the EUTurkey Statement, the administrative detention of vulnerable applicants under this scheme does not serve any legitimate purpose. Nevertheless, as per the testimonies of many “low profile” detainees, the medical and vulnerability screening tends to be hasty and perfunctory, in response to pressure from the police authorities to speedily proceed to their detention. Additionally, many have complained that they could not communicate with the medical staff of EODY due to lack of interpretation. The first detention order issued against “low profile” detainees, called a “temporary detention order,” is usually issued on the day of their arrival, but after they have already declared their “will to apply for international protection.” The unique reference number of their declaration can be found on the top left corner of the temporary detention order. This decision is issued by the Director of the Police Directorate of Lesvos and orders the detention of the third-country national "until a deportation decision is issued within three days" because “he irregularly entered the country in violation of Art. 83 of Law 3386/05.”10 It either contains no reasoning as to why the detention is considered necessary, or includes the stereotypical phrase “because, based on the general circumstances, he is considered to be a flight risk.” 8 As per Art. 14(8) of L. 4375/2016, “As vulnerable groups shall be considered for the purposes of this law: a) Unaccompanied minors, b) Persons who have a disability or suffering from an incurable or serious illness, c) The elderly, d) Women in pregnancy or having recently given birth, e) Single parents with minor children, f) Victims of torture, rape or other serious forms of psychological, physical or sexual violence or exploitation, persons with a post-traumatic disorder, in particularly survivors and relatives of victims of ship-wrecks, g) Victims of trafficking in human beings.” 9 However, as of March 2019, HIAS Greece has been informed of cases of vulnerable applicants who were returned to Turkey under the EU-Turkey Statement. 10 Art. 83 of Law 3386/05 regulates the irregular entry and exit of third-country nationals from Greece. Welcome the stranger. Protect the refugee. | 9 9