detention centres is not standard. In that case, in few detention centres, they have restricted access to a phone booth and there have also been allegations that police deny this access (one should take into account the fact that detainees do not have sufficient or no money at all). The practice of the competent authorities, concerning the different possibilities of the detainees, varies. The lack of relevant interpretation inside the detention centres creates even more obstacles to the communication of the detainees with the authorities. Overall, the lack of information by the authorities is evident in this case. Article 30.2 of Law 3907/2011 provides for challenge of the detention order, but not for a right to free legal aid (as opposed to the provision on remedies against deportation) and yet the Greek government has not taken any steps to ensure that those detainees without resources to pay for legal aid can challenge their detention orders. Another major issue regarding this topic concerns vulnerable persons and unaccompanied minors who are subjected to the same detention practice and conditions. There is no standard identification mechanism for vulnerable groups and specifically minors. When inside the detention and as soon as the minors are identified – with the authorities' unsafe and not standard criteria- the lack of facilities for Unaccompanied Minors (UAM) where they can be hosted, as well as the lack of an effective guardianship system in Greece are two major gaps in the protection of this vulnerable group of migrants. Specifically, UAM who are apprehended without legal documents at border areas and/or within the country and are registered as minors are held in detention facilities under degrading conditions until a place at a reception centre for UAM is found. Due to the lack of sufficient specialized reception centres for minors, children may be detained for a period of up to three months in detention facilities, while the minors have no access to information, guidance and legal representation and, therefore, in most cases, no access to the asylum procedure. In the Detention Centre of minors in Amygdaleza they are held in detention even for a period of up to 2 or 3 months and after that period they are released without any referral, by the police authorities, to reception centres for UAM (GCR reports – field missions). 2. Access to a fair and effective asylum procedure The Law 3907/2011 was adopted, in order to address international protection issues in compliance with international and EU standards. Almost two years after its adoption no progress has been made in practice: neither the new Asylum Service, consisting of civil personnel nor the new First Reception Service (the competent authority for screening centres), are not yet functional. (the operation of the New Asylum Service has been postponed, until March 2013 and it is rumored that it will be further postponed until summer 2013). Meanwhile, the so called “provisional” P.D. 114/2010 which was adopted in order to restore the administrative appeals‟ procedure, providing certain procedural safeguards, (participation of UNHCR in the process, participation of two non-public servants in the three-member Appeals‟ Boards), presents serious problems. The major gap is the fact that the competence to receive and examine applications at first instance remains within the police until today. Apart from the

Select target paragraph3