that there is “conflicting evidence about the accuracy and reliability of the available methods of age assessment, which may generate significant margins of error”.717 In practice, the lack of qualified staff within the reception and identification procedure and shortcomings in the age assessment procedure in the RICs undoubtedly have a spill-over effect on the asylum procedure, as the issuance of an age determination act by the RIS precedes the registration of the asylum application with the Asylum Service. While registration of date of birth by the Hellenic Police could be corrected by merely stating the correct date before the Asylum Service, this is not the case for individuals whose age has been wrongly assessed by the RIS. In this case, in order for the personal data, e.g., age, of the person to be corrected, the original travel document, or identity card should be submitted. Additionally, a birth certificate or family status can be submitted, however, these two documents require an apostille stamp,718 which in practice is not always possible for an asylum applicant to obtain. In practice, however, employees in the RAOs sometimes corrects the age of the person on the basis of documents without apostille. Alternatively, according to the law, the caseworker of the Asylum Service can refer the applicant to the age assessment determination procedure in case that reasonable doubt exists as to their age.719 In this case, referral to the age assessment procedure largely lies at the discretion of the Asylum Service caseworker.720 2. Special procedural guarantees Indicators: Special Procedural Guarantees 1. Are there special procedural arrangements/guarantees for vulnerable people? Yes For certain categories No ❖ If for certain categories, specify which: Article 1-λγ of the Asylum Code: “children; unaccompanied children; direct relatives of victims of shipwrecks (parents, siblings, children, spouses); disabled persons; elderly; pregnant women; single parents with minor children; victims of human trafficking; persons with serious illness; persons with cognitive or mental disability and victims of torture, rape or other serious forms of psychological, physical or sexual violence such as victims of female genital mutilation.” 2.1. Adequate support during the interview According to Article 72 (2) Asylum Code, where applicants have been identified as applicants in need of special procedural guarantees, they shall be provided with adequate support in order to be in the position to benefit from the rights and comply with the obligations in the framework of the asylum procedure. The Asylum Code provides examples of forms of adequate support that can be granted in the procedure. More specifically:721 ❖ The possibility of additional breaks during the personal interview; ❖ The possibility for the applicant to move during the interview if their health condition so requires; and ❖ Leniency to minor inconsistencies and contradictions, to the extent that they relate to the applicant’s health condition. National legislation expressively provides that each caseworker conducting an asylum interview shall be ‘trained in particular as of the special needs of women, children, and victims of violence and torture.’ 722 717 718 719 720 721 722 See, inter alia, World Medical Association, WMA Statement on Medical Age Assessment of Unaccompanied Minor Asylum Seekers, October 2019, available here. Decision of the Director of the Asylum Service No 3153, Gov. Gazette Β’ 310/02.02.2018. Article 80(3) Asylum Code. For a detailed description of the problems related with the age assessment on Lesvos Island, see Fenix, A Child’s Best Interests? Rights Violations in the Absence of Presumption of Minority, 13 October 2022, available at: https://bit.ly/3ACqq2t. Article 67(2) IPA. Article 82(12)(a) Asylum Code. Also, according to the Concluding observations on the combined eighth and ninth periodic reports of Greece of the Committee on the Elimination of Discrimination against Women “training immigration officers on gender-sensitive interviewing techniques, and that gender-based violence against women is recognized as a protection ground”, available here, 13. 144