arrived people […] until their registration procedures with the police and First Reception have been completed. According to Greek law, this de facto detention period […] is not supposed to exceed 25 days, […] (and) only by way of exception. During this period, […] (v)ulnerability assessments are not conducted, leaving pregnant women, unaccompanied minors, people with medical conditions or SGBV survivors without the proper care they need and are legally entitled to. […] Since the opening of the CCAC […] one state-appointed doctor worked inside the medical unit of the facilities, for one month, between October and November 2023. […] As there are no health workers present in the facilities, their medical needs are assessed by police officers or security employees, who are not qualified to do so. Any person who resides in the CCAC and especially those who are de facto detained, have insufficient and inconsistent access to medical care. Additionally, due to the absence of healthcare and individual vulnerability assessments, asylum seekers with communicable diseases risk remain undetected or unable to seek medical treatment for several weeks after arrival which causes a serious risk of contagion”607. Moreover, according to a joint submission of GCR & OXFAM to the European Ombudsman in March 2023: “[..] there is currently no designated staff on site for vulnerability identification or assessment. This means that vulnerabilities are currently not taken into account during the interview or in the decisionmaking on individual cases. Moreover, it means that individuals with vulnerabilities, including GBV survivors, torture survivors, traumatised individuals, those with PTSD, people in need of psycho-social and mental health support, as well as those with serious medical conditions, chronical diseases or particular needs are not offered the support or procedural safeguards that they have a right to. The Medical Unit of the CCAC has no doctor and lacks the required specialised medical staff to examine alleged minors and assess their age. Regarding Victims of Torture (VoTs), […] the reception state, is required to provide specialized staff as well as continuous specialized training to public staff. However, there is currently a lack of specialist staff in the Medical and Psychosocial Unit of the CCACs’ Reception and Identification Service (RIS) and the islands’ General Hospitals. Therefore, there currently is no systematic identification and assessment of a VOT and/or GBV, contrary to the Istanbul Convention’s provisions and Istanbul Protocol on procedural safeguards”.608 Kos: Shortcomings related to understaffing were also reported in 2023 in the RIS of Kos, as there was no EODY doctor, nor a psychologist, resulting in medical services currently being provided by an army doctor and medical missions of the Hellenic National Public Health Organization medical teams deployed from other CCACs609. Thus, vulnerability assessments were signed in mass when a visitor doctor from EODY arrived at the RIS. Based on GCR’s observations, only obvious vulnerabilities were identified (e.g., pregnant women, elderly people); while victims of GBV or Female Genital Mutilation were often identified as vulnerable by RIS only after issuance of a first instance negative decision on their asylum application. Moreover, according to a joint submission of GCR & OXFAM to the European Ombudsman on March 2023: “In […] Kos, a doctor from Leros island occasionally visits the facility. This makeshift solution jeopardizes residents’ health, as there is no one to provide medical first aid or to assess daily health risks in the CCAC. […] Moreover, the lack of full-time medical staff hinders adequate and timely vulnerability and age assessments, procedural safeguards that have a significant impact on the outcome of individuals’ asylum procedure”.610 On 12 December 2023, in a case represented by GCR before the ECtHR, the Court -pursuant to Rule 39 of the Rules of the Court- granted Interim Measures with regards to two Afghan women and their five accompanied minor children residing at the CCAC of Kos in absolutely inadequate conditions. The Court 607 608 609 610 Joint Statement of 20 civil society organisations, NOT AGAIN IN 2024 – Call for upholding human rights in the Samos Closed Controlled Access Centre, 31 January 2024, pp. 1-4, available at: https://tinyurl.com/3dxhybnk. GCR / OXFAM, Inquiry on Fundamental Rights in the EU-funded Migration Facilities on the Greek Islands / Case OI/3/2022/MHZ, Joint submission to the European Ombudsman, p. 15, available at: https://tinyurl.com/bd4wpe3d. Information provided by a representative of the Administration during the GCR mission to Kos on 6 December 2023. GCR / OXFAM, Inquiry on Fundamental Rights in the EU-funded Migration Facilities on the Greek Islands / Case OI/3/2022/MHZ, Joint submission to the European Ombudsman, p. 13, available at: https://tinyurl.com/bd4wpe3d. 132