lifting the administrative detention and subjecting the detainees to reception and identification procedures at a competent RIC’. A geographical restriction is also systematically imposed on every newly-arrived person on the Greek islands, initially by the police and the Head of the Asylum Service, imposing the obligation to remain on the islands. This is separate to the decision of the Governor of the RIC imposing a de facto detention period of up to 25 days, within the premises of the respective RIC (so-called “restriction of movement”). For more details on the geographical limitation on the Greek Eastern Aegean Islands, see Reception Conditions, Freedom of movement and Identification. The CCACs’ dominant trait is its prison-like environment. The sites are highly securitised and fortified with multiple layers of fencing around the sites’ periphery and around each accommodation section within the centre and private security and police personnel guard each fenced section. The Greek authorities maintain that internal fencing is required in order to minimise risks for vulnerable migrants, such as minors or those at risk due to their sexual orientation and/or gender identity. As the European Ombudsperson, points out ‘[t]he external and internal fences may [..] also have negative health (including mental health) consequences on vulnerable migrants and those who have fled difficult circumstances. It is questionable how respect for human dignity and protection of the best interests of the child and of vulnerable individuals can be ensured if residents are forced to stay in such an environment.238 (See Reception Conditions). Moreover, unaccompanied children, are prohibited from exiting the “SAFE AREA”, which is a fenced container section of the CCACs guarded by security personnel and where they are subject to “restriction of liberty” until their placement and transfer to shelters for minors. During 2023, the waiting period for the placement of UAMs in a ‘restriction of liberty status’ in CCAC to shelters for minors was short. According to official data available, the average waiting time for the placement of UAMs in ‘restriction of liberty’ in the RIC/CCACs was 7.7 days.239 Transfers from the CCAC to shelters for minors may be conducted with delay. Concerns have also been expressed about the absence of creative activities during the day and confinement in a non-child friendly, prison–like environment, especially when the waiting time for placement has increased.240 Since the implementation of the EU-Türkiye Statement, all newcomers are registered by the RIS.241 During 2023, due to the severe understaffing of the RIS, coupled with the increase of arrivals and the insufficient number or absence of medical staff, there were recorded delays and significant shortcomings or lack of provision of medical and psychosocial assessment/services, as required by law.242 (see also Identification). The registration of initial asylum claims on the islands was conducted by the RIS. Concerns were raised regarding wrongful registration of newcomers’ data, especially the incorrect recording of the date of arrival, incorrect records were often found in the dates of birth, names spelling and country of origin.243 238 239 240 241 242 243 European Ombudsman, Decision in strategic inquiry OI/3/2022/MHZ on how the European Commission ensures respect for fundamental rights in EU-funded migration management facilities in Greece, 7 June 2023, https://tinyurl.com/3v82dswd. Data made available to GCR by the General Secretariat for Vulnerable Persons & Institutional Protection of the MoMA, as of 04 March 2024. RSA, What is happening today in the refugee structures on the Aegean islands, available at: https://tinyurl.com/3dffraet. Article 8(2) L 4375/2016 as amended by Article 116(3) L 4636/2019, Article 9 L 4375/2016 as amended by Article 39 IPA; see also, Ministerial Decree No 1/7433, Governmental Gazette Β 2219/10.6.2019, General Operation Regulation of the RICs and the Mobile Units of Reception and Identification. Joint CSO Statement, Unlawful detention and worsening conditions: Over 4,000 asylum seekers unlawfully detained on Samos and Lesvos, 19 September 2023, available at: https://tinyurl.com/3w8natsr. Equal Rights Beyond Borders, HIAS Greece & RSA, Tthe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/3AtPXLu, 13. 61