There are also contradicting views between the GAS and the RIS as to when the identification procedures are completed, with the RIS until November 2022 taking a more restrictive interpretation of when someone is identified (on issuance of the red card), perhaps in an attempt to justify the detention of applicants in the CCAC for longer. The practice of the GAS conducting full asylum interviews without applicants being issued a red card raises serious concern as to the RIS’s justification that they could detain every asylum applicant for "identification purposes" until they receive their card. If such a claim is accepted, then the GAS is frequently interviewing asylum seekers before they have been properly identified. © Romy van Baarsen_ Romy Aimee Photography From April 2022 until December 2022, I Have Rights found that on average people were issued a red card after 12 days; however, 6% of beneficiaries did not receive their red card for over 25 days and in these cases, despite the presentation of a police note with a registration date from 25 days preceding, guards routinely refused to allow individuals to exit the CCAC. Frequently, individuals were invited for their substantive asylum interview before the 25-day restriction had passed and before they had received a red card, depriving them of the right to receive legal advice or counselling.[155] The effect of such de facto detention, whether it be until issuance of the red card or upon completion of the full registration interview is not proportionate to either stated aims or purposes. As a result of this measure, people are deprived of access to legal advice and counsel as well as community and psycho-social services. [155] Directive 2013/33/EU of the European Parliament and of the Council of 26 June 2013 on laying down standards for the reception of applicants for international protection (recast). Article 12(3). Page 45