of developing a comprehensive therapeutic strategy, an accurate diagnosis, and an accurate treatment. Especially when it comes to neurology, dentistry, and psychiatry, no assistance is provided at all as such services are not available on Kos. Lastly, according to clients’ reports and Equal Rights’ experience, referrals to the hospital in Kos Town do not take place or do not take place in a timely manner. b. Mental Healts The mental health care standards in the PRDC on Kos are not in line with Article 19 RCD, Article 47 (7) IPA, and Article 31 (3) Law 3907/2011. These standards, laid down in Greek and European law, have been further specified by ECtHR jurisprudence which clearly states that a specific and individualised assessment of needs has to take place298 and that there has to be a timely examination and diagnosis as part of a comprehensive therapeutic strategy in contrast to a “therapeutic abandonment”.299 Mental health care has to go beyond basic care.300 It has to be prompt and timely and respect the right to privacy enshrined in Article 8 ECHR. None of these requirements are met with mental health care provided in the PRDC. Clients reported that they have essentially no access to mental health care and that they lack information on the services provided. Furthermore, interviewees report long waiting times to see a psychologist or social worker. Even if an appointment is provided, it is not part of a therapeutic strategy. It merely constitutes a single appointment which is not necessarily followed up by another appointment, an in-depth assessment of the psychological needs, or a proper diagnosis. This is not surprising, as there is no interpretation available, making a proper assessment of the detainees’ mental state factually impossible. Hence, the mental health care in the PRDC amounts to a factual “therapeutic abandonment”, further aggravating the existing mental health problems that detainees already have. c. Covid-19 Measures The Covid-19 measures within the PRDC on Kos raise serious legal concerns. According to ECtHR jurisprudence, states have a positive obligation to protect the detainees’ health. Even if the ECtHR grants states a margin of appreciation, some measures must be taken and these measures must adequately prevent the spread of infectious diseases.301 The vaccine program for asylum seekers began in June 202,302 and by 28 October 2021 over 60% of the population in Greece had received at least one dose of the vaccine.303 However, the administrative authorities in the PRDC have not started vaccinations yet, although people detained in the PRDC clearly fall into the category of vulnerable groups more likely to contract and spread Covid.304 Furthermore, there is no state-run COVID-19 information policy in the PRDC, aggravating the spread of misinformation among detainees (such as the rumour that when detainees register for the vaccination, their detention period may prolong) which reduces the detainees’ willingness to receive a vaccination. 298 299 300 301 302 Murray v. the Netherlands [GC], § 106; Herczegfalvy v. Austria, § 82; Aerts v. Belgium, § 66. Strazimiri v. Albania, 2020, §§ 108-112. Rooman v. Belgium [GC], § 209. Poghosyan v. Georgia and Ghavtadze v. Georgia. Benjamin Bathke, Greece starts vaccination campaign at facilities for asylum seekers, Infomigrants (04 June 2021), available at: https:// bit.ly/2WXJtUj. 303 As of 12 August 2021, see https://ourworldindata.org/covid-vaccinations?country=OWID_WRL. 304 World Health Organization, Regional Office Europe, FAQ: Prevention and control of COVID-19 in prisons and other places of detention, available at https://bit.ly/3l07frm. 64 DETENTION OF MIGRANTS ON THE ISLAND OF KOS