According to client reports and experiences of Equal Rights staff members, detainees are only provided with masks when they leave the facility, and police staff do not always wear masks. Due to the very limited space, it is impossible for detainees to adhere to social distancing measures. Even if a broad margin of appreciation is granted to state authorities, it is clear that authorities within the PRDC on Kos do not implement any prevention measures, not even basic measures such as distributing masks to detainees or providing them with disinfectant. The lack of a consistent prevention strategy and even very simple prevention measures is contrary to the states’ positive obligation to protect the detainees’ health. The office of the Greek Ombudsman highlighted the high occupancy rate of detention centres during the pandemic and strongly recommended the ample use of alternative measures to detention.305 However, Greek authorities have repeatedly ignored the Ombudsman’s recommendations when it comes to immigration detention. Authorities still do not adhere to a specific recommendation from July 2021 concerning the release of 19 clients of Equal Rights in the PRDC on Kos.306 5. Conditions for Vulnerable Persons The conditions for vulnerable persons also fall short of the appropriate legal requirements. In general, the authorities do not pay particular attention to vulnerable persons or provide them with special treatment, as required by the law.307 Although both the IPA and RCD require that men and women are accommodated separately,308 the facilities in the Kos PRDC are not separated by gender. While men and women are generally housed in separate containers, the living areas are not separated by gender and the container doors do not lock. Further, multiple women in this report reported that they had shared a container with male detainees at some point during their detention, normally during the initial quarantine period. This has a particularly severe psychological effect on survivors of SGBV who reported feeling fear and discomfort sharing living spaces with men. For people living with serious physical and mental illnesses and survivors of serious forms of violence, the living conditions in the Kos PRDC similarly fail to meet basic legal standards, and the inadequate medical care in the PRDC was among the most serious problems highlighted in interviews. As discussed above, asylum seekers are generally not provided with “necessary health care” 309 in the Kos PRDC, especially given that there has not been a doctor there since July 2021. The complete lack of healthcare, even for vulnerable persons, means that people with serious medical issues often go long periods without treatment or medical attention. This likely raises an issue under Article 3 ECHR given the state’s responsibility to care for people entirely under its control. As for minors, the conditions in the Kos PRDC quite clearly fail to meet even the most basic standards established by EU, Greek, and human rights law. There are no age-appropriate facilities inside the Kos PRDC, including play areas, educational spaces and materials, family-only facilities, or enough beds for large families. This not only raises an issue under the RCD and IPA, but the ECtHR has also emphasized numerous times that, in the rare instances where states can detain minors, they may only do so in detention centres that 305 Ombudsman of the Citizen, Letter no. 38/27-03/2020 to the relevant Ministers (27 March 2020), available at https://bit.ly/3zOGFrt. 306 Equal Rights Beyond Borders, Greek Ombudsman calls for Release of 19 Persons who are Unlawfully Detained in the Pre-Removal Detention Centre on Kos (3 August 2021), available at: https://bit.ly/3BPvn6X. 307 Art. 16 (3) Directive 2008/115/EC. 308 Art. 10 (1) Directive 2013/33/EU, Art. 47 L. 4636/2019. 309 Art. 19 Directive 2013/33/EU. 65 DETENTION OF MIGRANTS ON THE ISLAND OF KOS