establishes a positive obligation to take sanitary precautions and to keep sanitary facilities in detention centres clean. Such obligations include measures against infestation with rodents, fleas, lice, bed bugs, and other vermin. The measures comprise sufficient disinfection facilities, the provision of detergent products, regular fumigation, and inspection of the cells.296 Administrative authorities within the PRDC do not comply with this legal obligation. All participants reported that toilets and showers are in very poor condition and have never been cleaned by the administrative authorities. Moreover, clients confirm that they are not provided with sanitary products to clean the facilities themselves. Instead, detainees must purchase cleaning products with their own money if they want to clean the sanitary areas. Clients report infestation with bed bugs, cockroaches, and other rodents within the PRDC. Faiza reported that mice and cats entered her room, that the floor had holes and cockroaches, and that other rodents were regularly coming in through the holes in the floor. Saeed reported that “small creatures” are jumping from his bed and on his head when he goes to bed and that this infestation caused a serious psychological impact. Similarly, Florence, an SGBV survivor, experienced negative psychological effects when she was menstruating but was not provided with sanitary products for several days while being surrounded by male policemen. In some cases, the sanitary facilities in the detention centre raise concerns regarding Article 8 ECHR. Ismail told us that there was no door outside the toilet and that he and his fellow detainees hung a blanket in its place to ensure at least a modicum of privacy. 4. Access to Healthcare a. General Conclusions The lack of healthcare provided within the PRDC on Kos clearly violates both national and EU law as well as international human rights law. Article 19 RCD and Article 47 (7) IPA guarantee access to healthcare for asylum seekers. Similarly, Article 16 (3) RD and Article 31 (3) Law 3907/2011 guarantee at least emergency health care for rejected asylum-seekers and adequate medical and psychological assistance for vulnerable individuals. The lack of medical care may also raise an issue under Articles 3 and 8 ECHR, particularly because we have found that authorities are often aware that people need treatment and fail to provide it. The also ECtHR requires state authorities to ensure prompt and accurate diagnosis and treatment in detention facilities including, where necessary, a comprehensive therapeutic strategy297 and to ensure the detainees medical confidentiality. None of these requirements are met in the PRDC. As of 29 October 2021, there was no doctor working in the detention centre. However, even when there was a doctor, the quality and quantity of medical staff was not sufficient to provide the legally required standards of medical assistance. Participants reported a lack of knowledge on how to access medical services. Furthermore, there is practically no interpretation available for detainees, clearly implicating their right to privacy as individuals have to choose between not receiving any medical aid or sharing confidential medical details with fellow detainees who help them translate. The fact that detainees must justify to police their medical needs before being granted an appointment with the doctor infringes on their right to privacy. According to clients’ reports and the experience of Equal Rights as well as the appointment that Equal Rights staff had with the doctor in the PRDC, the medical staff in the detention centre only provide a very limited amount of basic care and mainly prescribe paracetamol instead 296 ECtHR, Judgement of 10/12/2020, No. 42732/12, Ananyev and Others v. Russia, para. 159, ECtHR, Judgement of 27/01/2015, Nos 36925/10 et. al., Neshkov and Others v. Bulgaria, para. 243. 297 ECtHR, Judgement of 30/07/2009, No. 34393/03, Pitalev v. Russia, para. 54. 63 DETENTION OF MIGRANTS ON THE ISLAND OF KOS