screened for Covid-19, 201 and that families and women – including survivors of sexual and gender-based violence – were unlawfully detained together with men, separated by only a small fence.202 People who are detained in the PRDC cannot leave the premises on their own for any reason, even to visit the asylum service, seek medical treatment, or meet with lawyers. Lawyers are only allowed to enter the PRDC to meet with clients with prior approval from the police. UNHCR also has access to people detained in the PRDC. According to UNHCR, the organization visits the PRDC at least once per week. However, protection officers have not been able to enter the living areas since March 2020. The asylum service has offices inside the PRDC, but those offices are used for limited reasons. For most communication with the asylum service, detained applicants are expected to use e-mail or request information from the police. For interviews and appointments with the asylum service, police transfer applicants by police car to and from the RIC. For medical care outside of the PRDC, the police also transfer applicants in their custody. B. Legal Preconditions 1. Greek and European Law Central to this report are the provisions laid out in Article 10, 11 and 19203 RCD and Article 47 of the IPA. Specifically, Article 10 RCD imposes on Member States the following minimum standards: • Asylum seekers should be detained, as a rule, in specialised detention facilities as opposed to prisons. In exceptional cases where they cannot be detained in a detention centre, they should be kept separately from “ordinary prisoners” and from other migrants who have not lodged an asylum application.204 • Asylum seekers must have access to open-air spaces.205 • Minors and families should only be detained in exceptional circumstances and with specific safeguards.206 • Where female applicants are detained, Member States shall ensure that they are accommodated separately from male applicants, unless the latter are family members and all individuals concerned consent thereto.207 • Asylum seekers shall receive “the necessary health care which shall include, at least, emergency care and essential treatment of illnesses and of serious mental disorders” and “necessary medical or other 201 Refugee Rights Europe, The Invisible Islands: Covid-19 Restrictions and the Future of Detention Kos and Leros, 5, available at: https://bit. ly/3gYol7H 202 Ibid at 10. 203 Health Care is not specifically mentioned for detention in Art.10, so Art.19 (which does not specifically address detention) applies without modifications. See also Peek/Tsourdis in Hailbronner/Thym EU Immigration and Asylum Law, Part D.V. para 298, p. 1480. 204 Art. 10 (1) Directive 2013/33/EU. 205 Art. 10 (2) Directive 2013/33/EU. Art. 10 (2) has to be interpreted in the light of the CPT Standards. The European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) has stated more specifically that every type of prisoner without exception, should be allowed at least one hour of exercise in the open air every day. According to the Committee, this is widely accepted as a basic safeguard and preferably it should be part of a broader programme of activities (CPT Standards, CPT/Inf/E (2002) 1 – Rev. 2011, 18), see also Peek/Tsourdis in Hailbronner/Thym EU Immigration and Asylum Law, Part D.V. para 160, p.1453. 206 Art. 11 (2), (3), (4) Directive 2013/33/EU. 207 Art. 11 (5) Directive 2013/33/EU. 35 DETENTION OF MIGRANTS ON THE ISLAND OF KOS