assessment procedure in the first place because RIS had failed to inform them. 3. Conclusions The practices on Kos towards members of vulnerable groups raise serious questions about whether they are in line with EU law, Greek law, and human rights law. First, the policy of automatically detaining all asylum seekers upon arrival and then automatically extending their detention upon a second rejection excludes the possibility that authorities are conducting an individualised assessment that accounts for their vulnerabilities and the ways in which their needs could be met in detention. Since Equal Rights started working on Kos in January 2021, we have not been aware of a single detention order for asylum seekers or rejected asylum seekers where authorities conducted a proportionality assessment, weighing the need for detention on the one hand and the individual’s vulnerabilities on the other hand. The lack of such individualized assessments is contrary to Article 30 (1) Law 3907/2011, Article 15 (1), 16 (3), 17 RD and Article 8 (2), Article 11, Article 21 et. seq. and Recital 15 RCD, Article 58 (2), Article 46 (1) IPA. Similarly, the ECtHR requires state authorities to consider potential vulnerabilities when issuing detention orders and to prevent inhuman and degrading treatment.143 For example, there is no doctor on site for people with serious medical issues and the psychologist does not have an interpreter. This automatic application of detention renders detention orders of individuals with specific vulnerabilities disproportionate and hence unlawful. Second, the historical practice of detaining minor children in the PRDC quite clearly violates EU, Greek, and human rights law. In the cases we represented where minors were detained, their detention orders did not take into account alternative less-restrictive measures, whether the PRDC was a suitable accommodation, or the children’s best interest, all of which are required by the law for both asylum seekers and rejected asylum seekers.144 Further, the PRDC is in no way equipped to house minors – there are no play areas, educational programs, or specialised medical/psycho-social staff (see more in Section 2). These conditions not only violate EU law and Greek law but are similar to the conditions that led the ECtHR to find violations in both Popov and Rahimi145. F. Formal Legal Pre-Conditions: Procedural Guarantees and the Right to an Effective Remedy Having analysed the legal grounds for detention in Greece, this section documents what procedures the authorities must follow when detaining migrants and asylum seekers. In particular, this section looks at detained persons’ experiences accessing legal services, the asylum procedure, information about their detention, and remedies against detention. We have found that detained persons lack access to reliable, accurate information regarding the reasons for their detention and the asylum procedure. We have observed that this lack of information undermines detained asylum seekers’ ability to legally challenge their detention and to understand and engage with the asylum procedure. 1. Formal Legal Preconditions a. Access to Asylum and Information about Asylum Procedures Under Greek law, asylum seekers have a right to access the asylum procedures and information about the procedure from as early as the reception and identification procedure and even before they’ve filed formal 143 Thimothawes v. Belgium, § 73; Rahimi v. Greece, § 108, Neshkov and Others v. Bulgaria, § 227 with further references. 144 See e.g., Art. 11 (2) Directive 2013/33/EU, Art. 17 Directive 2008/115/EC. 145 Cf. footnotes above. 21 DETENTION OF MIGRANTS ON THE ISLAND OF KOS