56 GREECE IRREGULAR MIGRANTS AND ASYLUM-SEEKERS ROUTINELY DETAINED IN SUBSTANDARD CONDITIONS 88 Guidelines 5 and 10. 89 Article 16(2). 90 See Protocol Regulation 4803/22/44, Treatment and rights of persons detained by police authorities, 4 July 2003, at http://www.unhcr.org/refworld/pdfid/426f1f14.pdf. 91 See Amnesty International, “Hunger strike of migrants on Samos brings to the surface long-term problems regarding the implementation of the rights of migrants”, Press release, 22 April 2010 (in Greek). 92 Similar assistance is provided by experts (interviewers) to the Greek Police on the island of Chios. A second body of experts, deployed by the Member States in the framework of Frontex-coordinated joint operations on the islands of Samos and Chios, collects information in order to understand the modus operandi of the networks facilitating illegal border crossings (e-mail correspondence with M Parzyszek, Frontex Public Relations Officer, 5 May 2010). In June 2010, the UNHCR Office in Greece recommended the clarification and institutionalization of the competences and the legal framework of cooperation between the Greek authorities and Frontex in such a way that the administrative decisions that are taken within this framework and determine the further treatment of foreign nationals can be subject to review (Press Release, 16 June 2010, op.cit.). 93 Interview with A., Afghan irregular migrant, 9 March 2010 (personal details held on file); interview with N., asylum-seeker, 23 February 2010 (personal details held on file); interview with Z., asylumseeker, 23 February 2010 (personal details held on file). 94 A copy of A.’s official notice handed to him by the Greek authorities following his release from detention, showing that he was registered as an Iranian, has been viewed by Amnesty International. 95 Amnesty International sent letters to the Greek authorities expressing its concerns over these reported practices on 27 August 2009 and 20 December 2009. 96 Copies of these notices have been viewed by Amnesty International. 97 The CRC also stated that “in developing policies on unaccompanied or separated children, including those who are victims of trafficking and exploitation, States should ensure that such children are not criminalized solely for reasons of illegal entry or presence in the country.” (UN Committee on the Rights of the Child, General Comment No. 6 (2005), Treatment of unaccompanied and separated children outside their country of origin, 1 September 2005, UN Doc. CRC/GC/2005/, paras 61-62). 98 Concluding Observations of the Committee for the Elimination of Racial Discrimination, Greece, CERD/C/GRC/CO/19 August 2009. For reports on the situation of unaccompanied children in Greece, see Human Rights Watch, Left to Survive: Systematic Failure to Protect Unaccompanied Migrant Children in Greece, 11 December 2008; Georgia Demetropoulou and Ioannis Papagheorghiou, UNHCR Office in Greece commissioned report, Unaccompanied asylum-seeking children in Greece, April 2008. 99 Summary of the Working Group’s proposals, 14 April 2010, at http://www.yptp.gr. 100 See also UNHCR, Observations on Greece as a country of asylum, pp 11-12. 101 There are eight reception centres for unaccompanied children in Greece and 405 available places. Some unaccompanied children are offered accommodation in reception centres for adult asylum-seekers. The number of available places does not correspond to the number of arrivals each year. According to statistics provided to UNHCR by the Greek authorities, some 6,000 unaccompanied and separated children arrived in Greece in 2008 (UNHCR, Observations on Greece as a country of asylum, p 13). 102 UNHCR, “The UN Refugee Agency shocked at conditions at Greek detention facility”, Press release, 28 August 2009. 103 Demetropoulou and Papagheorghiou, pp 56-60. 104 Council Directive 2003/9/EC of 27 January 2003. On 6 May 2010, the European Commission adopted an Action Plan to increase the protection of unaccompanied minors entering the EU, encompassing common standards for guardianship and legal representation, IP 10/5/34. Amnesty International July 2010 Index: EUR 25/002/2010