According to Art 13 paragraph 7 Presidential Decree 220/2007 legal advisors or lawyers and representatives of the UNHCR shall have unlimited access to accommodation (Reception Centers) and other housing facilities in order to assist applicants. The Director of the Center may extend access to other persons, too. Limitations to such access may be imposed only on grounds relating to the security of the Accommodation Centers and housing facilities and of the applicants themselves. In pratice, lawyers, as well as NGOs, friends or family members have had access to Reception Centers. 6. Addressing special reception needs of vulnerable persons Indicators: - Is there an assessment of special reception needs of vulnerable persons in practice? Yes No Due to large number of asylum seekers and the extremely limited number of in total1006 beds in the Reception Centres NGOs which usually take care of the accommodation of the asylum seekers give priority to vulnerable persons. It should be mentioned that despite the legal safeguards in relation to the treatment of unaccompanied children, Amnesty International has observed that unaccompanied children or those separated from their families are being systematically detained for extended time periods until a place becomes available at a reception centre. In the detention centre for unaccompanied boys in Amygdaleza, in August 2012 children were being detained in substandard conditions. Further, in detention centres in Athens and Evros, children were being detained together with adults and/ or they have been registered 70 as adults . As mentioned above in section E relating to asylum procedures the Greek law foresees an identification and referral system based on Articles 17 and 20 of the Presidential Decree 220/2007 which transpose respectively Articles 17 and 20 of Council Directive 2003/9/EC laying down minimum standards for the reception of asylum seekers. Article 20 states that: “the competent authorities to receive and accommodate or to receive and examine an application for asylum shall ensure that persons who have been subjected to torture, rape or other serious acts of violence are referred to specialized unit in order to receive support and the necessary treatment of the wounds caused by aforementioned acts.” Furthermore, Article 11 paragraph 2 of Law 3907/ 2011 concerning screening centres states that: “the Head of the Centre of Unit shall, upon recommendation of the head of the medical screening and psychosocial support cell, refer persons belonging to vulnerable groups to the competent body of social support or protection. For the purposes of the present, vulnerable groups are: victims of torture, rape or other serious forms of psychological, physical or sexual violence.” According to Article 11 paragraph 5 “In the cases mentioned in paragraphs 2 and 3 above, the referral note to the competent authority shall be issued within fifteen days, at the latest, from the admission of the third-country national to first reception procedures. In exceptional circumstances, the period of admission to the verification and separation procedures may be extended, if reasoned, for another ten days maximum. If the delay in verification is due to wrongful or improper conduct of the person subjected to first reception procedures, this person shall be considered as refusing to cooperate for the preparation of his return and shall be transferred in view of his/her removal, deportation or return. Time limits and procedures of this article shall only apply in the context of the operation of the First Reception Centers.” 70 Amnesty International, Greece: The end of the road for refugees, asylum-seekers and migrants, 20 December 2012, EUR 25/011/2012. 43