More specifically, according to a 19 September 2023 Joint Statement by Civil Society Organisations (CSOs),233 ‘[l]egal actors on Samos have observed that the provision of these 5 and 20 day “restriction of freedom” orders, frequently is issued after the detention period has already begun. For example, on Samos, legal actors have recorded that the 5-day restriction of freedom orders were retroactively provided to applicants on the same day that they were given the 20-day restriction order. Applicants reported being forced to sign orders that were back-dated, masking the reality that they had been detained for several days without documents. [… ] Legal actors on Lesvos have observed that newly arrived asylum seekers are de facto detained in the Lesvos CCAC without the issuance and/or notification of any specific decision ordering detention or restriction of their freedom. They are issued with neither a detention order within 5 days of arrival, nor an extension for up to 25 days, as required by Article 40(a) Asylum Code. Asylum seekers are issued only a piece of paper documenting the simple registration of their will to seek asylum, containing only their basic biographic data. After their asylum claims have been fully registered, asylum seekers are free to leave the Lesvos CCAC, but this process is unacceptably delayed, in some cases for more than three weeks, in violation of Article 69(2) of [Asylum Code].’ According to testimonies of applicants collected by the Greek Council for Refugees, in Kos, decisions imposing a ‘restriction of liberty’ were issued days after the actual arrival and confinement of the newcomers and were not notified to them. No issuance and/or notification of decisions of ‘restriction of liberty’ was taking place for the persons confined in the Controlled Temporary Accommodation Facility for asylum seekers of West Lesvos. The detention conditions of the ‘waiting areas’ are grounds for sharp criticism. According to the aforementioned Joint CSO Statement, as of September 2023, ‘On Samos, hundreds of people have been restricted to the “Temporary Accommodation Zones” of the CCAC, the sections of the CCAC that were previously used for Covid-19 quarantine. These enclosed zones are composed of accommodation containers only and are surrounded by layers of barbed wire fences. Police provide 24/7 surveillance and residents are only permitted to exit for urgent medical needs or for interviews with the authorities. Mobile phones are taken by the police upon arrival for between 7-10 days, resulting in a mass violation of applicants’ privacy and leaving new arrivals with no possibility to reach out for medical or legal support to non-governmental actors operating outside the CCAC.’ As newly arrived persons are detained within subsections of the CCAC, they do not have access to any services, including medical support. This is compounded by the fact that no doctor is permanently present in Samos CCAC to provide medical care to people who have just arrived, resulting in hundreds of asylum seekers being unable to access medical, including psychological support. The potential repercussions for this lack of access are significant, as asylum seekers are frequently exposed to violence en route and/or in their country of origin and present specific health vulnerabilities. This includes, for example, survivors of sexual violence and pregnant women, who may need urgent sexual and reproductive health care. Additionally, owing to the absence of healthcare and individual vulnerability assessments, applicants with non-communicable chronic diseases such as diabetes or cardiovascular conditions and communicable diseases risk remaining undetected or unable to seek medical treatment for several weeks after arrival. On Lesvos, newly arrived persons are de facto detained inside the Lesvos CCAC, housed in large rubhalls. They can circulate throughout the CCAC, but are prohibited from leaving, except for specific medical emergencies or medical care, normally in coordination with Médecins Sans Frontières (MSF). Men, women, and children (including unaccompanied children and other vulnerable groups) are housed together in these rub-halls, without any privacy or safety measures to protect vulnerable individuals. As in Samos, there is 24/7 surveillance of the Lesvos CCAC by police both at the entrance and throughout the CCAC, and all the mobile phones of newly arrived persons are taken by police upon arrival for several days. Conditions in these rubhalls are unacceptable. There are insufficient mattresses and beds meaning that people are forced to sleep on the ground. People de facto detained in these conditions have reported that 233 Joint CSO Statement, Unlawful detention and worsening conditions: over 4,000 asylum seekers and unlawfully detained on Samos and Lesvos, 19 September 2023, available at: https://bit.ly/3VPTWxx. 59