surveillance of the centre, restrictions on outside communication, and their prolonged confinement. Whether people seeking international protection could be permitted to leave the country they were restricted to, cannot rule out de facto deprivation of liberty.[22] Moreover, it is not necessary that the 'building was locked' to show detention: that people must ask permission and that time spent away was always subject to controls and restrictions could amount to detention.[23] In J.R. and Others v Greece the Court considered that those awaiting a deportation decision were 'in detention' within the Greek reception and identification facility up until it became a semi-open centre where the applicants had the option to go out during the day.[24] Similarly, the Administrative Court of Syros in Greece ruled that the exit prohibition of an individual without an asylum card from the Samos CCAC and the failure to issue a written detention order amounted to de facto and arbitrary detention. [25] Ultimately, by considering the 'concrete situation' and the 'degree and intensity', the circumstances of the CCAC may amount to an unlawful deprivation of liberty. In the following section, we consider the grounds for which a person may be lawfully detained. 1.2 Grounds for detention under EU law According to the RCD, "a person should not be held in detention for the sole reason that he or she is seeking international protection".[26] Applicants may only "be detained under very clearly defined exceptional circumstances laid down in this Directive and subject to the principle of necessity and proportionality with regard to both to the manner and the purpose of such detention".[27] Importantly, the EU Directive requires an individual assessment of each case, prohibiting blanket detention of applicants of international protection.[28] The Directive outlines that an individual may be detained for the following reasons: [22] Riad and Idiab v Belgium (First Section) [2008] ECHR (App No 29787/03 and 29810/03). [23] Stanev v Bulgaria (GC) [2012] ECHR. (App No 36760/06). [24] J.R. and others v Greece, [2018] ECHR (App No 22696/16), para 86. [25] Decision No AP 36/17-12-2021 Administrative Court of Syros. [26] Directive 2013/33/EU of the European Parliament and of the Council of 26 June 2013 laying down standards for the reception of applicants for international protection (recast). Article 8. [27] Directive 2013/32/EU of the European Parliament and of the Council of 26 June 2013 on common procedures for granting and withdrawing international protection (recast). Preamble 15. See also, Article 8. [28] Ibid. Article 8(2). Page 10