STEP STEP STEP 01 02 03 MANDATORY QUARANTINE IDENTIFICATION PRISON-LIKE STRUCTURE STEP 04 STEP 05 AFTER A NEGATIVE DECISION PRE-REMOVAL DETENTION 3.3 De Facto detention on Arrival to the CCAC Every asylum seeker who first enters the main sections of the CCAC is served with an order for "restriction of freedom" for up to 25 days for "identification purposes", resulting in their blanket de facto detention. Until November 2022 the RIS determined that identification procedures were completed upon issuance of the "red card"- the asylum applicant’s ID. From November 2022 until the time of writing, the RIS considers that the identification procedures are completed earlier, which is after the full registration interview. Through I Have Right’s work monitoring their beneficiaries ability to leave and enter the structure, we have observed the following in practice. Firstly, from September 2021 until April 2022, new arrivals without red cards could leave the CCAC for appointments with lawyers, as long as they requested permission from the RIS the day before. Second, Until November 2022 the authorities strictly prevented newly arrived asylum seekers without a red card from leaving. This meant that many people were prevented from seeking legal assistance prior to their asylum interview as often people were interviewed before receiving their red card. Third, since November 2022, newly arrived asylum seekers, despite not yet being issued with a red card are entitled to leave the CCAC upon completion of the full registration interview. While many of I Have Rights’ beneficiaries have been able to leave after this point, others have been prevented from leaving due to the privately-contracted staff of G4S not permitting people to leave. Finally, for people who are without a red card due to receiving a rejection on their asylum application, in practice they are mostly able to leave the CCAC by using their "Police Note" which acts as an interim identification document. I Have Rights is greatly concerned that the detention of asylum seekers in the CCAC is in practice inconsistently applied, which creates uncertainty for asylum seekers in the CCAC and for this practice to be challenged. Moreover, the restriction of people for identification purposes and/ or without a red card within the _____ Page 41