without access to legal services can therefore have serious consequences for applicants’ chances of success. Additionally, on 13 July 2021 a group of 26 asylum seekers arrived on the island of Kos. According to several people interviewed by Equal Rights and other NGOs on the island, the police brought the new arrivals to a quarantine area in the PRDC on 13 July 2021 where they stayed for one day. On 14 July 2021, one day after they arrived in Greece, all 26 newly arrived asylum seekers were registered by Frontex and RIS, in which they underwent medical and vulnerability ‘assessments.’ Approximately half of the new arrivals were registered by GAS on 14 July 2021 as well, and at least six were scheduled for asylum interviews for the following day, 15 July 2021. After putting significant pressure on the authorities, lawyers from the three NGOs on Kos were allowed to meet with the group of new arrivals, who were all being held in a gated area inside the RIC, for a little over one hour. During that time, lawyers and interpreters from the three NGOs provided people with background information on the asylum procedures, and in particular what they could expect during the asylum interview. However, lawyers were not able to sign legal authorisations with any of the new arrivals on 14 July 2021 and were otherwise prevented by the authorities from attending the interviews the following day.184 After their registration, all of the new arrivals were transferred back to the PRDC, with the exception of four unaccompanied minors. At the same time, the police took the phones of every new arrival – a decision seemingly connected to an investigation into smuggling routes – and had yet to return them one week later, by which time many had already received first instance rejections. Ultimately, it was impossible for the majority of the new arrivals to access legal services both prior to their interviews and for their appeals. iii. The Right to Information on Reasons for Detention and Individualised Detention Orders On this point, we identified two major issues facing people detained in the Kos PRDC: first, the issuance of generic, template-likedetention orders and, second, a lack of information provided to detainees about the reasons for their detention. We identified these issues primarily through our representation of more than fifty clients detained in the PRDC along with interviews conducted for this report. aa. Detention orders Both through interviews conducted for this report and experience providing legal representation on Kos, we found that people detained in the PRDC have either never seen their detention orders or were unaware of the orders’ contents. Detention orders are issued in Greek and, due to the lack of interpreters in the PRDC, are rarely orally translated.185 Clients of Equal Rights frequently contact us seeking an explanation as to what the “paper for three months,” means—unaware that they inadvertently signed an order to extend their detention. Even when served properly, the detention orders generally lack sufficient reasoning or valid legal basis. In July, Equal Rights submitted a complaint to the Greek Ombudsman on behalf of 19 rejected asylum seekers detained in the PRDC. In preparing the submission, Equal Rights observed that—across the board—detention orders simply copied the relevant provision of the law and contained no individualised assessment. None of the detention orders considered vulnerability, despite that fact that three of the applicants were SGBV survivors, one was a victim of human trafficking, and several suffered from serious medical and psychological conditions. Similarly, the orders did not address the length of any previous detention. One of the 19 people included in the submission had been in detention for 17 months at the time of the submission, and 17 had been detained for over six months. Further, Equal Rights discovered numerous procedural errors, that, in 184 Equal Rights and GCR submitted a letter to the competent authorities and Greek Ombudsman in response to these events. The letter was also published in the media. See e.g., Γιώργος Παγούδης, Σύγχρονοι Πύργοι του Κάφκα, EFSYN (07 August 2021), available at: https://bit.ly/3DBfMZl. 185 An example detention order is included as an annex to this report. 28 DETENTION OF MIGRANTS ON THE ISLAND OF KOS