Necessary sanitary precautions also include measures against infestation with rodents, fleas, lice, bedbugs, and other vermin. Such measures comprise sufficient and adequate disinfection facilities, provision of detergent products, and regular fumigation and check-ups of the cells, particularly bed linen, mattresses, and areas used for keeping food.238 f. Access to health care i. General aspects The ECHR does not specifically guarantee a right to healthcare as health care would be considered a socioeconomic right.239 However, in the case of detention, there are no precise and clear boundaries between the fundamental rights and freedoms enshrined in the Convention and socio-economic rights. Healthrelated cases brought before the Court have most frequently been argued under Articles 2, 3, 8 and 14 of the Convention.240 Generally, the national authorities must ensure that diagnosis and care in detention facilities, including prison, are prompt and accurate. Where necessitated by the nature of a medical condition, health care supervision must be regular and involve a comprehensive therapeutic strategy aimed at ensuring the detainee’s recovery or at least preventing deterioration of his or her condition.241 Furthermore, the Court has highlighted that medical assistance must be in line with Article 8 ECHR and Chapter III, paragraphs 34 and 50 of the CPT standards,242respecting the detainee’s privacy and the principle of medical confidentiality.243 Inadequate health care may also violate Article 8 ECHR, which grants every person the right to have his or her family and private life respected. The ECtHR has emphasized in various places that, while the ECHR does not include a right to medical care, respect for private life includes a person’s “physical, psychological and moral integrity.” In the absence of an explicit codification in the ECHR, the Court thus reads a right to physical integrity, such as is known from Article 3 (1) CFR or Article 2 (2) German Grundgesetz, into the duty to respect private life from Article 8 ECHR.244 In accordance with the human rights doctrine described above, the state also has a positive obligation to protect this integrity. 245 In its case law, the ECtHR has so far derived obligations to protect from Article 3 ECHR. The Court has expressly clarified that “suffering which flows from naturally occurring illness, physical or mental, may be covered by Article 3, where it is, or risks being, exacerbated by treatment, whether flowing from conditions of detention, expulsion or other measures, for which the authorities can be held responsible.”246 State acts and 238 Ibid at para 159. See also, ECtHR, Judgement of 27/01/2015, Nos 36925/10 et. al., Neshkov and Others v. Bulgaria, para 243. 239 Matters such as health and other socio-economic rights are traditionally addressed in instruments such as the European Social Charter or by the United Nations International Covenant on Economic, Social and Cultural Rights. 240 See for health-related issues under the Convention: ECtHR, Thematic Report, Health-related issues in the case-law of the European Court of Human Rights (June 2015), available at https://bit.ly/3ySMv9D. 241 ECtHR, Judgement of 30/07/2009, No. 34393/03, Pitalev v. Russia, para. 54. 242 European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) Standards for Immigration Detention, CPT/Inf(93)12-part, available at https://rm.coe.int/16806ce943. 243 ECtHR, Judgement of 02/06/2009, No. 36936/05, Szuluk v. the United Kingdom, para 43-55. 244 See, for example, ECtHR, Judgment of 24/09/2007 - No. 5410/03 - Tysiąc, para. 107; Judgment of 09/03/2004 - No. 61827/00 Glass, para. 74 et seq. 245 As early as 1981, the German Federal Constitutional Court stated that Art. 2 (2) of Grundgesetz also stipulates the state’s duty to “protect and promote the legal interests mentioned in Art. 2 (2) of Grundgesetz and [...] to preserve them”, see German Constitutional BVerfGE 56, 54, 73 – Fluglärm [Aircraft Noise]. 246 ECtHR, Judgment of 29/04/2002 - No. 2346/02 - Pretty, para. 52. 39 DETENTION OF MIGRANTS ON THE ISLAND OF KOS