EU Strategy on Combating Trafficking in Human Beings Feedback from I Have Rights.

 

I Have Rights (IHR) is a non-profit refugee law clinic operating on the Greek island of Samos. We provide free legal information to asylum seekers to guide them through the asylum process, ensure they understand their rights and support them in preparing their asylum claim. We also engage in advocacy and strategic litigation. During the course of our work over the last 12 months we have assisted 15 persons who are survivors of human trafficking. 

 

As the Northern Aegean islands are the entry point to the EU for many asylum seekers, it is crucial that the EU’s legal frameworks and Greece’s practices ensure the identification of survivors of human trafficking early in the asylum process and ensure that such persons are provided with appropriate support and assistance. However, in IHR’s experience, the Greek authorities consistently fail to meet their obligations to protect human trafficking survivors.  

In 2025, IHR registered 15 survivors of trafficking including forced labour, sexual exploitation, domestic servitude, forced marriage, with two survivors trafficked when they were children. This Have Your Say submission focuses on the experience of being held inside the Samos CCAC and its impact on survivors of human trafficking. IHR asserts that the CCAC is unsuitable for accommodating anyone, let alone individuals with exceptional vulnerabilities, including survivors of human trafficking, for the following reasons:

 

  1. De facto detention: Newly arrived individuals continue to face prolonged de facto detention in overcrowded spaces with inadequate access to sanitary facilities. During this period, no apparent individual or vulnerability assessments are conducted, and no psychological, medical, or psychosocial support is provided. This practice is particularly harmful for survivors of trafficking, who may have escaped exploitation just before reaching Greece.

‘Forced to sleep on cardboard on the floor’ 
M, who was identified by IHR caseworkers as a survivor of human trafficking, sexual violence and torture reported that she was de-facto detained in ‘very awful’ conditions that ‘she could not even describe’. Upon arrival in February 2025, her phone was reportedly removed by the authorities and withheld until after she was registered at the camp. M reported that the toilets in the room she shared with eight other people were  ‘disgusting’ and had not been cleaned. There were no beds and reportedly the group were forced to sleep on cardboard on the floor for three days. 

‘No running water and toilets were very disgusting’
L, who has been identified as a survivor of human trafficking and sexual exploitation, reported that she was in so-called ‘quarantine’ in March 2025 alongside 20 other people. L reported that men and women in the group were separated between two containers. L reports that there was no running water and the toilets were ‘very disgusting’ and hadn’t been cleaned at all. There were also reportedly not enough beds, meaning that they would have had to sleep two people in one bed. L reported that after a few hours, the group complained about the conditions and demanded to be moved, and were eventually taken to another zone in the camp, where they were detained for two days. L believes that if they had not protested the conditions, they would have had to stay in the first detention area for the duration of the quarantine period. 

MBK, a survivor of sexual violence and human trafficking for the purposes of forced labour and sexual exploitation, reported in July that she felt very unsafe while held in isolation. She stated:

 “Even at night you can’t sleep. So many noises. That was for 3 days.” 

On her health card the Greek authorities noted that she was 4 months pregnant, with a head wound and she was subsequently referred to the CCAC psychologist. However, no timely vulnerability assessment was carried out upon arrival, and for 3 days in isolation, MBK was subjected to inadequate reception conditions and de facto detention. 

 

  1. Inadequate conditions: The CCAC lacks specialized accommodation for vulnerable persons. Concerningly, this has resulted in vulnerable groups, including survivors of trafficking, being accommodated alongside the general population. For instance, a female client of IHR who was a survivor of sexual violence was reportedly forced to share a container with unrelated men.

‘We lock our doors with rope wire’
Z, a survivor of FGM, forced marriage and sexual violence, arrived on Samos alone with her seven month old baby reported that every night she locks the door to her container with rope wire she fashioned herself, otherwise reportedly the door would be able to be opened from the outside. In addition, another client reported that the doors in the showers and toilets of the female bathrooms cannot lock, and sometimes can’t even be closed properly. This is deeply concerning and violates the right to privacy of all people subjected to these conditions inside the CCAC, and has particularly harmful effects for survivors of exploitation and trafficking, who may have just escaped their trafficking experience before reaching Samos and people with cumulative vulnerabilities. 

‘It doesn’t matter if you are checked by a man or a woman’
One female trafficking survivor reported that when re-entering the CCAC, the camp authorities use a ‘machine’ to search between their legs and even ‘brush (their) breast’ whilst they are being searched, a practice she described as ‘humiliating’. Another client reported that once she saw a woman refuse to be searched by a man, and she was treated with further suspicion as if ‘she might be hiding something’. 

 

  1. Continuing Lack of Support Services: With one psychologist and no consistent full-time doctors for a population of close to 2000 residents, access to medical, paramedical, and psychological care remains critically inadequate for the whole population in Samos CCAC. This has far-reaching consequences for the whole population, especially for survivors of trafficking as this severely limits their access to essential medical and psychological assistance.

 

  1. Consistent shortages in interpretation continue to raise serious concerns about the ongoing failure of Greek authorities to adequately identify possible survivors of human trafficking. In March 2025, a client that IHR identified as a trafficking survivor reported difficulties in expressing their trafficking experience in their asylum interview due to interpretation issues. These challenges were compounded by issues in obtaining their interview transcripts, making it exceedingly difficult to challenge negative decisions, correct inaccuracies, and ensure proper recognition of their trafficking experience.

 

  • Inconsistencies in the asylum procedure: 

As asylum interviews continue to be delayed, inconsistencies and gaps in identification of survivors directly impact access to special conditions under the Palermo Protocol, and ultimately influence people’s asylum decision.  

AMG, is a survivor of human trafficking for the purpose of sexual exploitation, identified by IHR caseworkers at the end of May 2025, and officially registered in our database in July 2025. He did not share in his first asylum application, dating back to June 2023 that he is a survivor of human trafficking. Only now, in his subsequent asylum application is the claim of trafficking being considered. The lack of professional sensitised staff in the asylum procedure, and the absence of a coordinated response to ensure essential support for all individuals including trafficking survivors, further exposes individuals to lengthy and unfair asylum procedures. 

  • Delays in the asylum procedure: Delays in the asylum procedure often occur in the Samos CCAC. In May 2025 alone, 16 clients of IHR reportedly had their asylum interview postponed – some for the sixth time. These repeated delays in the interview phase force people to stay longer in undignified reception conditions and postpone the identification of survivors of human trafficking. S, a survivor of child labour exploitation, reported  that  their asylum interview had been postponed for the second time, moving from May to June 2025. As a trafficking survivor who was subjected to exploitative labor, repeated delays in their asylum process have serious consequences. They prolong her exposure to degrading living conditions in the Samos CCAC, undermining her entitlement to ‘psychological and social recovery’ and ‘appropriate and secure accommodation’ under international law. 
  • Evictions: At other times the Greek asylum service has accelerated border proceedings. In the context of the Samos CCAC, authorities are enforcing removal orders once applicants receive their asylum decisions. This practice goes against the 30 days -post official recognition- time period to leave the CCAC. Even though asylum seekers and recognised refugees, considered vulnerable as per Articles 39(5)(d) and 58(1) Law 4636/2019, should not stay in CCACs, as they are not an adequate accommodation where they can find the support they need, the eviction orders present severe protection gaps for people with cumulative vulnerabilities. Due to the lack of procedural safeguards at earlier stages of the asylum procedure, individuals with severe medical issues and in particular survivors of human trafficking are being affected by these eviction orders. In June, a case worker of IHR registered the case of a survivor of human trafficking with medical issues that reportedly received their refugee status on May 22nd, got her passport on June 16th and was told that she had to leave the CCAC the next day, despite being within the 30 days.  In this particular case, IHR sent an email to the pertinent authorities requesting the extension of their stay in CCAC due to the client’s medical issues. They were unable to stay longer in the CCAC but were able to transfer to Thessaloniki with A21, a non-governmental organization that works to fight human trafficking. In the past, appeals for extension due to individual vulnerabilities were considered, but current state practice shows strict issuance of removals. Authorities must comply with its obligations to provide specific guarantees with regard to the treatment of vulnerable individuals, including survivors of human trafficking. 

We urge the European Commission to ensure measures to protect survivors of human trafficking:

 

  • Ensure that the Greek authorities end the use of administrative and de facto detention measures against people seeking international protection in Greece, 
  • Ensure that Greek authorities urgently address the immediate deficiencies affecting accommodation, maintenance, healthcare services, and sanitation in the Samos CCAC, including through the provision of dignified conditions to newly arrived persons, 
  • Ensure that Greek authorities urgently improve the healthcare system, the provision of specialist care to people with vulnerabilities  and with specific needs held in the CCAC, and the prompt transfer to adequately resourced facilities on mainland Greece of residents with health conditions that cannot be adequately treated in the CCAC or in the public system,
  • Ensure that the Greek authorities address the ongoing shortage of qualified interpreters during the whole asylum procedure to ensure that applicants can fully and accurately explain their reasons for fleeing, including experiences of trafficking
  • Ensure consistency in the asylum process and the consistent and early identification of survivors of human trafficking.