European legal and policy framework on immigration detention of children In the autumn of 2015 in Denmark, for example, shortterm detention took place in sports centres near the borders (Roedbyhavn and southern Jutland). These facilities have now been closed as numbers of arrivals dropped. In the United Kingdom, Longport freight shed, a facility previously used to search vehicles, was used as a short-term holding facility, including for the detention of children, despite not having been adapted for this purpose. HMIP considered the conditions “wholly unacceptable”. Detainees were held for several hours or even overnight in the unsegregated freight shed, which could not separate women and children from men. They received no clean or dry clothes, food or hot drinks, and had nowhere to sleep other than on a concrete floor. During the inspection, HMIP observed immigration staff wearing police-style fatigues and stab-vests, and carrying batons. A second facility at Dover Seaport, which had been used to detain 370 unaccompanied children between July and September 2015, was considered too small for the number held there and not fit for purpose. The facility had one main holding room and a separate small family room with no natural light. The family room was not fit for purpose.321 Ø The time in short-term holding facilities is normally limited to a  few hours or days. However, delays in transferring children to specialised facilities may occur, particularly if specialised holding or reception facilities are crowded or not available, as is the case in hotspots in Greece and Italy. In Greece and Italy, new arrivals by sea, including children, are confined to the hotspots until they are registered and fingerprinted. In Italy, deprivation of liberty by the police can last for a maximum of 96 hours, after which detention can be continued only if confirmed by a judge, except for unaccompanied children, who must be released.322 In Greece, unaccompanied children who have applied for asylum while in detention may remain in detention only in “very exceptional cases” and “as a last resort” for the time required to refer them safely to appropriate accommodation facilities. Such detention cannot exceed 25 days. It can, nevertheless, be prolonged by an additional 20 days when, on account of “exceptional circumstances” and “despite reasonable efforts by competent authorities”, it is not possible 321 United Kingdom , Her Majesty’s Inspectorate of Prisons (2016) ‘Report on an unannounced inspection of the shortterm holding facilities at Longport freight shed, Dover Seaport and Frontier House’, London, p. 5, 10, 11 and 17. 322 Italy, Immigration code (Testo unico sull’immigrazione), legislative decree No. 286, 25 July 1998 (as amended), Article 14 (3) and 14 (4); Constitution of the Italian Republic, Article 13. Italy, Legislative decree (decreto legislative) No. 142/2015, 18 August 2015, Article 19 (4) as amended in March 2017. 78 to refer them safely to appropriate accommodation facilities.323 There is insufficient capacity in dedicated, specialised facilities, so unaccompanied children remain in the hotspots pending further transfer.324 For the same reasons, delays in transfer also occur when children are held in police stations in Greece. Such facilities are generally inappropriate for children, lacking the necessary support and assistance they require, space for outdoor exercise, proper hygiene conditions, items of personal hygiene and leisure activities, and are not always able to separate children from unrelated adults, the CPT has noted.325 7.2. Child-specific training Staff working in reception facilities must have adequate training, according to Article 18 (7) of the Reception Conditions Directive. Under Article 24 (4), EU Member States have a duty to provide specific training to those working with unaccompanied children. Article 17 (4) of the Return Directive requires that, as far as possible, personnel take into account unaccompanied children’s needs; this requirement presupposes that personnel are aware of the rights, needs, and risks of unaccompanied children. Ø Very few of the specialised facilities employ staff who have received specific training on child protection, according to the information that FRA has collected. This particularly applies to guards as well as private staff employed to run facilities in some EU Member States. 323 Greece, Law No. 4375 of 2016 on the organisation and operation of the Asylum Service, the Appeals Authority, the Reception and Identification Service, the establishment of the General Secretariat for Reception, the transposition into Greek legislation of the provisions of Directive 2013/32/EU, 3 April 2016, Article 46 (10) (b). 324 FRA (2016), Opinion of the European Union Agency for Fundamental Rights on fundamental rights in the ‘hotspots’ set up in Greece and Italy, Luxembourg, Publications Office, pp. 28–31. 325 The CPT visited Amygdaleza Special Holding Facility for Unaccompanied Minors, Petrou Ralli Special Holding Facility for Irregular Migrants, Attica Police Headquarters. See: CPT (2016), Report to the Greek Government on the visit to Greece carried out from 14 to 23 April 2015, CPT/Inf (2016) 4, paras. 105–108.; Greece, Greek Ombudsman (Συνήγορος του Πόλίτη), Annual Report 2015, Athens, March 2016, pp. 127–129, 139–139; Greek Council for Refugees (Ελληνικό Συμβούλιο για τους Πρόσφυγες) (2015), ‘Complementary Submission to the Committee of Ministers of the Council of Europe in the case of M.S.S. v. Belgium and Greece (Application No 30696/09): the issue of unaccompanied minors’, press release, 29 May 2015.