The non-admission procedure is expeditious and simplified; refusal of entry forms are often pre-completed, particularly the renunciation of entitlement to a period of one clear day before removal. The procedure is limited to submitting a copy of the refusal of entry and recording the identity of people concerned in the electronic entry-exit system. The documents are never read out to the people concerned, they are not notified of their rights, no interpreters are present and asylum is never an option. The notion of family is misused, extended to encompass the situation of any child travelling in a group. Moreover, children are not subject to protection or a special procedure in light of their vulnerability. 3.2 The prospects for improving immigration detention 3.2.1 Updating French law There is nothing trivial about detaining people - especially when these people have not committed any offence. There is a concern that the Government is not sufficiently convinced of the new direction outlined for a reform on the day this report was being written: extension of the detention time-limit to 90 days, increase to 24 hours of the maximum time people can be detained to check their right of residence, placement in detention of a person likely to come under a Dublin procedure once the request to take charge has been sent to the corresponding State, etc. It should particularly be pointed out that the 45-day detention time-limit is already unnecessarily long since, in reality, where a forced removal has not proved possible during the first two or three weeks, it is highly unlikely that it will be possible at all, if the country of origin does not recognise their national citizen. Doubling this time-limit, therefore, as has recently been proposed, would not only represent a backward step in terms of fundamental rights, but also be devoid of purpose. In the vast majority of cases, the 32-day detention time-limit, however, which applied prior to the 2011 law, is amply sufficient. 3.2.2 A draft instrument codifying existing minimum standards relating to conditions of administrative detention of migrants, under the auspices of the Council of Europe A draft instrument codifying existing standards relating to conditions of administrative detention of migrants is currently being prepared, under the auspices of the European Committee on Legal Cooperation, a Council of Europe intergovernmental body. International experts and associations have expressed very clear reservations about this draft instrument, on which the CGLPL was consulted in June 2017, as have the other national torture preventive mechanisms. Unlike prison law, the law governing detention is incomplete; codifying it therefore reveals a number of gaps that the principle of "established law as it stands" prevents from being filled. In order to overcome this substantial difficulty, the writers have decided to transpose the European prison rules each time there is no corresponding standard. What this means is that the instrument applies rules set out for prisoners to detained foreigners, adopting an approach to detention that is fundamentally geared towards criminal law. Such a position is unacceptable. An approach grounded more in human rights is necessary. As the draft codifying instrument currently stands, it falls short of the existing standards: the rules proposed concerning particularly vulnerable people do not go far enough in terms of protection, with it being possible to admit children into detention, provisions bearing on avenues of appeal, rights of communication and visits 29