Detention of third-country nationals in return procedures in asylum procedures or administrative or judicial proceedings, they should, in addition to the appointment of a guardian, be provided with legal representation.367 Access to legal representation is crucial to allow children to make effective use of existing legal procedures. Such access may be difficult where children have access to legal assistance in the same way as adults.368 While separated children deprived of their liberty may often be entitled to benefit from the same protection safeguards as those not detained, in practice legal representation for detained children can be challenging. Different obstacles can exist. As an illustration, in Austria, the Youth Welfare Agency is not always informed when separated children are deprived of their liberty,369 whereas at the Roissy-Charles de Gaulle (CDG) airport in Paris the appointed representatives had only the capacity to take responsibility of 75% of minors in 2007.370 367 Committee on the Rights of the Child, General comment No. 6 (2005), Treatment of Unaccompanied and Separated Children outside their country of origin, CRC/GC/2005/6 at paragraph 36. 368 Less then one out of four of the 28 children aged 10-17 interviewed by the Jesuit Refugee Service reported having seen a lawyer. By comparison, for other age groups the percentage of respondents who had been visited by a lawyer ranged from 51-65. See Jesuit Refugee Service, Becoming vulnerable in detention, pages 30 and 74. 369 Assessment of a Country Questionnaire, Improving Guardianship for Separated Children in Europe: Regional survey on current legislation and practices, survey conducted in context of a UNHCR project by the Children and Youth Ombudsman of Styria in cooperation with Asylkoordination Österreich, question 19, available in English online at: http://www.asyl.at/ umf/umf/guardianship_austria.pdf. 370 ANAFE, Statistiques relatives aux étrangers à la frontière, 2008, p. 10, available online at : http://www.anafe.org/download/generalites/statsza-nov2008.pdf. See also Human Rights Watch, Lost in Transit Insufficient Protection for Unaccompanied Migrant Children at Roissy Charles de Gaulle Airport, October 2009, p. 25ff. 62 FRA Opinion Where legislation exceptionally allows for the deprivation of liberty of a separated child, domestic law should require appointing immediately a legal representative at no cost, unless the child already has one, in addition to an independent guardian.