prison work escapes from ordinary employment law and a temporary social security number is sufficient); - the conduct of formalities concerning foreigners’ residency rights is in most cases restricted on numerous grounds: institutions lacking any “legal information and advice access points” or ill-equipped due to lack of interpreters; difficulty of filing asylum applications which may be subject to processing by means of “priority” procedure, refusal of provisional grants of asylum on the part of prefectures, on the grounds of serious threat to public order, and failure to implement the provisions of the circular of 25th March 2013 12; - greater difficulty in obtaining reduced sentencing: the absence of a residence permit in practice means that foreigners are deprived of the right to seek employment contracts or training, or to claim social security benefits, and that they therefore cannot meet the conditions enabling partial or conditional release placements; foreigners may apply to serve their sentence in an institution of their country of origin, although this is only possible where bilateral agreements exist authorising this type of transfer. On the basis of these findings, the Contrôleur général des lieux de privation de liberté stressed the need to consider special measures for foreign prisoners, in order to ensure implementation of the principle of equality in prison. The conclusions of this Opinion were mentioned in an interview of 2nd September 2014 between the Minister of the Interior and the Contrôleure générale des lieux de privation de liberté. In particular, the Contrôleure Générale stressed that prefectures that have not signed an agreement with the prison services, as provided for by the circular of 25th March 2013 (cf. supra), should take the necessary measures. She recalled that, notwithstanding the signature and implementation of such agreements, the definition of “danger of disturbance of public order” needs to be interpreted in accordance with its letter and spirit, in order to ensure respect for foreign prisoners’ fundamental rights. Indeed, prefectures often tend to interpret this definition in a very wide manner, therefore refusing to issue or renew residence permits. This Opinion, whose findings unfortunately remain entirely pertinent, has not received any response nor been followed up by any concrete action to date. 12 Circular of 25th March 2013 concerning procedures for initial issue and renewal of residence permits for persons of foreign nationality deprived of liberty. 25

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