A/HRC/45/16/Add.1 unaccompanied children from Greece, which led to the relocation of 59 children in April 2020. 3. Age assessment 73. According to article 14 (9) of Law No. 4375/2016, whenever there is doubt as to whether a third-country national or stateless person is a minor, an age assessment is undertaken and, until the assessment ruling is issued, the person is presumed to be a minor. According to article 6 of Joint Ministerial Decision No. 92490/2013, age assessment is to be conducted in three consecutive stages: clinical examination by a paediatrician; psychological and social expert evaluation; and medical examination of skeletal age. Article 6 (8) of the decision provides for procedural guarantees, including ensuring that the person is represented throughout the procedure, obtaining consent and ensuring that the primary consideration is the best interests of the child. 74. The Working Group notes that these provisions are not being applied in practice. At present, the police reportedly rely primarily on X-ray and dental examinations under the third step of the age-assessment procedure. Persons claiming to be children are not generally represented or informed of their rights in a language that they understand during the assessment. In order to challenge the outcome of the assessment, the person must submit an appeal to the secretariat of the reception and identification centre within 10 days of notification of the decision, which poses difficulties for persons who cannot access the relevant documentary proof of their age within such a short time frame. 75. Joint Ministerial Decision 1982/2016 on the age-assessment procedures initiated by the Asylum Service applies when there are serious doubts about the age of a person lodging an application for international protection, with similar provisions and procedural guarantees. A new joint decision is planned to be issued by the Minister of Migration and Asylum and the Minister of Health in order to adopt a common approach for age assessment in both the identification and the asylum procedures. 76. Minors are thus being detained unnecessarily owing to inaccurate assessment procedures, and are treated as and detained with adults. The Working Group recommends that the authorities consistently apply the guarantees outlined above, particularly the presumption that a person is a child unless the contrary can be proven. The Working Group reiterates the Greek Ombudsman’s call to the Government in 2018 to put a complete end to all administrative detention of migrants under the age of 18 years. 4. Vulnerability assessment 77. Greek law does not prevent the detention of vulnerable individuals or groups. However, the law contains guarantees for such individuals. Under article 20 of Law No. 4636/2019 (as amended), vulnerable persons include minors, family members of victims of shipwrecks, persons with disabilities, older persons, pregnant women, single-parent families with minors, victims of trafficking, persons with severe health conditions, persons with intellectual or psychosocial disabilities or mental health conditions, victims of torture, rape or other severe forms of psychological, physical or sexual violence. The vulnerability of an individual must be assessed by the Reception and Identification Service prior to registration of an asylum application or during the asylum process, and is a factor in determining whether to detain or prolong detention. 78. According to article 46 (4) of Law No. 4636/2019, any relevant decision on a person’s detention must be justified for each person. 79. The determination of vulnerability has been critical to the immigration and asylum procedures, at least until the entry into force of the new law on international protection, under which the vulnerability assessment is no longer associated with the type of asylum procedure to be followed. Before November 2019, if a person was determined to be part of a vulnerable group specified in the legislation, the geographical restriction to remain on the island at which he or she arrived or was registered was lifted, and the person could travel freely within Greece without risk of arrest. The consideration of asylum applications was also partially prioritized, for the most vulnerable groups. 13