A/HRC/45/16/Add.1 allegations of such pushbacks, including any acts of violence or ill-treatment that may have occurred during such incidents, and to ensure that such practices do not occur in future. 88. The Working Group was informed that the European Border and Coast Guard Agency offered an anonymous complaints mechanism. While the Government indicates that no complaints were made through this mechanism in 2019 for irregular pushbacks, the Working Group considers that it may be a useful means of ensuring that any allegations of pushbacks are received and investigated by the appropriate authorities. 7. Legislative amendments and the announced policy on migration 89. The Working Group notes the entry into force of Law No. 4636/2019 on 1 January 2020. The new provisions appear to introduce more restrictive procedures that may compromise the general legal principle that detention of asylum seekers is exceptional and should be resorted to only where provided for by law and where necessary to achieve a legitimate purpose. 90. According to article 46 of Law No. 4636/2019, persons applying for international protection may be detained, if necessary, regardless of whether they apply for asylum while in detention or not. In addition, as outlined above, the Asylum Service will no longer provide a recommendation regarding the detention to the police. 91. The Working Group also notes that the extension of the maximum detention period for asylum seekers from 3 months to 18 months, which may reach 36 months if added to immigration detention, appears to treat the detention of migrants and asylum seekers as the rule and not the exception. The Working Group is concerned that these provisions are not in accordance with the principles of proportionality, necessity and reasonableness, which should govern measures of deprivation of liberty in the context of migration to ensure that such detention is a measure of last resort.8 92. The Working Group is aware of the Government’s plans to establish five new centres on the islands of the northern Aegean at the sea borders with Turkey to create more space to accommodate asylum seekers. It is unclear whether and to what extent these centres will be closed centres, meaning that residents are in effect deprived of their liberty. The Working Group received numerous allegations that the facilities, as created by the new law and in accordance with the Government’s policy, will indeed be closed, as opposed to de facto open centres such as the existing reception and identification centres. The authorities have argued that the term “closed” means only that the entrance and exit of the centre will be controlled. 93. It is important to ensure that any new centres are open centres and do not reinforce the practice of detaining asylum seekers. However, the plans also reportedly include the creation of centres for unaccompanied minors staffed by doctors and psychologists, which may be a positive development if they are not closed centres. C. Deprivation of liberty in the context of psychosocial disability and social care 94. The Working Group was informed that psychosocial disabilities are increasingly common as a result of the economic crisis in recent years. The Ministry of Health is prioritizing the deinstitutionalization of persons with psychosocial disabilities whenever possible, which is commendable and has resulted in community-based care being made available to more individuals. For example, Dromokaiteio Psychiatric Hospital in Attica provides hospices, boarding houses and supported-living apartments to allow persons to live independently in the community. 95. With regard to the care institution for children and young adults with disabilities in Lechaina, the Working Group encourages the Government to continue with the deinstitutionalization process and to provide it with sufficient resources and personnel to 8 Revised deliberation No. 5, paras. 12–13. 15