16 | PROTECTING STATELESS PERSONS FROM ARBITRARY DETENTION IN BULGARIA centre in the period from 2012 until April 2016 has been 40 days.58 The number of negative responses in this regard is listed in Table 3 below. Regarding detention of persons of ‘unknown citizenship’, the official replies of the Ministry of the Interior are contradictory. In a freedom of information decision of 14 October 2015, the Ministry of the Interior replied that taking 9 October 2015 as a reference point, there were two persons of ‘unknown citizenship’ and one stateless person in detention.59 However, in its freedom of information decision of 21 June 2016, the Ministry of Interior replied that for the period 2007 – 31 May 2016, no persons of ‘unknown citizenship’ were detained. Table 3: Number of negative answers to readmission requests made by Bulgaria by year There is no other statistical data on the nationality of immigration detainees besides that collected by the Bulgarian government. Upon their monitoring visits to the Bulgarian detention centres, UNHCR representatives employ the data provided to them by the Bulgarian state authorities.60 Going back to the statistics for the year 2015, the statistical data collected on efficiency of detention for the purpose of removal is as follows: 755 persons have been removed, for 16 persons there have been negative readmission answers, while 11,902 individuals have been in the regular detention centres of Bousmantsi and Lyubimets. It therefore remains unknown what has happened with the outstanding 11,131 persons. In 2015 there were 11,902 detained persons in the Bousmantsi and Lyubimets detention centres in Bulgaria, but only 755 of them were removed from Bulgarian territory.61 In a freedom of information request under this study, we asked the Ministry of Interior the number of detainees who have been released following detention, because their removal order was not implemented due to the impossibility to obtain the necessary documentation from third countries. The Ministry of the Interior replied that “there are no statistics on release from detention on this criterion”. We asked the Ministry of Foreign Affairs of the Republic of Bulgaria what statistical data is collected regarding the documents provided by third countries for the return of their citizens. The Ministry of Foreign Affairs replied62 that it does not collect any statistics in this regard, although it plays a role in the communication with those countries. The Ministry of Foreign Affairs also stated that it does not have information on the number of positive and negative answers to the requests addressed to third countries to provide documents for the return of their citizens. For further information in this regard, the Ministry of Foreign Affairs forwarded the freedom of information request to the Ministry of Interior. In a follow-up reply to the forwarded questions, the Ministry of Interior stated63 that the General Directorate ‘Border Police’ is the competent body within the Ministry of Interior structure to implement the readmission agreements concluded by Bulgaria. Therefore, the answer to the posed questions was narrowed down to the implementation of readmission agreements. The Ministry of Interior replied that the refusals to readmit third country nationals upon requests made by Bulgaria have been based on two main grounds: either the persons cannot be identified as citizens of the requested country or there is not sufficient proof that the foreign nationals have resided on the territory of the requested country. Year Number of refusals to readmit 2014 17 (14 by Pakistan, 1 by Russia and 2 by Greece) 2015 16 (10 by Pakistan, 1 by Serbia and 5 by Greece) 2016 (up to 31 May) 18 (8 by Pakistan and 10 by Greece) According to the SAR, in 2015 there were 125 stateless persons who sought asylum in Bulgaria. In 2015 the chairman of SAR issued 162 decisions on applications for asylum by stateless persons: in 68 of them SAR granted refugee status, in 26 of them SAR granted subsidiary international protection, in 15 of them SAR rejected the asylum application and in 53 of them SAR discontinued the asylum procedure.64 Regarding the number of stateless residents in Bulgaria, the Ministry of Interior provided statistics of those who are lawfully residing (see Table 4 below).65 Table 4: Number of residence permits issued to stateless persons in Bulgaria by year Year Continuous residence66 Permanent residence Long-term residence 2007 49 14 - 2008 41 21 - 2009 33 8 - 2010 33 16 - 2011 23 16 - 2012 26 15 - 2013 40 20 - 2014 57 6 - 2015 67 14 - 01 January – 31 May 2016 23 2 -