19 | PROTECTING STATELESS PERSONS FROM ARBITRARY DETENTION IN MALTA to, for example, non-cooperation, absence of information, practical difficulties, etc. 3.5 ALTERNATIVES TO DETENTION Maltese law makes no provision for alternatives to detention, saving the possibility for detained migrants to request bail from the Immigration Appeals Board.80 It is expected that the transposition into Maltese law of the recast Reception Conditions Directive will require Malta to introduce alternatives to detention into national law. Since, at the time of writing, the draft transposing law was not made available, no further information may be provided. In the context of pre-removal detention, the national transposition of the Return Directive does mention the obligation of the Principal Immigration Officer to not detain individuals if “other sufficient and less coercive measures are applicable”, clearly requiring an individual assessment as to the feasibility of applying alternatives to detention. The Regulations do not provide examples of such possible less coercive measures, and none are known to have been resorted to in practice.81 3.6 CHILDREN, FAMILIES AND VULNERABLE GROUPS The police asked us many questions and I explained everything. I told them we were born in Addis Ababa and later sent to Dekemhare in Eritrea. They wrote down Ethiopia as my country of origin, which was true. I also told them we were minors, my sister and me. They took everything we were carrying, our money, our personal belongings, etc. I begged the police woman to leave my pictures with me, the only pictures I had from my mother. I tried to explain that to her but she looked me in the eye, and tore the pictures in such small pieces that I will never be able to stick them together. They brought us to a camp in some military barracks, but we did not know what will happen next, how long we would have to stay and why would they keep us locked up. After all we had went through, I could not believe I was in Europe.” Tsegey, originally from Ethiopia Although the Maltese legislation does not provide for the identification of vulnerable groups, the public entity Agency for the Welfare of Asylum Seeker (AWAS) is responsible for the assessment and determination of vulnerability in the context of detention. These assessments are conducted through interviews by AWAS staff, generally social or care workers. AWAS also conducts interviews for determining whether persons claiming to be unaccompanied children are in fact below the age of eighteen. The Reception Regulations82 contain specific provisions for people with special needs, minors, unaccompanied minors and pregnant women, also enshrining the principle of maintenance of family unity.83 Upon confirmation of vulnerability or minor age in the case or unaccompanied children, persons are released from detention.84 In this regard, the AIDA report on Malta states that: “Due to resource and infrastructural limitations some vulnerable individuals are either never identified or, once identified, are unable to access the care and support they require”.85 Amongst other things, this report highlights concerns relating to the age assessment and adult vulnerability procedures, with a focus on vulnerabilities that are less visible than others, such as mental health problems. The report comments that the release of vulnerable persons, particularly of this group of ‘invisible vulnerabilities’, could take up to eight months.86 3.7 CONDITIONS OF DETENTION I spent four months and 10 days in detention, four months and 10 days doing nothing but eating and sleeping. I could only communicate with the dozen Bangladeshi people detained with me. Sometimes there were people visiting detention but I could not understand or ask them anything. I could not even call my family with the five euros credit they would distribute to us every two months. It would take much more than that to reach the network in Rakhine state, where my family lives. Even the medical care was scarce in there. We were given just one tablet of paracetamol, whatever pain we may have. They brought me to the clinic in handcuffs as if I was a criminal but the doctor there asked them to remove the handcuffs and gave me treatment. I sort of understand why we were often sick. We were mainly fed pasta in detention. I don’t eat much pasta as we mainly eat rice in my country. We never had any fruits or vegetables. But we did not have anything to do in detention, and the yard is so small for all the detainees, we did not get much physical activity. So you get easily sick if you have only pasta to eat and never move. You feel like a baby in detention, not in the sense that you are cared for, but in the sense of the total deprivation of anything that makes you a man. We did not even had clothes other than what we were wearing when we arrived and two boxer shorts. To wash these clothes, you had to shower in them. Kafil Kafil, originally from Myanmar But what a surprise when I arrived there. I could not believe I had finally reached Europe, the Human rights continent. They pushed us into small rooms packed with people of different nationalities. They called it B Block. It used to be a military barracks on which they had put barred windows and doors, with guards at the entrance after we entered a fenced off area full of military. The place was so dirty that I could not bring myself to shower for 25 days as I was disgusted by the