32. Although no official data is published on the detention of stateless people, there have been reported cases of stateless people being detained.47 Recommendations 33. Based on the above analysis, the co-submitting organisations urge reviewing States to make the following recommendations to Spain: I. Publish data on the SDP and on the stateless population in the country on a regular basis, disaggregated and bearing in mind the possible overlap with other categories such as “unknown nationality” or “people from countries without diplomatic relations”. II. Remove all possible barriers, such as language, computer literacy, absence of legal aid and lack of information, and encourage the ex officio initiation of the Statelessness Determination Procedure, including an effective referral mechanism from the asylum procedure, to ensure that the SDP is easily accessible for every person. III. Ensure that the 3-month deadline set forth in the law for the Ministry of the Interior to decide upon applications in the Statelessness Determination Procedure is adhered to in all instances. IV. Ensure that applicants are granted stay rights, work rights and documentation as soon as they lodge their applications to the Statelessness Determination Procedure, and ensure that they are guaranteed “first reception” support, on an equal basis as refugees, asylum seekers and beneficiaries of subsidiary protection. V. Allow for the facilitated naturalisation of stateless persons, with a reduced timeframe of 5 years as applied to refugees, and the removal of other possible barriers, such as strict language requirements, fees and citizenship tests, in line with Spain’s obligations to facilitate access to a nationality for stateless persons under Article 32 of the 1954 Convention. VI. Strengthen legal and policy measures, including alternatives to detention, to protect stateless persons or those at risk of statelessness from arbitrary detention, and ensure that all persons in immigration detention have access to the statelessness determination procedure. VII. Establish specific provisions in the law ensuring that statelessness, and risk of statelessness, is taken into consideration when assessing vulnerabilities. VIII. Consider acceding to the 1997 European Convention on Nationality and the 2006 Council of Europe Convention on the Avoidance of Statelessness in relation to State Succession. 47 Servicio Jesuita a Migrantes-España (SJM-E), Informe CIE 2016, page 50, available at: http://cort.as/-KBlO (Spanish) [accessed 8 July 2019]. Servicio Jesuita a Migrantes-España (SJM-E), Informe CIE 2018, page 12, available at: http://cort.as/-KzE_ (Spanish) [accessed 8 July 2019]. Fundació Migra Studium, Informe 2016 Centre d’internament d’estrangers (CIE) Zona Franca, pages 6-7, available at: http://cort.as/-KzE7 (Spanish) [accessed 8 July 2019]. 8