2020 Statelessness & Citizenship Review 2(1) determination. 40 A centralised procedure could be necessary in ensuring the same standards across a country. While a centralised system may be preferred, due consideration should be given to the need to have a certain balance between centralising expertise to conduct statelessness determination within a specialised administrative or judicial unit of trained and experienced officials, and allowing individuals to lodge applications with government representatives who might be spread out across the country. 41 This flexibility is particularly necessary in many poor countries in Africa, given the challenging context: these countries are large, and tend to have a weak national road and travel infrastructure, and poor standards of living. Allowing applications to be submitted through specialised agencies at local administrative levels spread across the country would be a preferred method. Government officials might encounter the question of whether a person is stateless in a range of contexts, reflecting the critical role that nationality plays in everyday life. For example, consideration of nationality status is relevant when individuals apply for passports or identity documents, seek legal residence or employment in the public sector, want to exercise their voting rights, perform military service or attempt to access government services. The issue of nationality and statelessness may also arise when an individual’s right to be in a country is challenged in removal procedures. 42 Therefore, it is important when designing a procedure to also make provision for the possibility of having some form of referral mechanism and pool of trained staff across relevant government agencies, equipped with knowledge to identify potential stateless persons or persons at risk of statelessness. These staff can help refer such persons to the central body or to the relevant government agency in the local government areas or districts. The design should also allow for officials to present an ex officio application on behalf of applicants when they encounter persons who are stateless or are of undetermined nationality. C Access to Procedure According to the UNHCR, for procedures to be fair and efficient, and to ensure that all stateless persons benefit from the implementation of the 1954 Convention, access to the SDP must be guaranteed and should not be subject to time limits. Information on the procedure and counselling services must be available to potential applicants in a language they understand. 43 Additionally, a good procedure should not impose time limits within which an application must be brought from the date of entry into the territory. Also in asylum systems there is typically neither a limitation of time nor a requirement of legal entry. It would be particularly unfair if stateless persons were caught by a time limit, especially in the migratory context where they may not be aware of such a procedure. Nor should a requirement of legal entry be imposed. 44 Such a requirement is 40 41 42 43 44 Handbook on Protection of Stateless Persons (n 11) 27 [63]. See Marilyn Achiron and Radha Govil, Nationality and Statelessness Handbook for Parliamentarians N° 22 ( 2nd ed, Inter-Parliamentary Union and UNHCR 2014) 20. Handbook on Protection of Stateless Persons (n 11) 25 [57]. Good Practices Paper — Action 6 (n 38) 5. Note that, protection against penalisation of illegal entry is not mentioned under the 1954 Convention. See also the difference in approach to modes of entry in both the 1951 and 1954 Conventions as highlighted in the UNHCR Handbook on Protection of Stateless Persons (n 11) 46 [127]. 93