Wales Watching

By Safer Schools Wales

Trans women are women, trans men are men, and non-binary identities are valid.”

Welsh Government, 2023

Smaller than the state of New Jersey, and with a population of just over three million, Wales has always been a nation which punches above its weight, leaving a mark on culture and society far exceeding its size. One area in which it hopes to continue this tradition is in ‘LGBTQ+ rights’, with First Minister, Mark Drakeford, last year announcing the Welsh Government’s (WG) ambitious target to ‘…make Wales most LGBT+ friendly nation in Europe.’

To achieve this target, the Welsh Labour government (supported by Welsh nationalist party, Plaid Cymru, under their Co-Operation Agreement) launched its LGBTQ+ Action Plan in February this year. This keystone document lays out a raft of proposals, including in areas of legislation devolved to Wales by the UK Government, namely education and healthcare. On reading the Action Plan, it soon becomes clear that the focus is very much on trans identities and the integration of gender identity ideology into all areas of public policy and institutions. This is perhaps unsurprising when considering the membership of the Independent LGBTQ+ Expert Panel which informed it.

The Independent LGBTQ+ Expert Panel’

The Independent LGBTQ+ Expert Panel was convened by WG in 2021, and is made up of thirteen people, including three representatives from Glitter Cymru (an organisation set up to ….support the BAME [Black, Asian and Minority Ethnic] LGBT community in South Wales’), two from Stonewall, one from Pride Cymru, and Dr Sophie Quinney (a self proclaimed ‘member of the LGBTQI+ community’ and ‘gender affirmative’ Clinical Director and GP Gender Clinician at the Welsh Gender Service). Many of the panel’s recommendations from its 2021 report to WG were carried through to the final action plan, including many of those in healthcare and education.

Healthcare

Recommendations in the panel’s report included ‘trans specific’ ones. Here are some examples:

  • Establish an NHS Wales gender identity service for children and young people, providing an affirmative approach to care in line with international clinical standards
  • Develop the Welsh Gender Service into a primary-care led model, with GPs able to initiate hormone therapy
  • Ensure parity of access to gender identity services for non-binary people

It is clear that the ‘international clinical standards’ referred to in the report are those of the highly-controversial WPATH, who are referenced several times in it, though WPATH is not referenced in the Action Plan itself.

Within the Action Plan, proposals include to ‘Review the Gender Identity Development pathway for young people in Wales’with the stated outcome being that ‘Trans Children and Young People in Wales can access services closer to where they live’ and that ‘Health services for trans children and young people are focused on clinical need and based on evidence.’This follows the publication of the Cass Review interim report and the ensuing closure of the Tavistock GIDS, where Welsh patients referred for gender identity services were previously sent. After I wrote to her last year about plans for Welsh services in light of the Tavistock GIDS closure, the Health Minister, Eluned Morgan, replied:‘Following the recent announcement regarding the closure of the Tavistock Centre in London, WHSSC [Welsh Health Specialised Services Committee] is working closely with the Cass Review team NHS England to ensure Welsh children and young people have access to the regional centres whilst the development of a clinical model for Wales is explored.’

While this should provide some reassurance that any new service will be developed with a sound evidence base underpinning it, there is no reference to Cass Report in the Action Plan or other WG publications. The expressly affirmative approach taken by the Welsh Gender Service (WGS) under Dr Quinney should be cause for concern for those who support a more exploratory approach to gender-related distress. The affirmative language used—‘trans children and young people’—highlights the set of assumptions and beliefs baked into the Action Plan and the wider health service in Wales.

A quick scan of the WGS’ website gives a clear indication of their approach. It has links to ‘LGBTQ+’ organisations like Umbrella Cymru, MORF Binder Exchange Scheme, and an article in Pink News, titled ‘Coming out as autistic and LGBT – and why it should be celebrated’, as well asinformation on how to legally change one’s name.One link included on the site’s homepage is to a ‘Trans Health Series’ YouTube video about vaginoplasty, in which Dr Quinney interviews Consultant Surgeon James Bellringer about the process. While the video covers some of the potential complications from the surgery, it is notable that it lacks any discussion about the magnitude of such a decision or considerations about its suitability prior to surgery.

In all, the WGS website has the haphazard, amateurish feel of one put together by a team of activist clinicians operating in a highly controversial and quasi-rigorous field of medicine, rather than a site providing the kind of cautious, factual, and well-evidenced information the public expects from an NHS webpage. Putting oneself in the shoes of a gender-distressed child or their parent, one gets the sense from the site that altering one’s body is the obvious and natural and path forward.

While the dust settles from the Tavistock GIDS closure and new structures are put in place, Wales is already moving towards a regional model, with the WGS providing links to ‘Local Gender Teams’. One such team, the Cardiff and Vale University Hospital Board (CAVUHB), operating under Dr Simon Braybrook out of Butetown Medical Practice, proudly displays the progress flag as the first image on its webpage, with the caption, ‘LGBT Friendly Practice. Always Trans Affirming’.

This all points to support for experimental ‘gender affirming care’ in Wales, just as other countries (including left-leaning Nordic countries which WG and those in favour of Welsh independence often look to as a model for government) are rethinking their approaches to gender identity care and moving away from an affirmative medical model in light of evidence and safeguarding concerns.

Education

This is the area which has attracted most attention in the media, largely relating to the mandatory Relationships and Sexuality Education (RSE) curriculum, which was launched by Education Minister Jeremy Miles in 2021. The new curriculum’s development was led by Professor of Childhood Studies at Cardiff University EJ Renold. The bulk of Renold’s academic work focuses on queering education and transhumanism. For example, in her 2005 book, Girls, Boys and Junior Sexualities: Exploring Children’s Gender and Sexual Relations in the Primary School, Renold says, ‘Queering childhood involves not just the queering of sex/gender and sexual binary oppositions such as male (masculinity)/female (femininity) and heterosexual/homosexual, but also the generational binaries ‘adult/child’ and ‘sexual/asexual’.

Since her involvement in Welsh RSE, Renold has been notable by her absence, but the resources she developed to support the curriculum—resources endorsed by WG and the National Society for the Prevention of Cruelty to Children (NSPCC), amongst other organisations—are still available online. CRUSH and AGENDA are both steeped in queer theory and have an openly activist approach to gender identity. They were previously held on Hwb, the education portal for schools and students, alongside resources from Stonewall, who WG and Welsh local authorities have paid millions to over recent years. Safe School’s Alliance UK, Transgender Trend, and Merched Cymru have written extensively about the Welsh RSE curriculum—its promotion of gender identity ideology, its queer theory foundations, and its close alignment with the UNESCO ‘Comprehensive Sexuality Education (CSE)’.

The WG’s Curriculum for Wales – RSE Code guidance itself is sufficiently vague and open to interpretation in its approach to ideas of gender identity, using both ‘sex’ and ‘gender’, at times interchangeably. Schools have been asking for clarification from WG and local authorities on how to teach this contentious topic under the new ‘Curriculum for Wales’, but little has been provided so far, with responsibility being pushed back on schools.

WG are due to publish transgender guidance for schools this autumn, but until now, schools have been reliant on often inappropriate and outdated guidance from local authorities. Issues with the toolkits being used by local authorities were highlighted in 2021 when Rhondda Cynon Taf council were required to review their guidance following the social transition of a secondary school student. Recent transgender guidance consultations have shown some improvements, with the Vale of Glamorgan Council (who are members of Stonewall’s ‘Diversity Champions’ programme) recently acknowledging the interim Cass report’s assertion that social transition is not a neutral act. However, there is still a clear ideological set of assumptions and language within such guidance and toolkits, and significant safeguarding concerns remain, including around the provision of mixed-sex toilets in schools. Guidance also promotes embedding LGBTQ+ issues and gender ideology not just in RSE lessons, but throughout all aspects of school life and through all areas of the Curriculum for Wales.

Supporting the rollout of RSE, the organisation Brook Learn were contracted earlier this year by Central South Consortium (CSC) (a consortium of all schools in five local authorities in south Wales) to provide online professional learning sessions, including sessions on supporting ‘LGBT+’ young people. While the material delivered is not publicly available, many concerns have been raised about Brook’s ideological approach to RSE, as highlighted in a recent report commissioned by Miriam Cates MP on RSE. A quick read of Brook’s gender definitions gives an indication of their beliefs around gender identity.

In 2021, the schools inspectorate in Wales, Estyn, produced good practice in which it references the infamous and highly-controversial ‘No Outsiders project, a project run by academics with an interest in ‘queering primary education’. This suggests that there is likely to be increased focus on schools’ implementation of gender ideology through school inspections under the banner of diversity, equality, and inclusion.

There has been substantial pushback from parents and different groups about mandatory RSE, including an unsuccessful judicial review in September 2022, which found that the content of RSE did not ‘breach the prohibition on indoctrination’ and that it was designed to be ‘inclusive’ and ‘reflect diversity.’ While the challenge was focused more broadly on the appropriateness and ideological nature of RSE and did not focus specifically on gender identity, this was a core concern raised by the five claimants, who plan to appeal the decision.

Another area of concern is schools counselling services. Under the School Standards and Organisation (Wales) Act 2013, local authorities are ‘required to make reasonable provision of independent counselling services for children and young people aged between 11 and 18 and pupils in Year 6 of primary school.’1 Unlike in England, in Wales, children and young people above Year 6 (10-11 years-old) who access counselling services through schools are not required to have parental consent.

To support the delivery of counselling in schools, WG produced a ‘School and community-based counselling operating toolkit (revised 2020)’ which aims to provide best practice guidance for counsellors and schools.

Under the section titled ‘Non-binary and transgender children and young people’, the document explains that ‘Not all children experience themselves to be exclusively male or female, boy or girl, either in an embodied sense, an internal sense or in terms of their social gender (or a combination of these).’It then goes on to add, ‘A growing number of children and young people identify within a range of gender spectrums, with research indicating the effects of early transition having a positive impact on well-being, as well as demonstrating that access to transition support improves emotional well-being.’

The document lacks any exploration of the comorbidities associated with gender dysphoria and trans identification, the impact of social or medical transition, the potential social and cultural factors in trans and non-binary identification, the associated safeguarding issues, or the role of parents. It instead promotes the work of Sam Hope (MBACP) as ‘a therapist and prominent writer in this field’, recommending his ‘10 Tips for Working with Trans Students’ as a useful guide for counsellors. Amongst other highly contentious suggestions, Sam says we should ‘Rethink Safeguarding: Focus on the known safeguarding risk (high risk of abuse and suicide for the trans person, due to social isolation and stigma) rather than imagined risk (trans person somehow overcoming their social marginalisation enough to have the power to harm other students). Peer support & inclusion are essential.’

What this shows is that WG are encouraging school counsellors to take an ideological and experimental affirmative approach to working with gender identity issues in young people, and signposting them to highly controversial resources, often without parental knowledge and with scant regard for the potentially huge safeguarding issues for the individual and his or her peers.

Conversion Therapy Ban & Gender Recognition Reform

With it looking likely that Labour will lead the next UK Government, we will undoubtedly see Welsh Labour push for more devolution of powers to Wales, with one such power being the ability to reform the Gender Recognition Act 2004. UK Labour recently suggested they will not push ahead with gender self-ID reforms, putting them at odds with Welsh Labour. As a concession for this, they may devolve powers in this area to Wales to allow them to deliver their policy commitments. The LGBTQ+ Action Plan states:

‘…we will ban all aspects of LGBTQ+ conversion practices that are within our current powers and seek the devolution of any necessary additional powers to enable us to achieve this. In addition, we will seek the devolution of powers in relation to Gender Recognition and support our Trans community.’

As is currently being debated in the in the rest of the UK, plans to include gender identity in legislation to ban conversion therapy are highly contentious due to fears they will prevent clinicians, therapists, and, potentially, parents from exploring the causes of gender distress in children and young people.

With the LGBTQ+ Action Plan and RSE curriculum now embedded, the strong influence of Stonewall and other transgender lobby groups, an activist LGBTQ+ Independent Expert panel, and with ‘LGBTQ+ rights’ being core components of an emboldened Welsh Labour’s programme for government: it would appear that gender identity ideology has found a home in Wales and is here to stay. However, as seen in Scotland and around the world, there is unlikely to be strong public support for many of WG’s proposals, and we are likely to see further scrutiny and criticism from parents, teachers, and health professionals as policies make contact with reality and the lack of strong evidence for their efficacy is exposed.

There are positive signs of change over the border in England, but with all the conditions for a perfect storm here, those of us concerned with the impact of gender identity ideology on public life and the health and well-being of all children and young people must keep watching Wales.

(Fersiwn Cymreig ar gael yma)


The author is a parent and qualified teacher living in south Wales who is concerned about the impact of gender ideology and critical social justice on society. He supports a return to factual, non-partisan, non-discriminatory and age-appropriate policy and practice in Welsh education.

Header image by Ian Procter from Pixabay


1 Welsh Government, 2023: ​​Counselling for children and young people: September 2021 to August 2022 | GOV.WALES