Help with filling in the Welsh RSE Consultation

The Welsh Government consultation on its new Relationship and Sexuality Curriculum is open until 16 July 2021.

Responses can be submitted in writing by post or online here: https://gov.wales/curriculum-wales-guidance-and-code-relationships-and-sexuality-education-rse

This curriculum will be mandatory for all Welsh children from the age of 3. Parents will not be able to withdraw their children from Relationship and Sexuality Education lessons. We have concerns about the Welsh RSE curriculum and the way it has been developed. We encourage parents, carers, teachers and governors to fill this consultation in while you have the chance.

The consultation questions are laid out in order below. We have included points to consider when writing your response under each question.

You don’t need to answer all of the questions. The important thing is to have your say.  

Question 1: Do you agree that the explanation of the definition of RSE is clear?

• Sexuality is defined in the guidance as ‘a central aspect of being human and encompasses sexual orientation, gender identities and roles, sex, reproduction and intimacy. Sexuality is experienced and expressed through thoughts, beliefs, behaviours and relationships.’  (p20).
  This definition comes from WHO guidelines but it is not what most people mean by ‘sexuality’. The guidance is using a word that most people associate with adult sexual desire and applying it to all Welsh children from the age of 3. This is inappropriate.

• Gender is introduced with four different definitions: a biological term, a term about identity, a term referring to social norms, and a harmful stereotype. Which definition the Welsh government is using in this document is not specified, so this is very unclear.

• Unscientific: The guidance introduces new key concepts like ‘gender identity’, ‘non binary’ and ‘assigned sex’ (p21). This is ideological and politically motivated terminology. It is also scientifically inaccurate.

Question 2: Do you agree that the principles for embedding RSE are clear?

• Bias: The document claims that RSE should be ‘pluralistic’ in nature, and yet the guidance document presents a single ideological position in relation to sex and gender: “Some people’s gender identity does not match up with the sex they were assigned at birth” is stated as a fact.
  Following this guidance would lead to a breach of the Education Act 1996, section 407 that requires local authorities and schools to take steps “to ensure that where political issues are brought to the attention of pupils…they are offered a balanced presentation of opposing views”.

• Ideology in the curriculum: The Guidance says that “RSE should be part of a whole-school approach”. As the guidance includes reference to gender identity, this suggests that schools should include content about gender identity from providers which promote this across the curriculum. But gender identity is an ideology with implications for women’s and children’s rights: it should be examined critically and not embedded as fact.

• Third Parties & Safeguarding: The Guidance says that “Effective RSE requires specialist expertise, time and resources” and “Provision should draw on specialist services and expertise”. But unlike the non-statutory guidance from the DfE (applicable to English schools) it gives no advice for schools on how those organisations and their materials should be chosen and vetted to ensure that schools fulfil their safeguarding obligations.

Question 3: Do you agree that the structure and content of the guidance is clear?

• Inconsistent content: The guidance is very unclear on the differences between sex, sexual intercourse and gender. The glossary of terms at the back, which contains unorthodox definitions, requires constant referencing to understand the new key concepts imposed.
  
• Sexist: The opportunity provided by this guidance for the replacement of ‘sex’ with ‘gender’ is fundamentally sexist. Women and girls stand to suffer the most from the disregard, if not political erasure, of sex. 

• Disability discrimination: As the Welsh RSE guidance treats gender identity as fact, and provides no information about how to choose a provider that has a proper understanding of safeguarding, there is potential for children to be taught that the answer to body dysphoria is to medically alter the body. The Bell v Tavistock judgment discussed the lack of evidence for this and the dangers of suggesting it to children. Given that according to the Tavistock and Portman NHS Trust’s own research, gender dysphoric children with either a diagnosis of autism or who have autistic traits make up nearly half of all referrals to the Tavistock, this could send many autistic children on a path to becoming sterile.

Question 4: We propose that the content set out in the three broad stages of the guidance will become mandatory as part of the RSE code. Do you agree that they encompass what is important about RSE for all learners’ ages and developmental stages?

The 3 broad stages or ‘strands’ of the Welsh RSE curriculum guidance (page 13) contain a number of high level statements. Given the lack of specific guidance about how to ensure that safeguarding is upheld, there are areas where these could be used in ways that parents would not expect:

• Bodily autonomy Strand 3, for ages 3 through to 11 refers to “the right to…bodily autonomy”. One use of the phrase ‘bodily autonomy’ relates to trans-identifying children having access to hormone treatments. This would be contrary to the decision which came from the Bell v Tavistock case that no child should be accessing puberty blockers without a court order to allow them to. Children of that age are not Gillick competent, meaning they cannot make decisions on their own about their medical treatment. It is reasonable to question what that phrase is doing there: it dilutes the responsibilities adults have to children to keep them safe. 

• ‘Be kind’ Strand 1, for ages 3 through to 11, emphasizes the need for kindness and compassion. However this is a concept that is taken advantage of by predators. Focusing on kindness will leave some children vulnerable to grooming and abuse.
  Girls are under more social pressure than boys to be kind, to their detriment. Many children, but particularly children who are autistic may struggle to comprehend that ‘be kind’ sometimes means being untruthful. Or they will follow the instruction to be kind to their own detriment, because that is what they have been told is right to do.
  In implementing this ‘strand’, schools should follow an anti-sexist, disability-aware curriculum that prioritises safeguarding. But how will the Welsh government ensure this happens? The guidance is high level, and all the supporting safeguarding information has been stripped out.

Question 5: Do you agree that the RSE code section of the guidance is clear and appropriate?

The summary under Section 2: RSE Code (page 13) says that:
“The content of RSE, set out per strand in table form within this document, reflects a number of themes: relationships, rights and equity; sex, gender and sexuality; bodies and body image; sexual health and well-being; and violence, safety and support.
Across these themes, curriculum content in RSE is to be inclusive and reflect diversity. It must include learning to develop learners’ awareness and understanding of different identities, views and values and a diversity of relationships, gender and sexuality, including LGBTQ+ lives.”

• The term “gender” is not clearly defined, and therefore how the RSE guidance is using it is not clear.
• The term “equity” is defined briefly but it is not clear why it has replaced ‘equality’, nor how schools should deliver it.
• The term “rights” is used without context. It should be made very clear that children have a right to single sex facilities on the basis of sex, not “gender”. It would be helpful if there were clarification on the Equality Act regarding single-sex facilities.
• The term “sexual health” is used without clarity on how that interacts with gender ideology. Girls benefit from being taught about maintaining ongoing urinary health, identification of UTIs and other conditions such as cancers (and required cervical screening) that commonly affect women. Similarly, men and boys would benefit from being taught about conditions that specifically affect their biological sex, such as prostate cancers. Biological sex is not the same as gender identity, and it is essential this is recognised in teaching and learning.

Question 6: Do you agree that the mandatory elements of the guidance (the RSE code) are the right ones? Is anything missing that should be included?

• Absent content, The “broad strands” are extremely patchy, missing out important information such as:
  
  • online harms
  • staying safe including from grooming
  • sexual harassment
  • sexism
  • sex discrimination
  • illegal and prescription drugs.
  • female genital mutilation
    
    There will be young people in schools directly affected by FGM, and there must be clear guidance on how to support students and teachers with disclosures and safeguarding emergencies. 

• Safeguarding Concerns There is a total absence of safeguarding principles and practices, or any links to relevant child protection resources and guidance. The nature of RSE often leads to disclosures. Schools must be prepared for this with appropriate and comprehensive guidance. It is extremely worrying that this information appeared in earlier versions, but safeguarding and child protection information has now been removed. 

• Balanced information: If the Welsh RSE curriculum covers ‘gender’ then it should also cover the physical harm caused by puberty blockers, such as the impact on brain and bone development. Puberty blockers lead to cross-sex hormones almost 100% of the time, and these cause infertility and vaginal atrophy. The fact that it is scientifically impossible to actually change sex must be made clear to children and young people at an appropriate stage of their development. Children need to be given a safe environment to learn about and come to terms with their bodies as they are.
  
  

Question 7: Do you agree that the guidance offers relevant information to support practitioners when designing their school curriculum for RSE?

• Inconsistency: one of the aims of a compulsory RSE curriculum is to reduce the risk of patchy and inconsistent curriculum delivery. This guidance does nothing to allay such concerns. Responsibility and liability still resides with schools and yet this curriculum and guidance gives them very little to work with except the requirement to introduce all Welsh children to ideologically biased materials and concepts as fact. 

• Third parties :The curriculum strongly suggests that third party “expertise” should be used in the teaching and development of this curriculum. However there is no guidance on who would be an appropriate third party, teacher oversight and presence in the classroom, content checking or areas to avoid. This leaves schools open to possible conflict with parents as well as introducing potential safeguarding risks.

• Unbalanced: No alternative organisations or perspectives on ‘gender’ are indicated, such as those put forward by Safe Schools Alliance, Transgender Trend or Bayswater Support, who are more balanced in their approach to gender confused children.
  
• Safeguarding: It is good that there is some information on violence, safety and support but the Welsh RSE guidance is otherwise devoid of safeguarding and child protection protocol. Sexual health education often leads to disclosures. It is deeply disturbing that the schools guidance fails to consider fundamental principles of safeguarding and child protection.

Question 8: We would like to know your views on the effects that the RSE draft statutory guidance would have on the Welsh language, specifically on:

i) opportunities for people to use Welsh

Some parents who do not feel their children are safe in Welsh schools as a result of this political curriculum will not be sending their children there. Therefore they will not be learning Welsh unless it is already in the home. This compulsory RSE indoctrination has the potential to alienate children and their families from schools, communities and the Welsh language. The risk of conflict with parents, carers and concerned stakeholders is significant.  

ii) treating the Welsh language no less favourably than the English language.

Issues may be lost in translation, particularly when the original definitions are unclear.

Question 9: Not commented on

Question 10: We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to report them.

• Parenting Rights There is no respect of parental rights, responsibility and involvement in the development and delivery of this Welsh RSE curriculum. Parents are permitted only to view RSE policies, not the actual resources that will be used. 

• Excluded Stakeholders Throughout the entire development of this curriculum parents and concerned stakeholders have been excluded from the developmental process and ‘consulted’ at the end. This suggests that this curriculum has been decided on in advance and is ideologically motivated.