We prepared the following briefing ahead of the House of Commons debate on the epetition calling for a Government ban on Conversion Therapy. At the end of the debate, Equalities Minister Kemi Badenoch gave a measured speech stressing the government’s view that conversion therapy has “no place in a civilised society” and that the government is taking time to ensure that they get it right.
There followed a furore, with Jayne Ozanne resigning from the government’s LGBT+ advisory panel, accusing ministers of creating a “hostile environment” for LGBT+ people. Resignations followed by James Morton and Ellen Murray, and a letter expressing “deep concerns” was sent to Ms Badenoch by organistions including Stonewall and Trans Media Watch as reported by the BBC.
We support the measured and thoughtful response from Kemi Badenoch and have therefore decided to publish our briefing publicly to balance the reaction from the LGBT+ lobby, along with the submission from MP Alicia Kearns calling for a government ban on “LGBTQ+ conversion therapy.” As this demonstrates, and our briefing evidences, the definition of ‘conversion therapy’ has been expanded into “Q+” areas of sexuality and the called-for government ban is no longer about gay conversion therapy, but covers a much wider agenda.
Conversion Therapy Briefing
1. Sexual Orientation
Our recommendation is that if the government decides that conversion therapy is a government matter, it cautiously approves on principle professional practice guidelines against the practice of ‘gay conversion therapy’ with the caveat that for the sake of freedom of choice, those who feel conflicted about their sexual orientation should be able to access truly neutral counselling to explore the issues. This is especially important as groups such as Stonewall are now promoting ‘sexual orientations’ such as ‘ACE’ (asexual). A person may not be happy about being asexual; it may be the result of trauma such as childhood sexual abuse, and such people should not be denied the opportunity of neutral counselling.
The government should be clear about the definition of same-sex attraction. Stonewall has redefined same-sex orientation as ‘same gender’ orientation, redefining a heterosexual male as a ‘lesbian’ if he ‘identifies’ as such. This has led to young lesbians facing accusations of transphobia if they refuse to consider transwomen as potential sexual partners. Stonewall also defines sexual orientation as an ‘identity’:
“SEXUAL ORIENTATION is a person’s sexual attraction to other people, or lack thereof. Along with romantic orientation, this forms a person’s orientation identity.” (An Introduction to Supporting LGBT Young People, 2020, p. 68)
We see evidence that, as in the increasing number of gender identities, sexual orientation is being reframed as a spectrum of identities, including (so far) pansexual, asexual, grey-sexual, demi-sexual and queer. Evidence shows that sexual practices such as fetish, kink and BDSM are being reframed as sexual orientations/identities which cannot be questioned. For young people, young women in particular, such practices may be an unhealthy/unsafe choice, or a response to trauma or coercion. In this case would therapeutic exploration be viewed as ‘conversion therapy’? (see Appendix B).
2. Gender Identity
Therapy for gender dysphoria is not ‘conversion therapy’. The government should not include ‘gender identity’ in any legislation on conversion therapy without specifically clarifying this point, nor conflate this term with sexual orientation. The addition of ‘gender identity’ to any policy on ‘gay conversion therapy’ leaves therapists with no option but to agree with a patient that they are really the opposite sex, foreclosing any possibility of exploration of feelings and meanings, or underlying issues/mental health problems that may have lead to a cross-sex identity, for fear of being accused of ‘conversion therapy.’ This puts children and young people particularly at risk of progressing to a medical transition with lifetime consequences they may later regret. (See for example Keira Bell).
Framing proper therapeutic support as ‘conversion therapy’ mandates ‘affirmation’ as the only legitimate response to children and young people with gender dysphoria. There is no evidence to support this experimental one-size-fits-all approach which serves to cover up any underlying mental health problems or trauma, leaving young people without the mental health support they need. Health professionals have a responsibility to provide normal duty of care to gender dysphoric youngsters. ‘Gender identity’ is not a protected characteristic, has no objective meaning, and its addition to any legislation on conversion therapy would prohibit therapists from offering the same standards of care to young people suffering gender dysphoria as for any other troubled youngster.
Recommendations for Government Response to the E-Petition
Sexual orientation and ‘gender identity’ are two distinct categories which must be considered separately.
Sexual orientation must be defined in line with the protected characteristic ‘sexual orientation’ as defined in the Equality Act 2010.
1. Background: The Memorandum of Understanding on Conversion Therapy
1.1 The first version of the Memorandum of Understanding on Conversion Therapy (MOU v1) was published in 2015. The MOU is a semi-legal professional practice guide for all professional therapy and counselling bodies.
1.2 The MOU v1 was widely acclaimed and signed by all professional bodies as well NHS England. It is a guide to protect lesbian and gay people from therapists and counsellors who may try to convert them to a heterosexual orientation.
1.3 In 2017 ‘gender identity’ was added to the MOU. The 2017 version (MOU v2) states:
“For the purposes of this document ’conversion therapy’ is an umbrella term for a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other, and which attempts to bring about a change of sexual orientation or gender identity, or seeks to suppress an individual’s expression of sexual orientation or gender identity on that basis.”
1.4 The addition of ‘gender identity’ changes the MOU from a guide that protects lesbian and gay people to a guide that puts pre-gay and lesbian children, and lesbian and gay adolescents at risk of a new form of gay conversion therapy: medical transition to the opposite sex and a ‘heterosexual’ orientation.
2. Sexual orientation and ‘gender identity’ should not be conflated
2.1 Sexual orientation and gender identity are two very different things which should not be confused, but treated separately.
2.2 Everybody has a sexual orientation, this is an uncontroversial fact. There is no scientific basis for the claim that everybody has a ‘gender identity’, defined as an innate ‘knowing’ or sense of being male or female, independent of either biological sex or socialisation as a boy or girl.
2.3 Sexual orientation involves no medical alteration of the body leading to potential infertility, loss of sexual function and becoming a medical patient for life.
2.4 Gender identity has no scientific, biological or legal definition, it is a term wholly manufactured by activists and promoted to children and young people as fact online and in schools.
3. Why MOU v2 puts lesbian and gay youngsters particularly at risk
3.1 It is a widely established fact that a cross-sex identity in childhood is overwhelmingly predictive of homosexual orientation in adulthood. The next most likely outcome is heterosexual orientation with resolution of gender dysphoria by the end of adolescence. Becoming transsexual in adulthood is the least likely outcome. Around 80% of children will naturally outgrow a cross-sex identity during puberty if left alone.
3.2 MOU v2 essentially mandates ‘affirmation of preferred gender’ as the only legitimate response to a young person presenting with gender dysphoria, eg. a girl who says she is a boy must be ‘affirmed’ as a boy; a boy who believes himself to be a girl must be ‘affirmed’ as a girl. This creates a self-fulfilling prophecy.
3.3 ‘Watchful waiting’ is the global established approach towards a young person with gender dysphoria. This is a developmentally informed approach which may involve exploration/family therapy etc. Data on adult outcomes was derived from studies drawn from the watchful waiting approach.
3.4 Affirmation and ‘social transition’ is not a clinically developed approach but a mandate by transgender activists who claim that any other approach is ‘conversion therapy.’ There is no research or evidence to support the affirmation approach.
3.5 Gay and lesbian adolescents tend to be more gender non-conforming, may be bullied and may feel ashamed of their emerging sexual orientation and develop internalised homophobia, making them more vulnerable to the message that they were ‘born in the wrong body’.
3.6 A 2017 study has shown that exposure to sustained homophobic bullying and name-calling can change a young person’s gender identity. In schools now a young person will find that a ‘trans’ identity is more acceptable among peers than being gay or lesbian.
3.7 A 2019 study of adolescents and young adults referred to a UK gender service (16 – 25years) reports that many transgender people identify as lesbian, gay, or bisexual and experience homophobic bullying before later identifying as transgender, and that gender non-conforming girls are most at risk of being bullied.
3.8 A study of referrals of adolescents (12+) to the Tavistock in 2012 showed that, of the girls, 67.6% were lesbian and 21.1% were bisexual. Of the boys, 42.3% were gay and 38.5% were bisexual.
3.9 Keira Bell, who describes herself as “within the LGB”, is an example of an adolescent who felt she was ‘wrong’, changed her ‘gender identity’, medically transitioned and then regretted her choice and now sees clearly how susceptible she had been as a teenager to the pressures to understand and define herself as ‘transgender’. She is left with irreversible lifetime physical changes to her body including a deeper voice, facial and body hair, male pattern baldness and a double mastectomy. She does not know if she has lost her fertility.
4. Other groups of young people at risk
4.1 Referral patterns to the Tavistock Gender Identity Development Service (GIDS) shows 35% exhibit moderate to severe autistic traits. Autistic children tend to be gender non-conforming, find it difficult to conform to gendered social rules and prescribed gender roles, and experience high levels of bullying.
4.2 Adolescents who present to gender clinics have elevated rates of pre-existing mental health disorders.
4.3 Teenage girls make up over three quarters of referrals to the Tavistock GIDS. The historically unprecedented rise in the number of adolescent girls who identify as boys mirrors the steep rise in the rate of mental health issues, self-harm and suicide figures for adolescent girls. 
4.4 In a study of parental reports by Dr Lisa Littman, females made up 82% of cases. Parents reported that 41% had expressed a non-heterosexual sexual orientation before identifying as transgender and 62.5% had been diagnosed with at least one mental health disorder or neurodevelopmental disability prior to the onset of their gender dysphoria. 86.7% of the parents reported that, along with the sudden onset of gender dysphoria, their child had an increase in their social media/internet use and/or had multiple friends in their friendship group who had identified as transgender.
4.5 Medical intervention for adolescents who identify as transgender is based on low or very low quality evidence and the long-term results are unknown. Puberty blockers followed by cross-sex hormones will result in infertility. An analysis of all published studies by Professor Carl Heneghan concluded:
“The current evidence base does not support informed decision making and safe practice in children.”
Whatever decision the government makes, ‘gender identity’ should not be included in any policy on conversion therapy without specific protections built in for therapists and a clear definition of what is not conversion therapy. To do so would put children and young people at risk of medical harm. The High Court in the Bell v Tavistock judicial review found that children under the age of 13 are ‘highly unlikely’ to be able to give informed consent to puberty blockers, for those under the age of 16 it is ‘highly doubtful’ and clinicians treating 16 and 17 year-olds must also seek authorisation from the Family Court if there is any doubt that the treatment is in the child’s best interests. The judgment shows how serious the harms done to children have been under previous ‘gender affirming’ protocols.
Keira Bell has said that what she needed was mental health support, not ‘affirmation’ that she was really a boy. There is no way of knowing what percentage of the recent cohort of adolescents will go on to regret medical intervention with lifelong effects. One study of detransitioned young women indicates that medical transition is not a cure for underlying trauma or mental health issues. Only 6% of respondents felt they had received adequate counselling before medical intervention.
The government must put child protection and safeguarding at the centre of any policy that will apply to children and young people and make every effort to fully understand how proposed policy may put young people at risk.
In 2019, with no public announcement, a small addition was made at point 6 of the MoU v2, which now reads, “Nor is it intended to stop professionals from prescribing hormone treatments and other medications to trans parents and people experiencing gender dysphoria.”
This sentence, in a position statement for therapists seems as if it is intended to normalise the idea that therapists may be prescribing hormone treatments.
Download our report here:
Stonewall has redefined sexual orientation as ‘gender orientation’, for example:
“A person is bi (bisexual) if they are attracted to more than one gender.” (Getting Started, Early Years, 2017, p. 38)
“BI is an umbrella term used to describe a romantic and/or sexual orientation towards more than one gender. Bi people may describe themselves using one or more of a wide variety of terms, including, but not limited to, bisexual, pan, queer, and some other nonmonosexual and non-monoromantic identities.” (An Introduction to Supporting LGBT Young People, 2020, p. 67)
“LESBIAN refers to a woman who has a romantic and/or sexual orientation towards women. Some non-binary people may also identify with this term.” (An Introduction to Supporting LGBT Young People, 2020, p. 67)
Other LGBT+ organisations have also changed the meaning of sexual orientation as defined in the Equality Act 2010, for example:
“Lesbian: someone who identifies as a woman and is usually only attracted to other women.”
“Bisexual: A person who is attracted to people of two or more genders” (PSHE Association fact sheet: Terminology written by Mermaids and GIRES)
Sexual orientation is increasingly referred to as an ‘identity’, for example:
“ORIENTATION is an umbrella term describing a person’s attraction to other people. This attraction may be sexual (sexual orientation) and/or romantic (romantic orientation). These terms refers [sic] to a person’s sense of identity based on their attractions, or lack thereof. Orientations include, but are not limited to, lesbian, gay, bi, ace and straight.” (Stonewall: An Introduction to Supporting LGBT Young People, 2020, p. 68)
“SEXUAL ORIENTATION is a person’s sexual attraction to other people, or lack thereof. Along with romantic orientation, this forms a person’s orientation identity.” (Stonewall: An Introduction to Supporting LGBT Young People, 2020, p. 68)
“If not shared or written down, you must ensure you inform the class of the characteristics, including: Sexual Identity, Gender Identity, Race, Religion or Belief, Disability, Sex & Age.” (Barnados)
The spectrum of ‘gender identities’:
“There is a spectrum of gender identities. Those identifying as neither man nor woman, but in between the two, may describe themselves as non-binary, gender queer or gender neutral and use terms such as pan-gender, polygender, bi-gender, third gender, neutrois, or gender fluid (fluctuating). Some reject the gender concept altogether and regard themselves as non-gender.” (PSHE Association factsheet: Terminology)
“Neutrois: Someone who feels they are exactly in between man and woman, and that their ‘man-ness’ is equal to their ‘woman-ness’. In other words, they are neutral in terms of the gender spectrum. This is sometimes called gender neutral.”
“Pangender: ‘Pan’ means ‘all’ and describes people who are all genders at the same time.”
“Polygender: ‘Poly’ means ‘more than one’ and describes people who have multiple genders at the same time.”
In the same way we are seeing an increase in the number of sexual orientation ‘identities’ on a spectrum, for example: Asexual (ACE), grey-sexual, demi-sexual, queer and pan-sexual:
“PAN is a word which refers to a person whose romantic and/or sexual attraction towards others is not limited by sex or gender.”
The meaning of the word ‘queer’ takes us into sexualities considered to be ‘outside the norm’:
“‘Queer’ is a broad word which describes any sexuality that is not straight, or anything which many people might think to be outside the norm.”
“Queer: A term used by those wanting to reject specific labels of romantic orientation, sexual orientation and/or gender identity. It can also be a way of rejecting the perceived norms of the LGBT community (racism, sizeism, ableism etc).
“LGBT+ The acronym for lesbian, gay, bisexual and/or trans. + is used as a way of including all other sexual, gender and romantic diversities who may or may not identify as lesbian, gay, bisexual &/or trans.” (PSHE Association factsheet: Terminology)
In schools, sex education resources promote the idea that there is no ‘normal’ and no sexual practice should be judged. LGBT+ charity the Proud Trust suggests this activity:
“Activity: What is my normal?
Is everybody’s normal the same?
If not, how do we decide who is more normal?
Do we judge people in this way?
How would it make a person feel if something they enjoyed doing was described as ‘not normal’ by others? Can we really say that anything is normal or not normal?
Are there more positive words that could be used instead of normal and not normal when considering our own and other people’s likes, thoughts and behaviours?
Suggestions could include ‘common’ and ‘uncommon’ ‘usual’ and ‘unusual’”.
“It is important to remember that some people find ‘risky sex’ pleasurable and the idea of reducing all risks is unrealistic.”
This is followed by the normalisation of unsafe sexual practices (warning: graphic descriptions):
“There is no such thing as ‘gay sex’! Is this a sexual activity which is engaged in by all and only gay men? A recent national survey in Britain revealed that almost one in five 16 – 24 year-olds reported having had anal intercourse in the previous year.”
“Sex with penises and vaginas is not the only sex practised. Also, anal sex is not exclusively practised by men who have sex with men, many heterosexual couples enjoy anal sex”. (PSHE Association fact sheet Sex Education)
“It is important to uncouple sexual practice from sexual orientation (e.g. the association of vibrators with lesbians or anal sex with gay men), as such assumptions are ignorant and may encourage stereotyping and prejudice.”
“Anus/penis: Sometimes called ‘anal sex’ this can be a pleasurable experience for the person inserting their penis and the person ‘receiving’ the penis in their anus. The internal clitoris and/or prostate gland can be stimulated through this kind of sex.”
“Anus/object: the anus can be pleasured by placing objects next to the anus or inside it. The anus responds to temperature, size and movement changes. It is important that objects used in sex are clean. Objects must be smooth, or have ridges, but must be retrievable!”
“Anus/mouth: sometimes called ‘oral sex’ or ‘rimming’. It can be pleasurable for some people to experience giving and receiving oral sex to the anus. You can explore the anus with the tongue and lips by kissing, sucking and licking the area.”
“Anus/hands and fingers: you can touch, stroke or insert finger(s) into the anus – this is called ‘masturbation’ or ‘fingering.’” “Anus/vulva: some people enjoy pushing or rubbing their anus and vulva together as the warmth, pressure and moisture can be pleasurable.” 
(All examples taken from our guide Inclusive Relationships and Sex Education in Schools (RSE). Download here.)
In the adult literature it is clear that the ‘Q+’ part of the LGBTQ+ acronym refers to fetish, kink and BDSM.
LGBTQ+ organisation Pink Therapy offers a course on Kink and BDSM and refers to this as a ‘sexual identity’:
“BDSM (bondage and discipline, domination and submission and sadomasochism) remains a demonised, misunderstood area of sexuality that can challenge Counsellors, Therapists or Mental Health Professionals who lack the training and knowledge to support their clients. If you’d like to develop your understanding of this specialist area of practice so that you can avoid the risk of pathologising BDSM/Kink clients, Pink Therapy’s BDSM and Kink online-learning CPD module is for you.
“You’ll be encouraged to examine your own assumptions and form a realistic understanding of BDSM and Kink so that you can be comfortable in offering truly inclusive therapy that promotes safe, sane and consensual principles without perpetuating shame or asking clients to make changes that feel incongruent with their sexual identity or values.“ 
In 2012 The British Psychological Society (BPS) published guidelines for psychologists working therapeutically with “sexual and gender minority” clients including “sexual and gender minority children.”
Sexual identities and activities include, as well as same-sex attraction, “asexuality, celibacy, and BDSM”.
The guidelines end with the call for psychologists to avoid attempting to change a client’s gender or sexual identity, saying it contravenes international professional guidelines and is unsupported by any professional opinion in the field.
 Gender affirming hormone in children and adolescents, Heneghan, C., BMJ (2019) https://blogs.bmj.com/bmjebmspotlight/2019/02/25/gender-affirming-hormone-in-children-and-adolescents-evidence-review/
 Female detransition and reidentification survey (2016) https://guideonragingstars.tumblr.com/post/149877706175/female-detransition-and-reidentification-survey