RSE Government Consultation

The RSE (Relationships and Sex Education) Government consultation gives everyone the chance to air their views on what is taught to primary and secondary age children on the subject of sex and relationships. The consultation is open until November 7th and we urge everyone to respond and to share this with friends, family and especially parents who may not have heard about it. The consultation (together with the draft regulations and draft guidance) can be viewed online here.

You do not have to answer all the questions. The first 9 questions relate to your personal details, although you do not have to fill all of them in and you may remain anonymous. The key questions are 10 – 15 which ask your view about whether the draft guidance is appropriate and adequate for primary and secondary children. We have read through the draft guidance and although we are pleased to see that the teaching of ‘gender identity’ is not included, we believe it to be wholly inadequate on the teaching of sex. It does not equip children with basic knowledge of their own bodies, nor help them navigate the highly sexualised culture they are growing up in and it does not address the issue of sexual harassment of girls in schools. Accurate knowledge about biological sex is even more crucial for children of this generation growing up in a culture which denies its existence, particularly for girls whose rights as the female sex are being eroded by gender identity ideology. You can read the draft guidance here.

Question 16 refers to the right of parents to withdraw their child from sex education. We believe that every child has a right to basic sex education but that parents must be able to retain the right to withdraw their child if material such as pornography is shown as part of a lesson, or if ‘gender identity’ is taught as fact.

Question 21 is important as it potentially gives individual schools the responsibility to choose teaching materials. We feel there needs to be statutory guidance in this area to prevent harmful and confusing sex education resources being used in any school.

Question 24 is for your general views on the draft guidance and can be used to make general points about the right of children to learn facts about sex and human sexual dimorphism and not pseudoscience such as innate gender theories. If you do not have much time, this is the important point to make so that the government is made aware of parents’ opposition to this teaching.

Below is our full submitted response to the consultation. Please take the points you agree with and use this as a guide in submitting your own response. Every voice counts! The deadline is November 7th.

Submit your response here

Do you agree that the content of Relationships Education in paragraphs 50-57 of the guidance is age-appropriate for primary school pupils?

Agree

This content is more than suitable for the primary school age-group as it stands but it needs to go further.

Do you agree that the content of Relationships Education as set out in paragraphs 50-57 of the guidance will provide primary school pupils with sufficient knowledge to help them have positive relationships?

Strongly disagree

We believe that this guidance is inadequate, too abstract and uncontextualised. Safeguarding of children of this age depends on children knowing and understanding the basics of biological sex and human reproduction, including the accurate naming of body parts including genitalia. Otherwise they do not have “the vocabulary and confidence to report concerns or abuse”. Accurate knowledge and language is critical for safeguarding.

Avoiding all mention of sex in early years education does not equip children to understand  inappropriate sexual touching, harassment and exploitation. Although we welcome the section on boundaries and privacy, there is nothing to suggest here that violation of sexual boundaries is more serious than simply not respecting others’ space.  Bodily integrity, the right to privacy from the opposite sex, the need to respect, and the confidence to assert, sexual boundaries cannot be taught if children are denied basic knowledge of male and female biology.

The guidance needs to be more explicit about what constitutes an ‘abusive’ or ‘unhealthy’ relationship, including common techniques of emotional manipulation and coercive control, otherwise children are not equipped to recognise abuse. In particular, various forms of abuse of women and girls should be named:  FGM, sexual harassment and violence, forced marriage and pornography are all issues which children need to be taught in an age-appropriate way in the primary years, it is too late to introduce these subjects at secondary level. (Children however should never be shown pornography or films depicting CSE in the classroom as has already happened or we have seen suggested).

Given the high rate of sexual harassment in schools now, together with the easy access to online pornography,  it is crucial that both boys and girls are equipped to recognise specifically sexual coercion and abuse; this is especially important for the safeguarding of girls. Sexual consent needs to be specified and explained.

Children should be taught the difference between ‘sex’ (a biological fact) and ‘gender’ (a social idea linked to stereotypes) and how gender and sex-role stereotypes are harmful to both boys and girls, but in particular place girls as the inferior sex. This content should be delivered within an equalities framework and linked to the global inequality of women and girls. Safeguarding must be the guiding principle behind the teaching of sex in the primary years, but children also need to be equipped to understand power structures and know right from wrong in a wider context.

Do you agree that paragraphs 61-64 clearly set out the requirements on primary schools who choose to teach sex education?

Strongly disagree

We are disappointed that sex education is optional in primary schools as we believe all children need an understanding of human biological sex before secondary level. Children of primary age are beginning puberty; both boys and girls need to understand the changes in their bodies and hormones, menstruation and sexual development. It is especially important that children are equipped with facts about biology and not ideology-based teaching about ‘gender identity’ which takes away the right to sexual boundaries and consent along with all sex-based protections, privacy and safeguarding of girls.

Do you agree that the content of RSE in paragraphs 65-77 of the guidance is age-appropriate for secondary school pupils?

Agree

The guidance is more than age-appropriate for secondary age pupils but some of these topics need to be introduced earlier and we are concerned about what is lacking in this guidance.

Do you agree that the content of RSE as set out in paragraphs 65-77 of the guidance will provide secondary school pupils with sufficient knowledge to help them have positive relationships?

Strongly disagree

The way that this guidance is framed is worrying. It places too much emphasis on ‘choice’ and resistance to peer pressure, as if children are fully autonomous agents fully able to make healthy choices. This veers too close to victim blaming and places the responsibility too much on the child, which may lead to self-blaming and make it more difficult to report abuse. It is not realistic to expect teenagers to resist peer pressure at a developmental stage when acceptance from the peer group is the most important factor in life. Teenagers’ ‘choices’ are largely unconscious and they would be more equipped to make conscious decisions if teaching included information about the changes in the adolescent brain.

It is also unfair to focus on peer pressure when peers are only influenced by the messages they imbibe from the wider culture. Teenagers should be taught to be critical media consumers, to recognise propaganda, stereotyping, objectification and dehumanisation (especially sexual objectification of women and girls). They should be encouraged to think critically about cultural ‘norms’ which denigrate women and girls and are conducive to violence against them. For example: ‘What does it tell us about women when there’s a lap dancing club on the High St?’ ‘What does it tell us when there are sex ads advertising women’s sexual services on the back page of the free newspaper?’ If sexual abuse and violence towards women and girls is to be tackled both in schools and in wider society, young people need to learn critical thinking and to become critical consumers. The influence of pornography on boys and the coercion of girls to perform sexual acts which are degrading, humiliating, or cause them pain and injury needs to be urgently addressed.

There should be critical examination of queer and gender theories which are linked to BDSM, kink and what is now euphemistically known as ‘sex work’. Queer theory is the latest manifestation of the pressure on girls to accept anything and give up all boundaries, or be seen as a ‘prude’.  Gender identity ideology should be critiqued in the same way as any other belief and the forms of self-harm it encourages, especially amongst girls (such as breast binding and use of off-label hormones) needs to be examined and challenged. Schools need to recognise the harm being done to young people through the cultural influence of these theories of gender which encourage body-rejection and disassociation, in particular amongst vulnerable groups such as ASD children. As with primary education, this needs to be taught within an equalities framework and linked to the school’s safeguarding policies.

Do you agree that paragraphs 36-46 on the right to withdraw provide sufficient clarity and advice to schools in order for them to meet the legal requirements?

Disagree

While it is important to proactively engage parents, it is a concern that the most vulnerable children, especially girls, may miss out on education which will help to protect them. Parents need to trust the school and this is more likely if parents can see that the school delivers factual, non ideology-based information which neither encourages young people towards sexual experimentation on the one hand, nor shame about sex on the other. Overall we feel that a good sex education is important for all children but parents should retain the right to withdraw their child if the school replaces ‘sex’ with ‘gender’ and teaches non-scientific theory as fact.

Do you agree that the content of physical health and wellbeing education in paragraphs 86-92 of the guidance is age-appropriate for primary school pupils?

Disagree

Although there is good content here and we agree that mental health is a very important area to cover, the section on the changing adolescent body is totally inadequate. Children need much more information in this area and leaving out so much looks like squeamishness. Children need the opportunity to talk and ask questions about fertility, menstruation and human reproduction before they go through these changes in their bodies. This is exactly the age to give clear, matter-of-fact information before children enter the teenage years and become too embarrassed to ask. Girls at this age may already be suffering painful periods, or needing to go to the toilet more often and they may feel ashamed to say why. Demystifying the sexual development of boys’ and girls’ bodies would be a step towards understanding and respect between the sexes, rather than the sense of secrecy and shame engendered by avoidance of the subject.

Do you agree that the content of physical health and wellbeing education as set out in paragraphs 86-92 of the guidance will provide primary school pupils with sufficient knowledge to help them lead a healthy lifestyle?

Strongly disagree

As above, physical health and well-being is connected to the approach and start of puberty for primary age children and this part of the guidance leaves out essential information which should be taught in an age-appropriate way as part of schools’ safeguarding policies and to support the health and welfare of all children.

Do you agree that the content of physical health and wellbeing education in paragraphs 93-99 of the guidance is age-appropriate for secondary school pupils?

Strongly disagree

It is too late to begin talking about menstruation at secondary school. Sex is completely missed out in the section about areas where teenage risk-taking behaviours are commonly seen (drugs, alcohol and tobacco) and the omission leaves teenagers open to picking up misleading information online or from peers and at risk of making poor decisions based on lack of understanding or knowledge of what is sexually healthy behaviour and what is not. Pornography should be viewed as a serious public health risk and a lesson, for example, on the effects of regular porn consumption on the developing adolescent brain would give teenage boys critical information to inform their decisions in this area.

Do you agree that the content of physical health and wellbeing education as set out in paragraphs 93-99 of the guidance will provide secondary school pupils with sufficient knowledge to help them lead a healthy lifestyle?

Strongly disagree

As above, this guidance fails to address critical issues of sexual health as well as sexual orientation and sexual boundaries. The rising number of young lesbians who are seeking medical transition indicates that this group is especially vulnerable and in need of support and information as well as access to positive role models.

Do you agree with the approach outlined in paragraphs 36-46 on how schools should engage with parents on the subjects?

Disagree

It is important to discuss with parents the content of the school’s sex education programme. Parents’ concerns are generally around their children’s right to be children, not learning too much too soon and not being introduced to distressing topics, as well as not being encouraged to experiment sexually.  Parents therefore need to be reassured that topics are introduced in an age-appropriate way and that the content is factual, sensitive and designed to support the school’s safeguarding protocols. All children should have the right to such an education, a child should not be penalised because of the parents’ religious beliefs. Schools need to be aware that withdrawal from sex education may be an indicator of risk.

Paragraphs 108-109 in the guidance describe the flexibility that schools would have to determine how they teach the content of their Relationships Education/RSE/Health Education. Do you agree with the outlined approach?

Strongly disagree

There needs to be a core area of learning which is compulsory, on the National Curriculum and which every child has the right to receive. Such an important area should not be delegated to schools or individual teachers within schools.

Do you agree that paragraph 44 of the guidance provides clear advice on how headteachers in the exceptional circumstances will want to take the child’s SEND into account when making this decision?

Strongly disagree

Pupils with learning difficulties or physical disabilities are particularly vulnerable to sexual abuse and exploitation and should not be denied this core area of knowledge.

Do you agree that paragraphs 30-32 of the guidance provide sufficient detail about how schools can adapt the teaching and design of the subjects to make them accessible for those with SEND?

Agree

Do you have any further views on the draft statutory guidance that you would like to share with the department? Do you think that the expectations of schools are clear?

This guidance does not fulfil the promise made in legislation last year. The call for better compulsory sex education which is relevant to children’s lives now was based on the need to equip children of this generation with guidance on such issues such as sexual harassment of girls in schools, online porn and sexting and abusive relationships. This is the context within which our children live and this draft guidance does nothing to help children navigate this culture.

Girls in particular are totally let down by guidance which seems afraid to even mention the word ‘sex’, as girls are particularly at risk of sexual harassment, coercion and violence. The government has a duty to protect the safety of girls and to implement preventive measures to tackle violence against women and girls. This guidance as it stands is a huge opportunity lost. The advice is wholly inadequate as well as being unclear on schools’ equality duties in implementing it.

Do you agree that more is required on financial education for post-16 pupils?

Agree

The department believes that primary schools should be able to access appropriate resources and training in order to teach effectively. Do you agree that the resources and support currently available to primary schools will be sufficient to enable them to teach the new subjects?

Strongly disagree

There needs to be statutory Guidance as there is in other key areas such as Safeguarding. It is unclear how schools can assess materials from outside agencies and how resources can be quality assured if there is no guidance to follow.

The department believes that secondary schools should be able to access appropriate resources and training in order to teach effectively. Do you agree that the resources and support currently available to secondary schools will be sufficient to enable them to teach the new subjects?

Strongly disagree

As above. There is some appalling ‘sexual health’ guidance available and teachers must be able to refer to statutory guidance before employing any outside agency to deliver training.

Do you agree that the draft regulations clearly set out the requirements on schools to teach the new subjects of Relationships Education, RSE and Health Education?

Strongly disagree

Marriage and Faith are set out as priorities in the draft regulations as well as in the draft guidance but other equality characteristics are not. Girls cannot be adequately protected as a sex when sex is barely mentioned. It is girls who disproportionately suffer harm when young people are not given proper guidance on sex and relationships, and it is girls’ safety which must be prioritised in the regulations and the guidance.

We are required to set out in the regulations the circumstances in which a pupil (or a pupil below a specified age) is to be excused from receiving RSE or specified elements of it. The draft regulations provide that parents have a right to request that their child be withdrawn from sex education in RSE and that this request should be granted unless, or to the extent that the headteacher considers that it should not be. Taking into account the advice to schools on how headteachers should take this decision, in paragraphs 41-46 of the guidance, do you agree that this is an appropriate and workable option?

Disagree

Every child has the right to factual knowledge about sex and relationships. Parents however must retain the right to withdraw a child from any PSHE lessons which cause harm or confusion, for example explicit pornography or CSE content,  or gender identity ideology and Queer theory presented under the guise of factual reality.

Do you have any other views on the draft regulations that you would like to share with the department?

The draft regulations seem to be written from a faith perspective rather than within an equalities and safeguarding framework. This only serves to hide the important issues and deny children the right to proper knowledge about their own bodies, sexual development and sex and relationships generally.  There should be no faith, belief or ideology underpinning and shaping sex and relationships education to the point where it overrides safeguarding and the teaching of facts.

Tables (6-8) in section F of the draft assessment set out the assumptions we have made in estimating the cost burden for schools to implement the new requirements. Do you agree with our assumptions and the estimated additional costs to schools?

Neither agree nor disagree

We are not qualified to judge. However, this area needs to be properly resourced and funded to ensure good quality teacher training and teaching resources.

Are there any other cost burdens on schools, which you believe should be included in the regulatory impact assessment?

Yes

Good quality training needs to be delivered to all trainee and NQT teachers and schools need to consult with local organisations with expertise in gender-based violence, inequalities and specific vulnerabilities of children and young people if meaningful and effective teaching is to be delivered in this area.

Please submit your response to the consultation here.

Thank you!

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