Blog

We have been raising concerns about inappropriate RSHE teaching resources in schools from external providers since 2019 (see our guide here). Over the years we have received countless emails from parents telling us of disturbing sexual material being taught in their child’s school. The organisation Safe Schools Alliance has also documented gender identity teaching and inappropriate sexually graphic resources in schools.

Last year the then Prime Minister Rishi Sunak brought forward a review of the RSHE curriculum guidance after Conservative MP Miriam Cates compiled a dossier of evidence of inappropriate content from external providers. The Children’s Commissioner, Rachel deSouza, expressed ‘shock’ on learning about ‘horrendous’ extreme and graphic materials being used in schools. However, despite a wealth of evidence, there was worrying push-back and denial from some head teachers and teaching unions that any problem existed.

After completion of the review of RSHE statutory guidance for schools, the previous government opened a public consultation on the new draft guidance, which closed on July 11th.

Given the seriousness of what we consider to be extremely harmful resources going into schools the draft guidance is sensible and could even be considered mild. Changes have been made to protect children from material they are not developmentally equipped to understand and may cause distress as well as putting children at risk. The guidance introduces sensible age limits and adds extra topics in line with ever-changing technology, such as deepfake and AI.

Although there was widespread denial of any problem when the review was announced, it still came as a surprise to see that a coalition calling itself the PSHE Strategic Partners Group has called for the new government to scrap the draft guidance altogether and start again. The coalition comprises Anna Freud, Association for Young People’s Health, ASCL, Barnardo’s, Brook, Centre of expertise on child sexual abuse, End Violence Against Women Coalition, NAHT, NSPCC, PSHE Association and the Sex Education Forum.

This coalition does not have a website but simply set up a landing page to publish their statement online. This statement has been signed by 100 organisations, including some of the sex education providers flagged up in reports of ideological and inappropriate resources: Brook, Barnados, SexpressionUK, Split Banana, School of Sexuality Education, Period Positive and Fumble. Signatories also include trans activist organisations Stonewall and TransActual, teaching unions, women’s organisations, Amnesty and Girlguiding.

Many of the organisations on this list we are familiar with; all of them ideologically captured. It is not an accident that extreme adult sexual practices came into RSHE lessons at the same time as ‘LGBT inclusion.’ The T part of the acronym introduced gender ideology, and the extension to ‘Q+’ added Queer Theory and adult sexualities, with no definition or ceiling on what this included.

This coalition objects to the age restrictions and topic bans introduced in the draft guidance to safeguard children. They are concerned about creating ‘harmful stigma’ around sex and sexuality, bemoan the lack of teaching about sexual pleasure, and say ‘LGBT+ people’ must see themselves represented in sex education (Brook compares this to Section 28, as if the government has banned teaching about gay people). These are familiar arguments among activists.

We hope the new government recognises that the real cause for concern here is the overreaction of so many organisations to what are measured and reasonable amendments in the draft guidance for the purpose of safeguarding children from adult content. That so many organisations, including children’s charities and child protection agencies, do not understand basic safeguarding is a matter for urgent investigation.

Following is Transgender Trend’s submission to the government draft RSHE statutory schools guidance. We have answered the questions that are the most relevant to us.

Review Timetable
11 Do you agree that we move away from a rigid commitment to review the guidance every three years?

No

Structure of the guidance
12 Do you agree that the changes to length and style of the guide make the guidance easier to understand and follow?

Yes

Schools’ relationships and sex education policies
13 Do you agree that these changes will do enough to ensure that schools are transparent with parents and that parents have sufficient control regarding what their child is learning?

Yes

Openness with parents
15 Do you agree with our proposed approach to increased transparency on RSHE material?

Yes

16 If you would like to offer any comments to explain your answer, please do so here.

Yes with some caveats. The guidance should not give schools leeway to share only a ‘representative sample’ with parents. Schools should not be able to cherry pick material to show to parents and hide more contentious parts of the resources they are teaching their children. Although it is reasonable for schools to ensure that parents cannot use the materials for commercial gain or sharing outside copyright restrictions, the changes also prevent parents from copying materials for the purposes of making a formal complaint, for seeking legal/professional advice or to expose ideological/political content in the RSHE curriculum.

Age limits on teaching certain subjects
Flexibility for age limits
17 Do you think this flexibility is sufficient to ensure that pupils are adequately safeguarded?

Yes

18 Do you think this flexibility is warranted?

Yes

Sexual orientation
20 Do you agree with changes to the lesbian, gay and bisexual content in the LGBT section (note that the next section provides an opportunity to comment on text about gender identity and gender reassignment)?

Yes

21 If you have any comments to explain your answer, please do so here.

This is a positive change from the previous guidance. ‘LGBT’ should not be used in government guidance as this conflates two very different things with no relation to each other. Point 40 should include Sex as one of the protected characteristics taught alongside sexual orientation and gender reassignment, as it is related to both in terms of legal protections. Primary schools should teach homosexuality only in relation to adults, not children, ie in the same way as ‘heterosexuality’ is taught, in an age-appropriate, non-sexualised way. For example, little children are told mummies and daddies love each other, they are not taught that little boys love little girls in the same way. Adult concepts of ‘gender identity’ similarly should not be applied to children, and the protected characteristics of both sexual orientation and gender reassignment should be taught with reference to adults, not children.

Gender reassignment
22 Do you agree with the proposed changes related to gender identity and gender reassignment in the guidance?

Yes

23 If you have any comments to explain your answer, please do so here:

As a definition of ‘gender identity’ this quote is pure ideology and a circular definition:
“It is a sense a person may have of their own gender, whether male, female or a number of other categories. This may or may not be the same as their biological sex.”

‘Male’ and ‘female’ are sexes (not ‘genders’). It would be better to say ‘Gender identity is a belief held by some people that human beings have an internal sense of being a man or a woman and that this inner sense overrides biology.

There should be clear guidance that schools should not use external providers that teach ‘gender identity’ as fact, other than as an example of one side of a political debate balanced with material from a sex realist group, to facilitate discussion amongst older pupils. It should also be made clear that teaching ‘gender reassignment’ does not mean teaching the concept of ‘gender identity’ which is a belief unrelated to the protected characteristic.

Primary aged children must not be taught the concept of ‘gender identity’ as this is developmentally inappropriate. In assuming adult levels of comprehension of an abstract concept it is likely to disrupt normal developmental stages of understanding of reality and sex constancy.

Pupils must be taught the legal protections that exist for girls as the female sex within the Equality Act and why these are necessary. Language must be based on reality for clear safeguarding reasons and the language of ideology should not be used in schools.

Addressing prejudice, harassment and sexual violence
24 Do you agree that the revised content on addressing prejudice, harassment and sexual violence is a helpful response to evidence of the prevalence of sexual abuse in schools?

Yes

Primary sex education
26 Do you agree with the restriction on teaching sex education only in years 5 or 6?

Yes

27 If you would like to make any comments to explain your answer, please do so here. It would be helpful if you could share your own views on appropriate age limits for this topic, for example if you think they are too low or too high.

Adult sexualities should not be taught to primary age children, nor celebrated in events such as Pride. Nor should adult entertainers such as drag queens be used in schools. This blurs the boundary between childhood and adulthood, which is a clear safeguarding risk. Teaching children about boundaries, privacy and consent within a non-sexualised context equips children to understand when their privacy/boundaries have been violated sexually. Adults should not be talking to children about sexual practices; this blurs the boundary between adult and child and normalises the grooming techniques of predators.

Secondary topics: Online and Media, Respectful Relationships, including friendships, and Being Safe
28 What constitutes harmful sexual behaviour and why, and that such behaviour is unacceptable, emphasising that it is never the fault of the person experiencing it. This should not be taught before year 7. Do you agree with this age limit?

Yes

29 We have placed an age limit on the following content in the secondary Respectful Relationships, including Friendships topic: That some types of behaviour, including within relationships, are criminal, including violent behaviour and emotional abuse, such as controlling or coercive behaviour. Schools should not, however, teach about the details of violent abuse before year 9 as it is important that pupils are not introduced to distressing concepts when they are too young to understand them. Do you agree with this age limit?

Yes

30 We have placed an age limit on the following content in the secondary Online and Media topic: About circulating images and information and how to safely report to trusted adults the non-consensual creation or distribution of an intimate image. Pupils should understand that
making, keeping or sending naked or sexual images of someone under 18 is a crime, even if the photo is of themselves or of someone who has consented, and even if the image was created by the child and/or using AI generated imagery. Pupils should understand the potentially serious consequences of asking for naked, semi-naked or sexual images, including the potential for criminal charges and severe penalties including imprisonment. This topic should not be taught before year 7. Do you agree with this age limit?

Yes

31 We have placed an age limit on the following content in the secondary Online and Media topic: The impact of viewing harmful content, including pornography, that presents a distorted picture of sexual behaviours, can damage the way people see themselves in relation to others, and can negatively affect how they behave towards sexual partners. This can affect pupils who see pornographic content accidentally as well as those who see it deliberately. The risks of inappropriate online content can be discussed in an age-appropriate way from year 7, however, the details of the sexual acts in question should not be discussed before year 9. Do you agree with this age limit?

Yes

32 We have placed an age limit on the following content in the secondary Being Safe topic: The concepts and laws relating to harmful sexual behaviour, including sexual harassment, revenge porn, upskirting and taking/sharing intimate sexual photographs without consent, public sexual harassment, and unsolicited sexual language / attention / touching. This should not be taught before year 7. Do you agree with this age limit?

Yes

33 We have placed an age limit on the following content in the secondary Being Safe topic: The concepts and laws relating to sexual exploitation, grooming, stalking, and forced marriage. This should not be taught before year 7. Do you agree with this age limit?

Yes

34 We have placed an age limit on the following content in the secondary Being Safe topic: The concept and laws relating to sexual violence, including rape and sexual assault. Whilst it’s important for pupils to understand the key principles around sexual offences and violence, for example the importance of understanding what consent means, schools should not teach about this in any sexually explicit way before year 9. Do you agree with this age limit?

Yes

35 We have placed an age limit on the following content in the secondary Being Safe topic: The physical and emotional damage which can be caused by female genital mutilation (FGM), virginity testing and hymenoplasty, where to find support, and the law around these areas. This should include that it is a criminal offence to perform or assist in the performance of FGM, virginity testing or hymenoplasty, or fail to protect a person under 16 for whom someone is responsible from FGM, or to take girls who are UK nationals abroad for FGM, regardless of whether it is lawful in that country. This should not be taught before year 9, except for where schools have identified a greater risk of FGM at an earlier age or have pupils who have been affected by FGM and need support. Do you agree with this age limit?

Yes

36 We have placed an age limit on the following content in the secondary Being Safe topic: The concepts and laws relating to domestic abuse including controlling or coercive behaviour, emotional, sexual, economic or physical abuse, and violent or threatening behaviour. Schools should not teach about the details of violent abuse before year 9 as it is important that pupils are not introduced to distressing concepts when they are too young to understand them. Do you agree with this age limit?

Yes

37 If you would like to offer any comments about the age restrictions in the secondary Online and Media, Respectful Relationships, including Friendships, and Being Safe topics please do so here. It would be helpful if you could share your own views on appropriate age limits for these topics, for example if you think they are too low or too high.

These age limits are appropriate with the caveat that they may be discussed earlier if a school has identified a particular problem. While teachers should give information about sex acts that are normalised in pornography – for example acts such as anal sex and the harms it can cause to female bodies such as fecal incontinence, or choking which is a serious risk for girls, independent of ‘consent’ – it is not the teacher’s business to talk to children about how pleasurable sex is (so-called ‘sex positive’ teaching).

This normalises talking about sex between adult and child and blurs boundaries. It confuses a child’s intuitive sense of when an adult is talking to them in inappropriate ways, and compromises a child’s ability to recognise grooming. Children should feel embarrassed/uncomfortable when an adult talks to them about enjoying sex, it is an important warning sign that something is wrong. A crucial part of sex education for adolescents, particularly girls, is the importance of trusting your own instincts and judgment. Adolescents should be given the confidence to act on these instincts, despite pressure to do otherwise, whether that is fear of being seen as a prude, or disappointing a teacher.

Teachers should be role models in maintaining boundaries with children. Talking about the pleasures of sex does not maintain a teacher’s professional boundary and could put children at greater risk of sexual exploitation by other adults. Teaching a range of sex acts deemed ‘pleasurable’ by the teacher just puts further pressure on girls to consent to acts they find distressing or uncomfortable. Girls need to know that their ‘consent’ can be forced or coerced by external pressures, not just from boys but from a culture that promotes sexual experimentation and pornography as the norm.

Secondary topic: Intimate and sexual relationships, including sexual health
38 Do you agree with the age restriction on the secondary intimate and sexual relationships, including sexual health topic?

Yes

Health and wellbeing

40 Why social media, some apps, computer games and online gaming, including gambling sites, are age restricted. This should not be taught before year 3. Do you agree with this age limit?

Yes

41 We have placed an age limit on the following content in the primary Online Safety and Harms topic within health education: The risks relating to online gaming, video game monetisation, scams, fraud and other financial harms, and that gaming can become addictive. This should not be taught before year 3. Do you agree with this age limit?

Yes

42 We have placed an age restriction on the whole of the primary Developing Bodies topic within health education. This should not be taught before year 4. This covers; growth, change and the changing adolescent body, this topic should include the human lifecycle. Puberty should be mentioned as a stage in this process; the key facts about the menstrual cycle, including physical and emotional changes. Do you agree with this age limit?

Yes

43 The secondary Health and Wellbeing topic is now clear that, given the sensitivity and complexity of content on suicide prevention, direct references to suicide should not be made before year 8. (Note that there is more detail on suicide prevention content in the curriculum provided in the ‘Suicide Prevention’ section shortly). Do you agree with this age limit?

Yes

44 If you would like to offer any comments about these age restrictions, please do so here. It would be helpful if you could share your own views on appropriate age limits for these topics, for example if you think they are too low or too high.

Schools should take extra care with subjects known to be associated with social contagion, for example suicide, anorexia and eating disorders, and gender dysphoria. Harm can be inadvertently caused by well-meaning but unqualified teachers, particularly in an area as serious as suicide. Teachers should not be introducing children to specific or serious mental health problems and are not qualified to intervene in pupils’ mental health issues.

Lessons on health must be focused on how to be well, how to manage problems/facilitate mental wellbeing, the association between physical and mental health, and how to think critically about information seen online. Teachers should not be facilitating mindfulness/meditation sessions, diaries of feelings, or any other experiment on children’s mental health.

Health and wellbeing
45 Do you agree with changes to the Health and Wellbeing section of the guidance?

Yes

46 If you would like to offer any comments to explain your answer, please do so here.

We agree broadly but we are concerned about the proposed teaching of suicide and think this must only be done by professionals. In the area of mental health, teachers are not professionals and could cause more harm than good. It is not fair to expect teachers to talk to children about mental health issues, and schools need guidance about professional resources they can trust. There is a risk of children self-diagnosing after learning about a mental health issue so schools need to be extra careful and sensitive in this area.

Suicide prevention
47 Do you agree with the proposals on suicide prevention as set out above?

No

48 If you would like to offer any comments to explain your answer, please do so here

We think this is a risky subject to include in the curriculum given the social contagion aspect of suicidality, especially in the hands of inexperienced teachers.

Additional topics
49 Do you agree with this additional content?

Yes

General comments
51 Is there anything else in the draft statutory guidance that you would like to comment on?

We would like the guidance to make clearer that ideology, and ideological concepts such as ‘gender identity’ should not be embedded in the RSHE curriculum under the guise of being ‘inclusive.’ RSHE should be entirely consistent with the biology curriculum. As Relationships education is compulsory in primary schools, the concept of ‘gender identity’ should not be introduced through this route by, for example, teaching children to use a person’s ‘preferred pronouns.’

‘Gender identity’ must not be taught to children in schools for primarily safeguarding reasons – including facilitating social contagion, blurring the boundaries between male/female and adult/child, creating a culture of secrecy and deception, confusing children about sex, disrupting reality, damaging children’s confidence in using correct language to report abuse and training children to ignore their instincts. Schools seem to have forgotten safeguarding in this area, and it is a rights-based or ‘diversity and inclusion’ approach that has led to this failure of safeguarding. This must be corrected.

We would like to see it made explicit in the guidance that schools must take a safeguarding first approach to everything they teach in RSHE, and all external resources must be assessed through this perspective.

Public Sector Equality Duty (PSED)
52 Do you have any comments regarding the potential impact of the guidance on those who share a protected characteristic under the Equality Act 2010, whether negative or positive? How could any adverse impact be reduced and are there any other ways we could advance equality of opportunity or foster good relations between those who share a protected characteristic and those who do not?

Treating all children as children, equally deserving of respect, is enough to foster good relations between those with different protected characteristics.