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Transgender Trend’s response to the government consultation Safeguarding children in schools and colleges. This was a call for evidence from the Dept for Education for the development of Keeping children safe in education 2025. Sex and gender identity was not a subject referenced in the questions, and responses were restricted to 1,000 characters. In our submission we have answered the questions where we feel this subject is relevant and must be considered if children are to be safeguarded.

Safeguarding Children in Schools and Colleges: A Call for Evidence

Communications and dissemination

Webinars Question 17: We intend to run a further round of DfE-run webinars on a variety of topics to support you in your role. Which three topics would you find most useful?

Topic 1

Sex and gender: safeguarding aspects of policy on sex-segregated facilities and accurate language.

Topic 2

The Cass Review in regard to safeguarding children who express a transgender identity.

Topic 3

Unlawful and misleading guidance from transgender and LGBT external providers.

Working with local safeguarding partners

Question 25: Do you feel that your school or college is sufficiently included in your local safeguarding partner arrangements? Yes / No / N/A

Question 26: How does this affect your school or college and its handling of safeguarding cases?

External transgender and LGBT organisations are providing advice that fundamentally undermines safeguarding in schools, regarding confidentiality, mixed-sex facilities, working together with parents and ignoring any safeguarding concerns when a child announces a trans identity.

The problem of bad training extends throughout the range of children’s services, agencies and authorities. A politicised approach towards children with a trans identity is rife everywhere, putting further pressure on schools and individual teachers to keep quiet about concerns. There is an across-the-board belief that ‘trans children’ exist as a category and deserve support through affirmation of their ‘gender identity.’ In this way these children have been placed outside normal safeguarding frameworks. This MUST be addressed by DfE in training webinars.  

Section 3 – How you record, retain, and share child safeguarding information

Question 30: Would you like to see more prescriptive, but not exhaustive examples of the types of information that should be recorded in the child protection file? Yes / No / N/A If yes – please provide examples of the information you feel should be recorded:

Yes

The concerns about the extremely vulnerable population of children expressing a trans identity are well-documented in the Cass Review. This needs to be directly and explicitly highlighted by DfE. These children should not be grouped under the (meaningless) label ‘transgender’ and celebrated for their ‘gender identity.’ Specific vulnerabilities must be addressed within this population. It is critical for safeguarding purposes to record that a child wants to be the opposite sex.

The subject of gender identity is the elephant in the room that nobody is discussing, including in this consultation, yet the subject of sex and gender is a live political and social issue. The Cass Review must be read and understood in terms of safeguarding children from harm and teachers need guidance on this.

Question 34: We know that over time, across multiple phases of education, a fuller understanding of unrelated behavioural concerns can often be helpful in identifying a need for early safeguarding interventions. What type of incidents and level of seriousness do you think should be recorded?

The expressed desire to be the opposite sex or no sex at all (non binary) should not be viewed automatically as an unrelated behaviour, but considered in relation to other factors in the child’s life/environment/relationships and school performance etc. It may be a potential indicator of safeguarding concerns, such as sexual abuse, trauma, peer pressure, family environment, porn consumption or internet grooming. A child may be sharing intimate feelings about their breasts or genitals with unknown people on social media, and be especially vulnerable to exploitation. A young child expressing a sexual identity such as ‘asexual’ should be seen as a safeguarding red flag. Teachers need to be aware of the ever-expanding group of sexual and gender identities promoted to children, all with their own flags. A child who spends a lot of time online may have imbibed ideas and beliefs from the adult world that put them at risk.

Section 4 – Safer recruitment

Question 40: When recruiting staff who have worked in a school or college in England during the three months prior to their appointment, is it your school or college’s normal practice to request an enhanced DBS certificate with barred list information rather than just a standalone barred list check? Yes / No / N/A

Question 41: If yes, we are keen to understand why your school or college does this:

There is a loophole in the law regarding name changes in the case of men who change their name to a female name as part of the process of gender reassignment. Like many people, teachers, including safeguarding leads, are afraid to ask questions or raise concerns about this issue, for fear of being accused of transphobia and having legitimate concerns about losing their jobs. DfE must not collude in the silence. Safeguarding failures occur when one group is exempt from normal levels of scrutiny, whether in terms of social status or political favouritism. Children should never be coerced (by being told it is ‘kind’) into being ‘allies’ of one group without question, especially an ever-expanding group of people professing adult sexualities and identities. The DfE must take the lead in ensuring that there is no subject exempt from debate and no protected group teachers are afraid to question.

Section 5 – Filtering and monitoring systems

Question 48: KCSIE requires all staff to undergo safeguarding and child protection training (including online safety which, amongst other things, includes an understanding of the expectations, applicable roles, and responsibilities in relation to filtering and monitoring at induction). We would like views on whether schools and colleges feel further clarification or advice is needed here? Yes / No / Do not know

Yes

If yes, please explain your answer:

Clear guidance from DfE is needed in regard to online promotion of drugs including puberty blockers and cross-sex hormones, and websites that promote and distribute breast binders for girls. Schools should filter for YouTube influencers who document their ‘transition journeys’ through hormones, binding and surgical breast removal, and transgender and LGBT websites from organisations that promote this form of self-harm.

Schools must do more to examine the social media output of job applicants, including the social media accounts and websites of external providers which may include links to porn content.

Section 6 – Child-on-child sexual violence and sexual harassment

Question 51: Are there any examples of best practice you could share on handling such incidents in this regard?

Question 52: How best could we help schools and colleges to handle such incidents?

Clear guidance is needed on the use of correct sex-based language. The term ‘child-on-child’ itself masks the problem that it is predominantly girls who are the targets of sexual harassment and abuse from boys. The incidence for boys should not be minimised, but accurate statistics are necessary in order to understand where schools need to prioritise. It is critical in this regard that accurate sex-based data is collected and recorded. Gender neutral language and terms, such as ‘all genders’, ‘cisgender’ and ‘non binary’ should never be used as all these terms cover up the reality of sex-based violence and harassment and who it affects. This is for the protection of both sexes.

Section 7 – Protecting children in boarding schools and residential special schools

Question 59: Thinking about KCSIE and the relevant NMS as currently drafted are there any gaps we should be looking to address?

Boarding schools and residential special schools need clear, unequivocal guidance from DfE that mixed-sex accommodation and facilities must never be provided under any circumstances, including as ‘optional’ alternatives. DfE needs to clarify that guidance from groups such as Stonewall is wrong according to the law on this issue and their guidance must not be followed. Safeguarding of girls must be a schools’ priority and this rule must be non-negotiable. Disabled girls are especially at risk of sexual abuse and their protection and safety must never be compromised by ‘gender identity’ policies implemented in place of sex-based protection.

Section 9 – other safeguarding issues on which we welcome your views Bring your own device policies

Question 73: Would further guidance on this be helpful? Yes / No / N/A Please explain your answer:

Smartphones should be banned in schools and DfE needs to take the lead on this issue. A parent may take precautions on behalf of their own child, but it is the child of the most lax parents who will dictate the safety of all children.

DfE needs to be on top of trends in algorithms and AI that lead children to propaganda and give false and misleading information about sex and gender in answer to children’s questions. Information about circular definitions of words would be helpful, eg. a woman is a person who feels like/identifies as a woman; gender is how you feel inside about your gender. Children need clear, accurate definitions of words. The basis of safeguarding girls is being able to make a distinction between the sexes in language and basing safeguarding policies on the reality of sex. For all children it is important that they have confidence in using accurate language in order to report abuse.