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Feminism: Sex and gender discussions

Secondary School complaint about mixed sex changing rooms. Update, school response and request for help writing the escalated complaint to governors

364 replies

TangenitalContrivance · 05/04/2025 16:56

Hello everyone. Some may remember I asked for help with a complaint to my daughter’s secondary school in Brighton which allows Males into female changing spaces. Including swimming, without informing either children or parents.

this is clearly a safeguarding issue, borderline illegal and must not be allowed to stand.

I’m going to have to take the whole thing through a governors complaint and even higher, which I am willing to do.

please, if you can, could you read my complaint and the schools subsequent response and give me pointers for what to say in my follow up.

feel free to use the original complaint at your own school. You will be surprised how many are doing this!

OP posts:
Thread gallery
17
Kucinghitam · 16/04/2025 10:27

TangenitalContrivance · 16/04/2025 10:21

This is a shitty lead sentence even from the guardian!

"Critics of equal rights for transgender women have won their supreme court challenge over the definition of a woman."

They just can’t help themselves!

2fallsfromSSA · 16/04/2025 10:25

TangenitalContrivance · 16/04/2025 10:21

I think I might be referring to the Supreme Court judgement from today, in my follow up complaint letter....

Absolutely, the timing could not have been better. No longer will schools be able to fudge the meaning of women/girls.

TangenitalContrivance · 16/04/2025 10:21

This is a shitty lead sentence even from the guardian!

"Critics of equal rights for transgender women have won their supreme court challenge over the definition of a woman."

OP posts:
TangenitalContrivance · 16/04/2025 10:21

I think I might be referring to the Supreme Court judgement from today, in my follow up complaint letter....

OP posts:
WarriorN · 16/04/2025 07:33

Todays ruling could / should have large implications on your situation op.

WarriorN · 14/04/2025 08:05

Well children at school won’t be able to get a grc so that would solve that.

However it’s still problematic beyond this. I could envisage a trans identified teacher with a grc demanding that they oversee the girls’ changing room for the validation and cos “it’s the rulez.”

grcs simply don’t work.

ThisLoftyBrickOP · 14/04/2025 07:54

Women-only spaces to get protection in equality law overhaul mulled by the Government

This could help you OP. There is a more detailed article in the times but it’s behind a paywall, have tried adding a cleaned up link but it didn’t worked.

Justme56 · 13/04/2025 11:30

https://www.telegraph.co.uk/news/2025/04/13/mum-banned-school-playground-trans-identity-row/

This is in the telegraph today. Different issues but the comments do seem to suggest people are frustrated with it all.

WarriorN · 13/04/2025 10:57

That’s a good point. I’ve not followed releases enough in the past to be aware.

BonfireLady · 13/04/2025 08:55

WarriorN · 10/04/2025 19:24

These are great points, as are so many other posts.

At the same time, they're not you going to take a blind bit of notice of a parent’s letters, even if lawyer sent, as they truly believe the law is as such and they believe that Labour will be reversing what’s currently in kcsie.

the only way to get any of this done, in that school, and to make changes in schools across the country, is to drag them through the courts and a judicial review.

the beliefs and fake laws that have developed and beloved to be true, thanks to the EA+activists, are really very chilling in the context of child safeguarding and must be dealt with asap.

At the same time, they're not you going to take a blind bit of notice of a parent’s letters, even if lawyer sent, as they truly believe the law is as such and they believe that Labour will be reversing what’s currently in kcsie.

Agreed.

Regarding the KCSIE, I assume we'll see an updated version next month ready to go live in September....?

(Does anyone on this thread know if they release the new versions every May?)

TheOtherRaven · 12/04/2025 12:33

Outstanding posts KTS, thank you.

Worth remembering too - all these increased risks and issues for multiple groups of children, the severity of risks, and why was it all changed to this increased risk in the first place?

So that a very small group of children (and the adults behind them) could escape boundaries on their self expression and normalise the removal of privacy, dignity and equality from women and girls.

MrsOvertonsWindow · 12/04/2025 12:23

Keeptoiletssafe · 12/04/2025 11:51

Hello
Apologies for the length. On phone, travelling.

This is the DfE specification for schools.
https://assets.publishing.service.gov.uk/media/65803d561c0c2a000d18cf3c/GDB_GenericDesignBrief-A-C17.pdf
And the annex for toilets.
https://assets.publishing.service.gov.uk/media/6380b52d8fa8f56eaf2f924b/GDB_Annex_2A_Sanitaryware-A-C12.pdf

If you search ‘changing rooms’ it says they have to be safe!

Primary is fine- mentions gaps. Secondary toilets don’t mention safety at all just privacy- a 5mm gap. This is what I have lots of correspondence with the DfE about. You will also note a completely new addition for the 2023 of a private toilet ‘identified as gender neutral’ on each floor. The language ‘identified’ jars with the normal tone and it has been tacked on with no explanation, since the 2020 documents. I am presuming this is to do with Stonewall membership the DfE had?
You can’t have both complete privacy and safety. Safety should be paramount (everywhere else in all DfE documents a ‘safe environment’ is the overriding factor).

What I have learned is:
@AnSolas
These are only guidelines. The DfE says you don’t have to use them. As long as a school says why, for example, they don’t want full height cubicle toilets, in the school specific brief, then you can go with the more traditional toilets with door gaps.
This, I know from experience, is actually the only way to ensure all pupils are as safe as possible. There have been instances recently of children dying in full height cubicles in schools, I know from one school they were new and called ‘gender-neutral’ as it had been announced in the press.

There was a campaign to have a defibrillator in every secondary school because children do collapse and if you get to them in time you can save them. Toilets are where people head to when they feel ill. The DfE mention the ‘safety’ feature listed in their documents of being able to open a locked toilet door outwards from the outside to get a body out, so they are not totally secure. But this is retrospective and too late. It can be hours (in some public toilet cases) days before people are found. It takes 4 mins without oxygen for brain damage to start.

Unless a secondary school governing body goes against the ‘standard’ specification listed, then designers will now put in full height cubicles. These are for all new schools and refurbs. Manufacturers are designing full height stock for schools. I know once we get more of these into the general school system, there will be more incidents.

This is what I think (but it hasn’t been tested yet):
There are children in each mainstream secondary school with conditions that mean they could collapse and need help before they become critically ill. Anyone who works in a school will know this happens. Some of these children will have conditions classed as a disability (diabetes, epilepsy, heart conditions etc). They have a right to an education and reasonable adjustments (Equality Act 2010). There are now no toilets suitable for them if schools follow the guidelines and I think it’s unlawful. Just taking one condition epilepsy, that’s 1% of children and many more may be undiagnosed or have one off seizures. For example there have been children having seizures through spiked vapes. Children go to vape in the toilets.

I really hope, by raising awareness by my FOI and correspondence, the DfE realise why gaps are more important than total privacy. I am presuming they get data about deaths and ‘near-misses’ in schools because then hopefully they will see a connection. It’s usually only when you have personal experience (like me unfortunately) that it hits home.

I am not convinced they do have the data though. Because they don’t seem to have linked sexual assaults to private spaces in schools. If you look back at my previous posts you can see why I think full height cubicles are discriminatory against girls in terms of the Equality Act too. It’s girls who are most at risk for sexual assaults.

@WarriorN the toilets you described have been called ‘rape cubicles’ by a parent, for obvious reasons. Yes you will find lots of incidences on Everyone’s Invited, of assaults happening in lots of toilets. It’s difficult to know what design but, in the past, it is reasonable to think that the disabled toilet was mixed sex and private, which it where many assaults took place as well as store cupboards. I detest the fact I can’t find anyone who has centralised data on this because it’s horrific to have to research. There are many girls, boys and women who have been forced into toilet cubicles. If they are private, mixed sex, acoustically sound and can be opened from the outside, who does it benefit? Yet this is precisely what we have in the DfE guidelines for a new gender neutral toilet - though remember it is not obligatory. And it’s what every toilet cubicle becomes if you don’t enforce toilets being single sex.

It’s not just school toilets, people get forced into toilets in train carriages, stations, shopping centres etc. which is why the ‘but we have mixed sex toilets in trains etc’ argument falls flat.

Back to legislation, when I questioned the DfE originally about the private v safety toilet situation, before they told me they had no records of equality and impact assessments done on their standard designs, they said that schools should know their cohort and have appropriate supervision. Which I argued was unworkable in a mainstream school. Then afterwards, they referred me to 1974 legislation as detailed in a previous post. And said schools should act like ‘prudent parents’.

To conclude, it’s very complicated, there’s so many documents to get your head round and it’s difficult to know when guidance is actual law, and no one seems to have collated data to assess toilet designs for risks of safety and health (inc lack of ventilation, disease prevention and for fire evacuations) leaving the most vulnerable in an unsafe environment.

I will put in a disclaimer here in that I am an ex-teacher, not an architect or lawyer and what I have found out is from reading and corresponding with various organisations and doing research because I want to keep everyone safe. They are various organisations and groups of parents that are doing the same. Mumsnet has helped a lot of us have discussions.

Another thank you for this post KTS.
It still horrifies me that some schools are happy to abandon clear safeguarding issues when the trans lobbyists come calling. I know they're bullies. I know that intimidation & coercive control are their modus operandi. But schools are meant to be professional and centre children's needs, wellbeing and safety over the demands of a niche group of queer theory lobbyists.

Schools such as the one centred in this thread that openly abandon fundamental safeguarding principles need to be publicly exposed and held accountable for their actions. Otherwise they simply continue with their professionally dangerous actions, with children - especially girls - being harmed.

WarriorN · 12/04/2025 12:12

Bookmarking this post, thank you @Keeptoiletssafe for all the very hard work you’ve done. This is clearly a terrible loophole in safeguarding. I also can’t believe no one has this data.

(Sending a pm too)

Keeptoiletssafe · 12/04/2025 11:51

Hello
Apologies for the length. On phone, travelling.

This is the DfE specification for schools.
https://assets.publishing.service.gov.uk/media/65803d561c0c2a000d18cf3c/GDB_GenericDesignBrief-A-C17.pdf
And the annex for toilets.
https://assets.publishing.service.gov.uk/media/6380b52d8fa8f56eaf2f924b/GDB_Annex_2A_Sanitaryware-A-C12.pdf

If you search ‘changing rooms’ it says they have to be safe!

Primary is fine- mentions gaps. Secondary toilets don’t mention safety at all just privacy- a 5mm gap. This is what I have lots of correspondence with the DfE about. You will also note a completely new addition for the 2023 of a private toilet ‘identified as gender neutral’ on each floor. The language ‘identified’ jars with the normal tone and it has been tacked on with no explanation, since the 2020 documents. I am presuming this is to do with Stonewall membership the DfE had?
You can’t have both complete privacy and safety. Safety should be paramount (everywhere else in all DfE documents a ‘safe environment’ is the overriding factor).

What I have learned is:
@AnSolas
These are only guidelines. The DfE says you don’t have to use them. As long as a school says why, for example, they don’t want full height cubicle toilets, in the school specific brief, then you can go with the more traditional toilets with door gaps.
This, I know from experience, is actually the only way to ensure all pupils are as safe as possible. There have been instances recently of children dying in full height cubicles in schools, I know from one school they were new and called ‘gender-neutral’ as it had been announced in the press.

There was a campaign to have a defibrillator in every secondary school because children do collapse and if you get to them in time you can save them. Toilets are where people head to when they feel ill. The DfE mention the ‘safety’ feature listed in their documents of being able to open a locked toilet door outwards from the outside to get a body out, so they are not totally secure. But this is retrospective and too late. It can be hours (in some public toilet cases) days before people are found. It takes 4 mins without oxygen for brain damage to start.

Unless a secondary school governing body goes against the ‘standard’ specification listed, then designers will now put in full height cubicles. These are for all new schools and refurbs. Manufacturers are designing full height stock for schools. I know once we get more of these into the general school system, there will be more incidents.

This is what I think (but it hasn’t been tested yet):
There are children in each mainstream secondary school with conditions that mean they could collapse and need help before they become critically ill. Anyone who works in a school will know this happens. Some of these children will have conditions classed as a disability (diabetes, epilepsy, heart conditions etc). They have a right to an education and reasonable adjustments (Equality Act 2010). There are now no toilets suitable for them if schools follow the guidelines and I think it’s unlawful. Just taking one condition epilepsy, that’s 1% of children and many more may be undiagnosed or have one off seizures. For example there have been children having seizures through spiked vapes. Children go to vape in the toilets.

I really hope, by raising awareness by my FOI and correspondence, the DfE realise why gaps are more important than total privacy. I am presuming they get data about deaths and ‘near-misses’ in schools because then hopefully they will see a connection. It’s usually only when you have personal experience (like me unfortunately) that it hits home.

I am not convinced they do have the data though. Because they don’t seem to have linked sexual assaults to private spaces in schools. If you look back at my previous posts you can see why I think full height cubicles are discriminatory against girls in terms of the Equality Act too. It’s girls who are most at risk for sexual assaults.

@WarriorN the toilets you described have been called ‘rape cubicles’ by a parent, for obvious reasons. Yes you will find lots of incidences on Everyone’s Invited, of assaults happening in lots of toilets. It’s difficult to know what design but, in the past, it is reasonable to think that the disabled toilet was mixed sex and private, which it where many assaults took place as well as store cupboards. I detest the fact I can’t find anyone who has centralised data on this because it’s horrific to have to research. There are many girls, boys and women who have been forced into toilet cubicles. If they are private, mixed sex, acoustically sound and can be opened from the outside, who does it benefit? Yet this is precisely what we have in the DfE guidelines for a new gender neutral toilet - though remember it is not obligatory. And it’s what every toilet cubicle becomes if you don’t enforce toilets being single sex.

It’s not just school toilets, people get forced into toilets in train carriages, stations, shopping centres etc. which is why the ‘but we have mixed sex toilets in trains etc’ argument falls flat.

Back to legislation, when I questioned the DfE originally about the private v safety toilet situation, before they told me they had no records of equality and impact assessments done on their standard designs, they said that schools should know their cohort and have appropriate supervision. Which I argued was unworkable in a mainstream school. Then afterwards, they referred me to 1974 legislation as detailed in a previous post. And said schools should act like ‘prudent parents’.

To conclude, it’s very complicated, there’s so many documents to get your head round and it’s difficult to know when guidance is actual law, and no one seems to have collated data to assess toilet designs for risks of safety and health (inc lack of ventilation, disease prevention and for fire evacuations) leaving the most vulnerable in an unsafe environment.

I will put in a disclaimer here in that I am an ex-teacher, not an architect or lawyer and what I have found out is from reading and corresponding with various organisations and doing research because I want to keep everyone safe. They are various organisations and groups of parents that are doing the same. Mumsnet has helped a lot of us have discussions.

https://assets.publishing.service.gov.uk/media/65803d561c0c2a000d18cf3c/GDB_GenericDesignBrief-A-C17.pdf

WarriorN · 12/04/2025 08:57

Some new schools have single self contained loos with basins built into them for staff but also for some children. I know of a couple. My concern there is that someone can be forced into them and the door looked inside. They also take up a lot of space from an architectural design pov.

I was reading some of the testimonies from everyone’s invited yesterday primary section and one girl had been locked in a store cupboard by boys and assaulted in there.

WarriorN · 12/04/2025 08:54

SinnerBoy · 11/04/2025 20:10

From AnSolas

(2) Separate toilet facilities for boys and girls aged 8 years or over must be provided except where the toilet facility is provided in a room that can be secured from the inside and that is intended for use by one pupil at a time.

I've seen this advice but something has only just occurred to me. Surely this means a stand alone unit, such as found in small cafes and the like? A single unisex room, with a toilet and basin etc and not a communal latrine, with banks of contiguous lockable cubicles?

yes. Schools have been proudly flouting this.

I saw a head boasting about her new unisex loos aka colourful doors and kids could choose either room of toilets to access. Based on “pupil voice” 🙄

AnSolas · 12/04/2025 05:45

SinnerBoy · 11/04/2025 20:10

From AnSolas

(2) Separate toilet facilities for boys and girls aged 8 years or over must be provided except where the toilet facility is provided in a room that can be secured from the inside and that is intended for use by one pupil at a time.

I've seen this advice but something has only just occurred to me. Surely this means a stand alone unit, such as found in small cafes and the like? A single unisex room, with a toilet and basin etc and not a communal latrine, with banks of contiguous lockable cubicles?

Yes because courts have to go with the actual language of the Regulation

Separate toilet facilities for boys and girls aged 8 years or over must be provided except where the toilet facility is provided in a room that can be secured from the inside and that is intended for use by one pupil at a time.

Plus section 3 allows non pupils access
(3) Where separate facilities are provided under paragraph (1) for pupils who are disabled, they may also be used by other pupils, teachers and others employed at the school, and visitors, whether or not they are disabled.

So 3 class of units
SSS block type muitl unit
Mixed sex Single unit "wheelchair" accessable
Mixed sex Single unit non-"wheelchair" accessable

So a single unit non-wheelchair accessable toilet would fall out of the single sex provision but per section 1 would have to be pupil only or exclude pupils if non-pupils were allowed access.

On that point I dont think that the new fashioned open provision with openplan single toilet bank with no hand washing facility and open-access mixed sex wash basin would meet the legal requirement of toilet facilities if referred to the court on a point of law. The fact that a non pupil can access the washbasin fails section 1 and mixed sex fails section 2

@Keeptoiletssafe do you know if there are acts/regs which defined what items of sanitary were /plumbing must be included under the term "toilet facilities"?

@Grammarnut good spot on the language in the letter.
This means that at least some single-sex toilets, or toilets “in a room that can be secured
from the inside”, must be provided in a school. School XXX complies with this requirement.

least some single-sex toilets

If the school has gotten legal advice that a mixed sex block is legal they better have gotten it in writting from a sueable party.

"I have sought advice from the legal services department at Brighton and Hove City Council."

I expect the LA have a "this is not legal advice" section added to their communications.

Grammarnut · 11/04/2025 21:18

Regulation 4(2) of the School Premises (England) Regulations 2012 provides that ‘Separate toilet
facilities for boys and girls aged 8 years or over must be provided except where the toilet facility is
provided in a room that can be secured from the inside and that is intended for use by one pupil at
a time.” This means that at least some single-sex toilets, or toilets “in a room that can be secured
from the inside”, must be provided in a school. School XXX complies with this requirement.
Not sure if anyone else has seen this, but the school is misinterpreting the exception here. It looks to me as if that regulation means that single sex facilities must be provided but that lockable single-person use toilets can be provided instead of/as well, and these do not have to be single-sex. The school seems to think it means that if some toilets are single-person use lockable toilets then the remainder do not have to be single sex.
As to the rest, did anyone read the complaint?

SinnerBoy · 11/04/2025 20:10

From AnSolas

(2) Separate toilet facilities for boys and girls aged 8 years or over must be provided except where the toilet facility is provided in a room that can be secured from the inside and that is intended for use by one pupil at a time.

I've seen this advice but something has only just occurred to me. Surely this means a stand alone unit, such as found in small cafes and the like? A single unisex room, with a toilet and basin etc and not a communal latrine, with banks of contiguous lockable cubicles?

WarriorN · 11/04/2025 19:49

I expect the part they’ll also hold onto is the mis interpretation / assumption that it’s draft and so doesn’t mean anything. Whereas it has been written, included and must be referred to ‘as is’ now, in the document, and linking to the draft document, with further updates potentially occurring before sept 25. Doesn’t mean it will be dropped. It’s there now.

Their assumption is null and void in the light of many of the excellent points made on this thread relating to legislation already in existence (ie not in relation to kcsie) based on sex.

if the op gets them to repeat these assumptions it will be useful for further steps.

also the term transexual - <shudders>

WarriorN · 11/04/2025 19:38

Excellent points, thanks!

AnSolas · 11/04/2025 18:09

WarriorN · 11/04/2025 17:46

They will bat back with “ kcsie states that LGBT children are not a risk in themselves but may require extra support” as per their first reply

They may try that but the LGB have a legal right to SSS and there is no T in the section quoted

paragraph 205 of the guidance which states:
“ A child or young person being
• lesbian,
• gay, or
• bisexual
is not in itself an inherent risk factor for
harm, however, they can sometimes be targeted by other children.”

Unless the school is proposing that an individual L/G/B child will be allowed access to the other sexs SSS there is no reason to mention this.

And no outstanding legal basis for the school to even attempt to collect the data.

If the school are proposing
For girls
T+ L/B = male SSS but
T+ S = female SSS
For boys
T+ G/B = female SSS but
T+ S = male SSS

They are discriminating on the PC sexual orientation as "Straight" is also a PC

Equality Act 2010

12. Sexual orientation
(1)Sexual orientation means a person's sexual orientation towards—
(a)persons of the same sex,
(b)persons of the opposite sex, or
(c)persons of either sex.

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