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Feminism: Sex and gender discussions

Complaint in to Lewisham re EHRC

36 replies

13RidgmontRoad · 11/08/2026 20:46

Two of us put our heads together and have submitted the following. More obviously very welcome. If there is appetite for in-person discussion or activism around this issue I'm happy to (vet and) arrange it.

Complaints to Lewisham: lewisham.gov.uk/mayorandcouncil/complaints-and-feedback/how-to-send-us-a-complaint-or-feedback

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Mayor Shrivastava,

We are writing to you regarding the recent statement published by Lewisham Council concerning the EHRC's updated Equality Act 2010 Code of Practice (CoP).

We agree with you that all residents of our borough deserve to live with dignity and safety and have no desire to see trans people excluded from council services. We are, like many, firmly in favour of the provision of third spaces where these can be appropriately and safely implemented.

However, we are concerned that in your focus on ensuring inclusivity for trans residents, the council is disregarding the importance of protecting single-sex spaces for natal women and girls in a context where they continue to be subject to disproportionate levels of assault, abuse and harassment (https://www.ons.gov.uk/peoplepopulationandcommunity/crimeandjustice/articles/thenatureofviolentcrimeinenglandandwales/yearendingmarch2024) which in our view and in law underpins the existence of single sex provision.

It is essential that the council acknowledges that provision for trans people cannot be made at the expense of these established protections and that women and girls' rights and experience have weight. Any future approach to service design must be handled with care, acknowledging the needs of the whole population of the borough, including those for whom single-sex provision is a necessity for cultural, religious, or personal safety reasons and to whom the council has an equal obligation.

As you know, the CoP is designed to protect women in single-sex spaces. This is following on from the ­Supreme Court's April 2025 decision in For Women Scotland that the interpretation of UK equality law requires terms such as 'man' and 'woman' to be read with their ordinary biological meanings. That means that women's services which are sex-segregated - among them changing rooms, rape crisis centres and hospital wards - must not be open to men, whatever their gender identity. This does not mean transgender people have in some way lost legal protection - they are protected under equality law. The EHRC also provides public-facing organisations with practical advice about how to comply with the law.

We would be grateful if you could clarify the council's specific approach to the day-to-day management of its services. Specifically, how does the council intend to ensure the continued accessibility and privacy of, for example, female-only swimming, gym, and dance sessions'which are vital services for many local residents'as well as the management of toilet and changing facilities across our public sites? And how does the council intend to ensure that services for some of its most vulnerable women, including domestic abuse services, rape crisis services and refuges - appropriately meet their needs?

The council is right to be conscious of the experience of different minorities within the borough. However, a truly egalitarian, inclusive and conciliatory approach must also recognise that Lewisham is home to a diverse population with a wide range of needs. We believe that working to achieve a balance where provision is thoughtfully designed to be inclusive of all residents, rather than prioritising the needs of one group to the detriment of another is the most appropriate use of council resources. It also importantly fulfils the council's obligations under the Public Sector Equality Duty - which, counter to your assertions in your motion - already protects right of trans people from discrimination, harassment and victimisation under the protected characteristic of gender reassignment, alongside, and with an equal weighting to, the eight other protected characteristics, including sex.

A challenge by the council against the EHRC Code of Practice, underpinned as it is by the ruling of the Supreme Court, would represent a gross misuse of the council's resources which runs counter to your obligations as part of Best Value duties and leaves you open to legal challenge and scrutiny, including by the Local Government Ombudsman at the point of which service users are affected by your decisions.

At a time when local government resources are severely constrained, we would expect you to focus resources on delivering the best outcomes for all residents rather than pursuing - at potentially significant cost to the council - a position which is at odds with your responsibilities under the Equality Act 2010 (including the promotion of good relations between communities), on which you have not undertaken any public consultation and on which the EHRC and Supreme Court have conclusively ruled.

We look forward to hearing your thoughts on this matter and understanding the council's strategy for navigating these issues in practice. We would appreciate a response to this letter within the timescales set out by Lewisham Council's complaints procedure.

Name 1
Name 2

The nature of violent crime in England and Wales - Office for National Statistics

An overview of the extent of violent crime in England and Wales, including long-term trends, use of weapons, and victim characteristics.

https://www.ons.gov.uk/peoplepopulationandcommunity/crimeandjustice/articles/thenatureofviolentcrimeinenglandandwales/yearendingmarch2024

OP posts:
minsmum · 11/08/2026 21:48

I would send to the Mayor and Chief Executive and also copy in the legal department. The Chief executive runs the council

Keeptoiletssafe · 11/08/2026 22:20

If you want to mention toilets as it seems that’s what get most attention:

‪Options‬ for allowing everyone in all toilets
‪They can: ‬
‪1. Dismantle all single sex toilet cubicles and build individual universal rooms‬
‪2. Contravene building regs, legislation and standards and permit everyone in to cubicles‬ and separate sex toilet washrooms. Certain sections of the Sexual Offences Act may need to be revisited.
‪3. State single sex means single sex and the regulated toilets stay as they are‬

‪3. is best for health, safety and not blowing all their budget on less safe and less hygienic designs‬

I may helpfully show them the building regs 2010 and mentioning that if the building owner or those responsible for the toilet refurbishment works contravene the Building Regulations, the local authority may prosecute them(selves) in the magistrates’ court 😵‍💫

Complaint in to Lewisham re EHRC
13RidgmontRoad · 12/08/2026 06:38

Keeptoiletssafe · 11/08/2026 22:20

If you want to mention toilets as it seems that’s what get most attention:

‪Options‬ for allowing everyone in all toilets
‪They can: ‬
‪1. Dismantle all single sex toilet cubicles and build individual universal rooms‬
‪2. Contravene building regs, legislation and standards and permit everyone in to cubicles‬ and separate sex toilet washrooms. Certain sections of the Sexual Offences Act may need to be revisited.
‪3. State single sex means single sex and the regulated toilets stay as they are‬

‪3. is best for health, safety and not blowing all their budget on less safe and less hygienic designs‬

I may helpfully show them the building regs 2010 and mentioning that if the building owner or those responsible for the toilet refurbishment works contravene the Building Regulations, the local authority may prosecute them(selves) in the magistrates’ court 😵‍💫

Thank you very much! I appreciate your contributions and the knowledge you bring to a lot of these threads.

I think we both wanted less focus on toilets in our letter, rightly or wrongly. “Toilets” seems to get everyone taking up a defensive position, and here it seemed like it might be more productive to point to other provision in the borough which is and should be single-sex. Let’s see. We may still get the same mumbo-jumbo back from them.

OP posts:
Dexternight · 12/08/2026 06:45

Tell them you know they are looking to make savings to all to essential services. There is massive pressures on children's, adult social care and temporary housing.
He the mayor should be focusing on this.

highame · 12/08/2026 07:11

Nice one op. I look forward to your updates

Boiledeggandtoast · 12/08/2026 07:26

Excellent letter @13RidgmontRoad , thank you.

LydiaMerton · 12/08/2026 07:33

Good letter - best way to ensure a response is to send to CEX and head of legal but also to put the questions in as an FOI. The council has a statutory obligation to respond to an FOI within 20 days and there are only a very few reasons not to do so, none of which would apply to this letter. For the FOI request I’d suggest you just make a list of questions. FOIs could be very powerful tools in flushing out exactly what local authorities are doing and, indeed, getting them to confront their own lack of action, as most are putting their heads in the sand and hoping it will all go away. We should all be putting FOIs in to our local authorities.

PublicSectorHag · 12/08/2026 08:44

LydiaMerton · 12/08/2026 07:33

Good letter - best way to ensure a response is to send to CEX and head of legal but also to put the questions in as an FOI. The council has a statutory obligation to respond to an FOI within 20 days and there are only a very few reasons not to do so, none of which would apply to this letter. For the FOI request I’d suggest you just make a list of questions. FOIs could be very powerful tools in flushing out exactly what local authorities are doing and, indeed, getting them to confront their own lack of action, as most are putting their heads in the sand and hoping it will all go away. We should all be putting FOIs in to our local authorities.

Great letter OP. Agree that FOIs are the best way of getting a response. In this case though, I don’t believe there will have been any implementation of the motion, so the questions might need to be along the lines of:

  1. Have you taken legal advice on the implications of your motion and if so, what advice did you receive and from whom? (Answer is probably no)
  2. What is the anticipated cost of pursuing this motion and where is the funding coming from to do this? (The answer will probably be that they haven’t considered this).
  3. Has an equality impact assessment been initiated to understand the impact of any potential actions on residents and service users, taking into account all nine protected characteristics? If this has not happened yet, when will this be done? (Don’t think this would have happened but makes point it should).
Keeptoiletssafe · 12/08/2026 09:18

13RidgmontRoad · 12/08/2026 06:38

Thank you very much! I appreciate your contributions and the knowledge you bring to a lot of these threads.

I think we both wanted less focus on toilets in our letter, rightly or wrongly. “Toilets” seems to get everyone taking up a defensive position, and here it seemed like it might be more productive to point to other provision in the borough which is and should be single-sex. Let’s see. We may still get the same mumbo-jumbo back from them.

Yes I agree. It’s difficult to know what their position is, but be aware these are the choices if they want everyone to access every toilet.

The only thing I would add is my previous post is this is only a basic outline. I can go in to much more detail about why 1. or 2. won’t work as a policy if you get to that stage. For example in terms of risks and equality impact assessment.

FanOfGailDines · 14/08/2026 15:02

Excellent letter. Thanks for putting it on here.One of the things I have thought is often as parents we send kids, including the young boys as well as girls off to female facilities knowing they will be safer there. Quite often the children are unsupervised for a time, for example going off to use toilets or changing rooms. We are supposed to be giving the kids more freedom and independence! Anyway, how do I explain to the children that if there is a man in the facilities this may or may not be cause for alarm and even though he looks like a man he might be a woman? I mean, what doesn't Lewisham Council want me to do as a mother? Either keep my children unhealthily supervised or give them explanations that don't make sense and also fly in the face of Safeguarding. The times we live in are a bit exhausting!

KnottyAuty · 14/08/2026 22:53

Bumping past the visitor’s 2010 zombie threads…

FanOfGailDines · 15/08/2026 12:47

I feel I wasn't very clear in my point: Is there an aspect of this related to children that should be highlighted? If men who identify as women are able to use women only facilities and this is supposed to be normalised how do you explain to children what might or might not be concerning? If it is not okay to say to children under the age of eight (which will include both boys and girls) that they shouldn't pay attention to a man in a woman's space is this not opening up an opportunity for those who would like to take advantage of that situation? How can you give children clear advice that would not be seen as prejudicial? What is the Council's advice to parents? I have lived in Lewisham most of my life and visit regularly but we live in Ireland now so I'm not a resident. In Ireland we have Gender Self ID and Gender Ideology and Trans Inclusivity are very embedded.
Anyway, I don't know about Safeguarding laws but it seems to me that there is a problem with explaining things to children whilst keeping them safe. You can't just say 'Transwomen are Women' to a five year old.

Ereshkigalangcleg · 15/08/2026 12:50

I think this is a good point and I don’t know the answer. Nor I suspect do the virtue signallers and activists at Lewisham council.

Ereshkigalangcleg · 15/08/2026 12:50

What happens in Ireland where self ID is the law?

Llamasarellovely · 15/08/2026 13:59

Gosh that's much better than my inquiry of my council (one of the other renegades) asking if they could let me know which other laws I can safely disregard. I might save yours for the follow up 😀

MsGreying · 15/08/2026 14:03

LydiaMerton · 12/08/2026 07:33

Good letter - best way to ensure a response is to send to CEX and head of legal but also to put the questions in as an FOI. The council has a statutory obligation to respond to an FOI within 20 days and there are only a very few reasons not to do so, none of which would apply to this letter. For the FOI request I’d suggest you just make a list of questions. FOIs could be very powerful tools in flushing out exactly what local authorities are doing and, indeed, getting them to confront their own lack of action, as most are putting their heads in the sand and hoping it will all go away. We should all be putting FOIs in to our local authorities.

https://www.whatdotheyknow.com/select_authority

What do they know is a good place to start.

FanOfGailDines · 15/08/2026 14:27

I have really no knowledge of what happens in Ireland. We live in a country town and have only been there for a couple of years. However, I have been made aware of all of this recently because I have been trying to do some work raising awareness about children seeing pornography and the many harms of that and so have looked at the Sex Ed programme for secondary which has a big chunk of gender ideology in it. The crazy thing is that all the people who 'get it' about the harms of porn and are the same organisations and people who are sold on Gender Ideology so it's all very confusing. Parents are rightly concerned about their children taking part in some of these classes and that gets in the way of things that really should be covered and are fact-based, evidence-based. This summer I have read Helen Joyce's book on Trans and also listened to the podcast series 'Julie in Genderland' and listened to Stella O'Malley. The only good discussion I've heard with anyone from the other side of the argument is a conversation between Peter Tatchell and Andrew Gold on his 'Heretics' podcast. So I'm trying to get myself well-informed but all I know so far about Self ID is that it is very easy to do and was sort of sneaked in without public debate. I am also Australian and in Australia there has been this ruling recently of 'Giggle vs Tickle' which is mad stuff. Despite what's being stated in Lewisham you are much better off in the UK on this issue than many other places. Thanks to the hard work of campaigners. I'm very grateful to them.

FanOfGailDines · 15/08/2026 18:15

So perhaps some questions for an FOI request could be something along the lines of:

What actions have Lewisham Council taken as part of their internal review to make sure that Children's Safeguarding is not diminished by the Council's public statement that no trans person be excluded from public spaces? These spaces will include the spaces which are the accepted safe space for children.

What actions have you taken to ensure that, for example, men who like to 'flash' don't take advantage of the public statement of the council because it will be hard to challenge men being in women's spaces?

What efforts have you gone to in this review to ensure that by your actions you have not, in trying to protect one vulnerable group, made another (children) less safe in the Borough of Lewisham?

Lewisham Council say in no uncertain terms: Trans women are women but what is your advice to parents on how to explain this to children? Explain that the person who looks like a man may or may not be able to use the women's toilets or changing rooms (which is also the space for children under 8 who are sometimes unsupervised)?

I don't know what the good wording would be but something along those lines... Does anyone have any advice?

BridgetYourFortyDaysAreUp · 15/08/2026 19:27

I'm afraid I've never submitted an FOI before, but hopefully someone else here has!

I think your questions are good, and the impact on safeguarding children should focus minds should!)

EasternStandard · 15/08/2026 20:44

Well done op, let us know what they respond with

FanOfGailDines · 15/08/2026 21:46

First link is Child Safeguarding Responsibilities of Councils. Second link is the Pornography Report from the Children's Commissioner. Women and children have always been subject to molestation and abuse but things have been made worse by the dominance of the pornography industry in our culture. In this increasingly tricky national environment for Lewisham Council to be cavalier about their safeguarding responsibilities to children and recklessly change established social norms that give women, girls and children a degree of security, driven by their blind ideology is pretty upsetting. Where is the sanctuary for these groups in the 'Borough of Sanctuary'?

https://www.local.gov.uk/publications/must-know-safeguarding-children

www.childrenscommissioner.gov.uk/resource/sex-is-kind-of-broken-now-children-and-pornography/

FanOfGailDines · 16/08/2026 16:54

Dear Mayor Shivastava,

I would like to submit a Freedom Of Information request regarding the recent statement published by Lewisham Council concerning the EHRC's updated Equality Act 2010 Code of Practice (CoP).

I would like to highlight the Government’s Must Know for Child Safeguarding that states that councillors should ensure their council is meeting these duties by considering Child Safety in all Services and Decisions.

Taken from the Local Government Association website:

Council services
Do staff have effective systems and technology to enable them to keep children safe?
Is council funding on child safeguarding spent effectively? Is it sufficient? How do you know?
Is there effective scrutiny of child safeguarding issues in your area?
How do you know whether your services keep children safe?
Are there any groups of children who are less safe than others in your area? Consider for example different characteristics and particular vulnerabilities.
Do all services within your council understand their role in child safeguarding?
Has your council recently invited the LGA to carry out a child safeguarding peer review?

These are my FOI Questions:

  1. What actions have Lewisham Council taken as part of their internal review to make sure that Children's Safeguarding is not diminished by the Council's public statement that no trans person be excluded from public spaces? These spaces will include the spaces which are the accepted safe spaces for children.
  1. What actions have you taken to ensure that, for example, men who like to 'flash' don't take advantage of the public statement of the council? Because it will be hard to challenge men being in women's spaces.
  1. What efforts have you gone to in this review to ensure that by your actions you have not, in trying to protect one vulnerable group, made another (children) less safe in the Borough of Lewisham?
  1. Lewisham Council says, 'in no uncertain terms: Trans women are women' but what is your advice to parents on how to explain this to children? How do you advise parents to explain to their children that the person who looks like a man may or may not be able to use the women's toilets or changing rooms? These spaces are also the space for children under 8 who are sometimes unsupervised.
FanOfGailDines · 16/08/2026 17:10

Question numbers should say 1-4 obviously!

Ereshkigalangcleg · 16/08/2026 17:30

That’s great, I bet they try to fob you off. But then you can escalate it.

13RidgmontRoad · 17/08/2026 06:57

That’s brilliant @FanOfGailDines , thank you and well done!

OP posts:
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