Are you in Devon, Bristol, North Somerset or South Gloucestershire? Tell NHS your view on trans guidelines NOW

[anotherFOIrequester]

Happy New Year!

Starting a new thread with the aim of putting all the information in one place as I now have a clearer picture.

Old thread here: www.mumsnet.com/Talk/womens_rights/3755711-Help-FOI-request-trans-guidance-in-NHS-in-South-West?pg=1

The NHS CCG for Bristol, North Somerset and South Gloucestershire are adopting 'best practice' guidance for trans patients that you can read here:

bnssgccg-media.ams3.cdn.digitaloceanspaces.com/attachments/govbody_5Nov19_item6.4.pdf

There is no consideration of women or anyone else with protected characteristics, eg 'Providing education to other service users in a ward to prevent ignorant or transphobic comments is, if successful, a better solution than having to protect or isolate the trans service user'.
There has been no equality impact assessment, no risk assessment and no consultation with patients who don't identify as transgender.

The guidance is produced by Bristol charity SARI (Stand Against Racism and Inequality) but the meeting minutes below reveal that the lead writer is Cheryl Morgan, director of the Diversity Trust:

bnssgccg-media.ams3.cdn.digitaloceanspaces.com/attachments/govbody_3Dec19_item3.pdf

Morgan is a transwoman who attended a menopause event and claims the ability to breastfeed:

medium.com/@elsaegret/abusive-misogynist-activist-writes-nhs-policy-in-bristol-21dd02cc4c9c

Morgan has also used abusive language to women for many years:

www.thetimes.co.uk/article/police-used-violent-transgender-activist-for-equality-training-x0mktgclw

SARI and the Diversity Trust have form:

medium.com/@elsaegret/stitch-up-bristol-fashion-f1eb298e28da

The guidance also features the logos of North Bristol NHS Trust and Devon Partnership NHS Trust. I have FOIs pending with both of them to establish what's happening there.

In response to women contacting the BNSSG CCG, they are now conducting an EIA, for what that's worth.

The good thing is we are disrupting the usual 'under-the-radar' proceedings before this is signed off - this is the time to contact them if you're in those areas, or if you're in Devon, or if you live elsewhere but use those NHS services.

Bristol/South Glos/North Som: [email protected]

North Bristol NHS Trust: [email protected]

Devon Partnership NHS Trust: [email protected]

Really glad to see this pushback in Scotland. How DARE they say to a woman who doesn't want to sleep next to a random male that she's as bad as a racist?

I notice a big difference - in Scotland MSPs are publicly criticising this, while down here... nothing. Women have definitely conatcted their MPs about it so what's the difference?

Tara Hewitt, who for some reason gets to tell the NHS what do, says:

'I think we need to be careful in saying this is new thou same with the "new" ward placement guidance which was substantively the same as it has been for a decade or more. Since Equality Act 2010 the training and guidance has been treat transphobic people in same way as racist.'

twitter.com/Tara_Hewitt/status/1235667195885228033

See also this:

uncommongroundmedia.com/the-2010-equality-act-is-being-undermined-by-official-guidance/

Wrote to Lord Lucas.

This was on BBC South West Politics today: www.bbc.co.uk/iplayer/episode/m000g8j9/politics-south-west-08032020

Coverage was pretty good and they gave about half the show to it - great overview section on the law from Jenny Kumah. Kathleen Stock was on it, and also Nicola Williams opposite Stephen Whittle. It's interesting that Whittle was representing the trans activist position rather than the transwoman who actually wrote the guidance. Whittle said not wanting a male on a female ward was akin to racism!! NW shot Whittle right down.

Tory MP was vague but had picked up on all the pledge damage, failed (can't think why) Lab candidate was TWAW TMAM.

Significantly, there was consensus that women are not being 'transphobic'... So secrecy is out, accusations of bigotry are out...what will TRAs do then?

I would have liked more on the awful statistics for sexual assault on mixed sex wards, and the point that women are being put in de facto mixed sex wards without being told.

Alarmed now that so many of the Plymouth public don't know what a woman is...

Hello! Have had time to look at all this again after adjusting to lockdown life and work and discovered this policy by the Devon Partnership NHS Trust. It's an absolute car crash! Picking my jaw up off the floor.
Hadn't noticed it before as had focused on the SARI guidance which 3 trusts inc Devon had signed up to, but it predates it (it's from 2018), is 100x worse, and is actual policy rather than guidance.

Devon women need to get this withdrawn.

It has the usual bonkers glossary, links and refs to Stonewall, GIRES, Mermaids and local cross-dressers' social groups. Not one mention of the consent of other patients to being in mixed sex wards (thank you MayaForstater for framing this so clearly) but a whole section on 'Transphobic Service Users'.

According to the glossary, 'transphobia' is 'A term used to describe a person with a fear or hatred of people who are transgender'. So - if you're a woman and a man is admitted to your single sex ward, the NHS is in the wrong and failing to implement its policy. As soon as that man says 'I'm a woman' you are full of fear and hatred.

'Case-by-case' is misrepresented as usual to mean each person rather than each service. While four paras a re given to those 'transphobic service users' only two mention any kind of counterbalance:

'14.4. For example, there if there [sic] are patients who have been victims of domestic violence or sexual abuse and may continue to be exceptionally vulnerable when sharing accommodation with other patients of a certain gender.'

It's those certain genders again!

So in order to access single sex NHS services in Devon women have to disclose DV and sexual abuse.

This is the real jaw-dropper:

'14.5. Where a transgender woman is admitted and has a history of sex offending, decisions regarding risk should include consideration of whether they are being prescribed anti-libidinal medication that would be expected to reduce sexual risk.'

People with DSDs are lumped in as usual despite no consultation with individuals with DSDs or orgs representing them.

There's a lot more, but to cap it all off they list the EA2010 protected characteristics and replace 'sex' with 'gender' and there's a pitiful EQIA which also does this.

It's unbelievable. Download here:

www.dpt.nhs.uk/resources/policies-and-procedures/clinical/supporting-transgender-non-binary-and-intersex-patients

Again, they have no idea what an Equality Impact Assessment is for, or how to do one.

I'm about to contact my local health Trust re a similar reason- their trans guidance infringes on single-sex service provision. I'm going to request a copy of their EIA though I presume I might have to make a FOI request.

It also infringes on child and parental rights as it states children it is preferable to accommodate minors according to their gender, even where the parents disagree, even if the child is not Gillick competent.

The Trust currently operates a male-only forensic mental health service at Langdon Hospital in Dawlish and a female-only Mother and Baby Unit at Wonford House in Exeter. Decisions relating to admission of a transgender person to these gender specific, single sex wards will be clearly documented and will consider the associated risks for the transgender person as well as other people on the ward. Any risks identified will be considered in a way which is dynamic and will be managed appropriately throughout the admission. Where the admission is to Trust Secure Services, an Access Assessment must be undertaken.

No man should ever be an inpatient in a Mother & Baby Unit

Utter, utter nonsense.

"Gender specific, single-sex wards" 🙄

Right, it's insane. Reading this stuff and trying to work out what they actually mean makes me feel as if I'm under sedation...

Chemise I think ironically in both those examples they are actually trying to look out for female people (who ID as trans). They recognise that a) there's a risk to female people from male people as in the forensic MH service and b) only female people give birth - I think the 'risk' is assumed to be from transphobic labouring mothers??!

So they fully understand two of the points we make again and again and again (male violence/biology exists)... but they only apply to females who trans-ID.

The rest of us will be post-op in a bed next to a male sex offender, and were we to make those points the staff would be directed to the 'Transphobic Service Users' section of the policy where they'd be told to record us on the risk management system.

I cannot believe that the starting point is not, now and forever, NO MALE SEX OFFENDERS ON FEMALE WARDS, but 'Hey, let's think outside the box, maybe there's a flexible way we can have some male sex offenders on female wards, I mean, why not?'

The starting point is women in Devon are not guaranteed a hospital bed away from a rapist.

I can't... my god.
My whole family lives in the south west, ranging from my 90 year old gran to my four year old niece. I'll have a proper read of this later and see if I can get my mum or sister to write in.

I'm still following; thanks for highlighting this op. I'll be sending it to relevant people.

Someone has posted on the M&S thread that Baroness Nicholson is now asking for evidence that public bodies including the NHS have implemented self ID. I think she’d be very interested to receive links to the documents recently posted - it is outrageous!

mobile.twitter.com/Baroness_Nichol/status/1262710247216553984

boatyard it'd be brilliant if you could link her to this thread - I'm not on Twitter

I’m not on Twitter but some posters have been emailing her at her parliamentary email & receiving prompt replies and thanks from her team.

Baroness Nicholson is now asking for evidence that public bodies including the NHS have implemented self ID.

Has she seen this guidance for NHS England?
improvement.nhs.uk/documents/6005/Delivering_same_sex_accommodation_sep2019.pdf

Previous thread here
www.mumsnet.com/Talk/womens_rights/3705528-New-NHS-guidance-on-same-sex-accommodation

From the OP of that thread:

But then there is Annex B, which says 'Trans people should be accommodated according to their presentation: the way they dress, and the name and pronouns they currently use. This may not always accord with the physical sex appearance of the chest or genitalia. It does not depend on their having a gender recognition certificate (GRC) or legal name change. It applies to toilet and bathing facilities (except, for instance, that preoperative trans people should not share open shower facilities).' Annex B was apparently written with input from the Government Equalities Office.

NHS accommodation is now mixed sex accommodation with allocations based on pronouns.

FOI request for their Equality Impact Assessment
www.whatdotheyknow.com/request/equality_impact_assessment_for_d_2

This is the response I got after prompting them a few times (they were a bit reluctant to respond to my request).
FOI response

Their response showed that they think people's sexual orientation is the reason for producing guidance on delivering same-sex accommodation and they think 'sex or gender' is a protected characteristic.

5.3. Gender reassignment–Significant given the subject matter of the guidance.

5.8. Sex or gender–Significant as this is the reason the guidance exists

5.9. Sexual orientation–Significant as this is the reason the guidance exists

There's going to be a Zoom meeting with the cheif exce and inclusion head etc next week for women who complained. I'm going to be working!! Not the best time to mess work commitments around, but I'll see what I can do, and if I can't do the meeting I'll write in.

Apols if you’re already onto this and I cant remember which authority’s guidance I found this in (Cornwall?) But one of the policies Re admitting TW to female wards says; “Where a transgender woman is admitted and has a history of sex offending, decisions regarding risk should include consideration of whether they are being prescribed anti-libidinal medication that would be expected to reduce sexual risk.' This seems to be suggesting that male sex offenders on the right medication would not necessarily be excluded from female wards. Wondering if anyone’s seen this in any other policies?

Hey - can I just check which area this is in as it would be good to know when attending other meetings too. Thank you :)

Think it’s Devon’s - published a couple of years ago

@XXcstatic

I work in the NHS, though not in the regions mentioned here. It is crucial to keep up the pressure on the CCGs: provider organisations like hospitals have to do what the commissioners (CCGs locally, NHS England nationally) tell them. It is the commissioners who direct policy.

Write to the clinical chairs of each CCG, both of whom are GPs:

For Bristol, N Somerset & South Glos, it's Dr Jonathan Hayes, c/o [email protected]

For Devon, it's Dr Paul Johnson c/o [email protected]

Bear in mind that they are both middle-aged men and probably have no clue about TRAs. I would suggest assuming no prior knowledge of trans issues and taking care not to sound transphobic, because this will make it easier to dismiss you as 'some kind of bigot' (to quote Gordon Brown). They are probably still at the 'Why can't we all just be nice?' stage, if they have thought about transgenderism at all.

I would instead focus on process: you are aware that a new policy is being considered. Could they please provide a copy of the equality assessment? What steps have been taken to ensure that there will be no negative impact on people with other protected characteristics, notably women especially those from cultures/religions that don't allow mixing of the sexes? What is the basis in law for stating that the needs of trans people should be prioritised over other people with protected characteristics?

I would follow up by quoting the EA's provision for single sex facilities.

Finally, I would ask them to explain why Cheryl Morgan was chosen to provide advice, given her history of violent misogyny and link to the Times article - CCGs hate negative publicity and won't want to see themselves criticised in the national media, as happened to the police.

Thank you. I'm in the West Country so that is very helpful.

Sorry, just realised we're way past the date for submissions.

SameoldBS no harm in writing and making your views known. No closing date.

I sent a FOI to Devon Partnership NHS Trust asking how many male sex offenders have been accommodated on female wards:

www.whatdotheyknow.com/request/convicted_male_sex_offenders_on