Work Gender Diversity Policy Consultations

[StellaAndCrow]

I work in a large public sector organisation. I'd checked that it wasn't a Stonewall Diversity Champion, and it wasn't on the list.
A policy has been circulated for consultation "Gender Diversity Equality and Inclusion Policy". It mistates the law, and seems to have misunderstood the concept of Equality Impact Assessment - saying for everything "positive or no impact".
It says that people can self identify their gender, and use the changing rooms appropriate to their chosen gender. And that gender fluid people might need two uniforms.
I'm surprised they're jumping on board with Stonewall just now, when there are so many concerns. They've consulted very narrowly so far, and we don't have a women's group, so I'm going to have to do an individual reply - I'm wondering whether to do it in my name or anonymously.
It feels daft and presumptuous to be advising them on the law, when it's coming from HR and directors, but it is clearly inaccurate.

I thought I'd start a thread as others may be in the same situation, and I'd find it helpful to share thoughts.

Has anyone here responded to a similar consultation? Thank you. :)

I meant to say - they weren't on the list of Stonewall Diversity Champions when I checked, but this policy states that they are, and that they met with Stonewall rep in March.

It has a list of definitions including
Cisgender : a person whose gender identity matches their sex assigned at birth.
Gender identity : a person’s deeply felt internal and individual experience of gender, which may or may not correspond to the sex assigned to them at birth.
Legal sex : The sex recorded on your birth certificate. Rarely relevant at work. Currently binary in the UK. Changed by applying to Gender Recognition Panel.

There's no mention of biological sex. And it doesn't mention that not everyone has a gender identity (or believes in the concept)
I'm not sure of the best approach.

I'm very happy to respect other people's belief in gender identity, but this seems to assume that everyone has one - I don't.

And
This policy has been developed together with colleagues from the Transgender Community with engagement and feedback gained from a number of different sources to ensure voices have been heard and views considered. There should be no negative impact of implementing this policy for any protected groups.

From the supposed "Impact Assessment",
Sex - This policy aims to support all staff regardless of sex, including non-binary people. That's it.
Similarly:
Age -People can transition at any age. Consideration given to the potential impact in terms of family and peer support, or lack of in some cases. This policy aims to support all people regardless of age or personal experience.
Religion or belief- Although individual views and cultural beliefs around Transgender people may differ, this policy provides positive support in terms of the Trust’s legal, ethical and moral obligations.

Addressing the impact on equalities : Positive impact

They don't seem to understand that an impact assessment should be about how a policy might impact on these other protected characteristics - should I be pointing that out?

Sorry I'm annoyed and these aren't even the most annoying bits.

Has anyone had any success with responding to work policy consultations? I've asked whether people can respond anonymously - apparently I'm the only person who's ever asked, so I may not be that anonymous! :) Thank you.

This is an NHS organisation btw - there's no mention at all of patients in the policy, or any effects on single sex provisions for patients.

This article might be helpful OP - it outlines the key issues with Stonewall law being applied in NHS settings: www.hsj.co.uk/workforce/working-with-stonewall-is-no-longer-compatible-with-nhs-values/7030259.article

And here's an overview from Sex Matters; sex-matters.org/where-sex-matters/healthcare/

They have clearly misunderstood the meaning of an equalities impact assessment - it is intended to provide an overview of the impact of a single policy on all other protected characteristics - and to set out how any negative impacts will be mitigated. That would need to be applied to patients and staff. The negative implications for the PCs of sex, race, belief and disability are self-evident.

It's infuriating that we have to keep explaining this to organisations!

That's brilliant, thanks very much olderbadger. Yes they seem to have completely misunderstood the concept of an impact assessment. I feel quite annoyed about it - it is the job of the people making the policy to check these things, surely.
Thank you for those links; I can use them to formulate a response.

I also found this which is useful - Cardiff University academics have written to the vice-chancellor about the university's relationship with Stonewall:
sites.google.com/view/cardiffopenletter/open-letter

They are getting a lot of support too...

Sex Matters have a template letter about Stonewall membership - sex-matters.org/posts/updates/leave-stonewall/ - I used it as the basis of a letter to my MP and Senedd member.

Water might wear away a stone(wall) eventually. Good luck.