Extra male toliets, female converted

[BelleOfTheProvince]

I'm sorry to repeat a theme but there was a similar thread with the information I need but I can't find it.

Was at a school premises today for a kid's activity (outside school agency)

It's a school I've visited before with children for competitions so I knew where the loops were roughly. It's a secondary school with an added on gym entryway and a cafe next door.

So went to go to the loo as usual and couldn't find it. Saw the men's, disabled traced back my steps and realised that they'd taken the sign off completely. No unisex, gender neutral, no indication it was a toliet at all. Went back to outside agency and asked where the ladies toliets are. They showed me to a separate men's, ladies and unisex attached to the gym foyer(so further away than the men's near the activity and the women's I remembered from past competition) I asked why the other loo wasn't signposted was told 'we don't use that one'.

So this secondary and public space has:
4 female cubicles (entry)
Presumably the male equivalent opposite
A disabled single occupancy

Nearer the activity
Additional male provisions
Disabled
And unisex not signposted.

I know it wasn't just me that was thrown. Saw another mum going into the non signed loos.

So it looks on the surface that there's much less provision for women/girls but is unclear as they haven't even bothered marking as unisex.

Now, obviously there could be very practical reasons for why it needs to be unisex(it's attached to a changing room so it could we'll need to be alternate girls and boys)

However I suspect it's the usual keep the men's make the women's unisex bollocks.

Any letter templates or relevant legislation you can link would be appreciated. I need to be factual and polite as my children may end up going to that school or I, working in education, may end up there professional capacity.
I'd like to be anonymous to be completely honest but don't know whether that would make complaining pointless.

www.transgendertrend.com/product/equality-law-and-statutory-schools-guidance/

Schools must comply with School Premises (England) Regulations (2012). Department for Education guidance is clear on this:
DfE Advice on standards for school premises (2015)
ISS Regulation 23A — (1) Subject to sub-paragraph (2), the standard in this paragraph is met if the proprietor ensures that— a) suitable toilet and washing facilities are provided for the sole use of pupils; b) separate toilet facilities for boys and girls aged 8 years or over are
3.20 The way in which school facilities are provided can lead to discrimination. Example: A school fails to provide appropriate changing facilities for a transsexual pupil and insists that the pupil uses the boys’ changing room even though she is now living as a girl. This could be indirect gender reassignment discrimination unless it can be objectively justified. A suitable
alternative might be to allow the pupil to use private changing facilities, such as the staff changing room or another suitable space.
3

Guide to Equality Law and Statutory Schools Guidance transgendertrend.com
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; and c) suitable changing accommodation and showers are provided for pupils aged 11 years or over at the start of the school year who receive physical education.
SPRs Regulation 4 — (1) Subject to paragraph (3), suitable toilet and washing facilities must be provided for the sole use of pupils. (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.

assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment data/file/410294/Adviceonstandardsforschoolpremises.

safeschoolsallianceuk.net/wp-content/uploads/2019/08/singlesextoiletsfactsheet.pdf

The above might help.

There’s further information about the building regulations act and numbers of each toilets, and how that interacts with the equality act. As in they can’t just turn the girls into mixed sex toilets. In addition to ignoring the laws detailed in the above it would also be sex discrimination, because now girls have way less toilets in comparison to boys. I’ve seen links posted on her to that but I’m not sure exactly where so hopefully someone will come along to post them.

safeschoolsallianceuk.net/2021/10/23/write-to-the-ehrc-you-can-make-a-difference/

You also might want to follow the above request from ehrc asking for people’s experience of toilet facilities in schools. It doesn’t have to be schools you teach at/kids go to, just any you are aware don’t follow the guidelines/laws (I did it for secondary schools we visited and saw mixed sex toilets/the schools policy made it obvious they were mixed sex).

You obviously will know the safeguarding risks because of your background, always useful to refer to safeguarding as I’m sure you’d know.

You also can let ssa know directly if you want them to report the school to dfe & ofsted. I don’t know exactly their criteria for this, but one secondary we visited had mixed sex toilets with no full doors/wash basins outside, and a lgbt+ policy that said it encouraged children to use the toilet of their preferred gender. We won’t be using this secondary school-for a number of reasons but this included- so with all other school concerns and complaints I have to deal with I didn’t feel I could do this for a school my children won’t attend. So it was recommended here I send them the policy and they said they’d report the school to ofsted & dfe. Which I’m super grateful for because my dc friends will go there and it’s horrifying to think of the risk they at because of this policy.

Hope that helps or that others can add further resources.

Good luck.

Thank you, that's a lot of information. I'm not a legal mind at all so may have to post my letter here before sending it.
I would like a little more information before I went further tbh, but have no way of knowing how the facility is used on a day to day basis. There was an obvious disparity between the men's facilities and the women's for my purposes, but as the activity had nothing to do with the school I can see me being robbed off by each signposting the other.
Regardless of whether the loos in question were meant to be used by the attendees, both male and female, the loos were not signposted and obviously if they are not supposed to be using the signless toilets/changing rooms that needs to be made more clear as I wasn't the only mum to get it wrong.

May have a few questions once I've reread and digested it all. Thank you.

If it were me writing, my first contact would be a simple “why have the women’s toilets from nearer the sports hall (?) disappeared, leaving fewer toilets for the people (women) who need more provision (they are the majority taking the children to these events, plus in normal circumstances you usually see a queue at the ladies’ but not the men’s, showing that the provision does not give equity of outcome even if the provision is equal) and also need to access it more quickly then men (after childbirth, with age etc).”
Then once you get a reply, you can gauge how technical/legal you need to pursue it.

The erasure of women from public spaces continues.

I think judging by the 'we don't use those toilets' comment, if I bring it up that the close ones were unsigned and the men's signed they will just say that the men's are not supposed to be used by outside agencies either.

It's entirety plausible that this is the case i.e. they only use the ones closest to the cafe because the cafe is open and so will be cleaned.

For me, it's that I think it's a sign that the girls attending the school are disadvantaged, but without knowing why the signage has disappeared or how they are used I can't know for sure they are definitely being discriminated against.

Do you think the men's ones are being used by outside agencies? If so, they need to take off the men's sign off of it, or put the women's sign back up if the other one did used to be a women's toilet.

@EarthSight

Do you think the men's ones are being used by outside agencies? If so, they need to take off the men's sign off of it, or put the women's sign back up if the other one did used to be a women's toilet.

They are definitely being used by the parents taking part in the activity of that makes sense, as they are the more obvious ones near the event and not in any way signposted as out of bounds. But the outside agency are not directing people to it. It's more they find them first and assume.

The real difficulty is the one closer to the activity that used to be women's is a bit of a labyrinth of loos, changing roo.s and showers, so easy to see why they'd point people to the further away bog standard bogs. But that being said, in practice it means the men use the closer ones(which may or may not have showers etc) and the women either ask(me) get confused and use the non sign ones(another mum witnessed doing this, possibly one that knew they were single sex previously) or walk further to find the tucked away foyer facilities. Or don't go I suppose.

I think I am going to get DH to scope out the closer men's before I next visit and re-evaluate the women's I was signposted to. I want to know what baby changing (very relevant, considering the nature of the class) and I might watch a few people getting confused to get a scope of the issues.

If your children, you or your school are affected by mixed sex toilets, or proposals for them, Write to the EHRC: you can make a difference