Here you go
Draft Complaint Letter
[Your Full Name]
[Your Address]
[City, Postcode]
[Email Address]
[Phone Number]
[Date]
The Directors / PCC / Relevant Authority
Sunderland Minster
[Full Address of Sunderland Minster – e.g., via their website or public records]
CC:
- Diocese of Durham (Bishop and relevant safeguarding/ legal officers)
- Employers’ Liability and Public Liability Insurers (if known, or request details)
- Health and Safety Executive (HSE)
- Charity Commission (if applicable as a registered charity)
Subject: Formal Complaint – Non-Compliance with Workplace (Health, Safety and Welfare) Regulations 1992, Equality Act 2010 Implications, Safeguarding Failures, and Insurance Invalidity at Sunderland Minster
Dear Sir/Madam,
I am writing to formally complain about Sunderland Minster’s public position and practices regarding single-sex toilets and related policies, which appear to place the organisation, its directors/PCC members, staff, volunteers, and the wider Diocese in breach of legal obligations.
1. Breach of Workplace (Health, Safety and Welfare) Regulations 1992
Following the High Court judgment in
Good Law Project v EHRC (and related clarification of the law post-
For Women Scotland), it is clear that Regulation 20 of the 1992 Workplace Regulations requires suitable and sufficient sanitary conveniences, with separate rooms for men and women (based on
biological sex), unless each convenience is in a separate lockable room for single occupancy.2327
Sunderland Minster has publicly posted a notice acknowledging a breach of these regulations by failing to provide single-sex toilets based on biological sex. You have also publicly stated your intention to continue permitting biological males (trans women) to use female facilities. This directly contravenes the requirement for single-sex provision “for reasons of conventional decency” and privacy.2
2. Public Intention to Breach the Law and Insurance Implications
Your organisation is on record stating that it intends to continue this policy despite the clarified legal position. A deliberate and public intention to breach statutory health and safety regulations is likely to invalidate both
employers’ liability insurance and
public liability insurance. This exposes directors/PCC members personally, as well as the organisation, to significant financial and legal risk in the event of any incident, claim, or regulatory action.
I request full details of your current insurance policies and confirmation that insurers have been notified of this stated position.
3. Website and Policy Non-Compliance
Your website and public materials appear to lack appropriate, up-to-date policies compliant with current equality and health & safety law. In particular, there is a concerning absence of clear, lawful safeguarding policies that reflect the legal position on single-sex spaces. This falls short of expected standards for an organisation open to the public, including families and children.
4. Safeguarding and Child Protection Concerns
Your public statement invites teenage girls (and other women) who feel uncomfortable to ask clergy or volunteers (unknown adults) to accompany them to the toilets and wait outside the stall. This involves unknown or minimally vetted adults being alone with or in close proximity to children in a state of undress in a supervisory capacity.2
This raises serious safeguarding issues, including:
- Potential lack of DBS checks, specific training, or insurance for such supervision.
- Risk of distress, inappropriate interaction, or safeguarding breaches.
- Failure to prioritise the dignity, privacy, and safety of girls and women.
Such practices have direct implications for the personal liability of directors/PCC members (“Friends of the Sunderland Minster” or equivalent) and potential reputational and legal exposure for the Diocese of Durham.
I urge you to immediately:
- Revert to full compliance with the 1992 Workplace Regulations by providing single-sex toilet facilities based on biological sex (or adequate single-occupancy alternatives).
- Remove or correct the non-compliant notice and public statements.
- Review and update all policies, including safeguarding, equality, and health & safety, to ensure legal compliance.
- Notify insurers and conduct a full risk assessment.
- Engage with the Diocese for oversight and support.
I reserve the right to escalate this matter to the HSE, Charity Commission, relevant regulators, and/or pursue other legal remedies if not addressed promptly.
I look forward to your full response within 14 days, including details of steps taken to achieve compliance.
Yours faithfully,
[Your Full Name]
Send to the people linked above including Directors and Diocese emails. Also safeguarding lead.
- Customise with your details and any specific evidence (e.g., screenshots of the notice/Facebook post).
- Consider sending via recorded delivery/email with read receipts.
- If you are a regular attendee, parent, or local resident, mention your legitimate interest.
Is there is WRN group or similar who could coordinate?