The Association of Educational Psychologists' feedback on DfE guidance “Gender Questioning Children”
Irresponsible Recommendations NOT to follow DfE GQC guidance!
This AEP feedback uses a pastiche of philosophies conveniently packaged together to try to highlight the significance of self-actualisation, individualistic 'recognition' in social pedagogy, trauma-focussed 'victimhood'. These spin-offs from Frankfurt School critical theory play well for an organisation invested as it is in the current 'identity politics' of a so-called social justice lobby. Their feedback to the DfE also represents the uncritical support for ‘gender-affirmation’ using the unaccountable advice of Gender-Ideology charities, which threatens child safe-guarding.
E.G “We recommend schools do not implement this draft, non-statutory guidance. We encourage teachers to stand for inclusion, not exclusion” … from the GI charity ‘Just Like Us’. The implication that gender-critical commentary would ‘stand for exclusion’ is disingenuous or faux-naïf at best.
Similar concerns re: rejection of ‘gender-critical’ input on EP training courses opens up the not insubstantial possibility of the Tavistock GIDS errors being permanently mirrored nationally in EP training, especially with regard to negative outcomes of “social transitioning”.
UK Educational Psychology training and local authority EP services have become something of a “silo” acting against ‘gender-critical’ debate. Educational Psychology training course tutors and senior local authority service managers are briefing against both the new DfE guidance “Gender Questioning Children” and the soon to be finalised Cass Report, despite both highlighting the poor evidence-base for outcomes of ‘gender-affirmative care’.
Association of Educational Psychologists Feedback to DfE on GQC
Introduction
The Association of Educational Psychologists (AEP) is the professional association and trade union for over 3,500 Educational Psychologists (EPs) across the UK. Our members are a highly skilled and essential element of the nation’s workforce, working collaboratively with many other professionals to provide expertise across the education sector as well as offering a psychological understanding of education and child development in other sectors. The AEP seeks to promote the overall wellbeing of all children and young people (CYP), to ensure that their holistic needs are met. Educational Psychologists have particular expertise and statutory responsibilities in regard to special educational needs and disabilities (SEND) as well as a key focus in promoting positive mental health and social wellbeing.
Child Voice
A key aspect of the EP role is gathering children’s views, particularly the voices of marginalised children that often go unheard. We do this because all children have a right to freedom of expression, and for their views to be respected (UNCRC, articles 12 and 13). We open our response to this consultation with this statement because the voices of ‘gender questioning’ children are often lost in discussions about their rights and are nowhere to be found in the draft guidance.
Please see views expressed via the organisation Just Like Us which gives voice to the young people this guidance concerns.
The views of a marginalised population in need of support, care and a sense of belonging are key in meeting their needs and should be central in any guidance about them.
EPs work to ensure that the child’s best interests are at the heart of their work. EPs are well placed to understand how children’s views relate to their experiences and contexts. This means that we should actively listen to the voice of the child and act in ways that they find empowering.
Safeguarding
Safeguarding is a key stated theme of the draft guidance, with one of the five general principles being that ‘schools and colleges have statutory duties to safeguard and promote the welfare of all children’. We welcome and support this aspiration.
However, we do not believe that this draft guidance addresses the serious safeguarding needs of the gender questioning population.
Transgender children and young people are more likely than their cis-gender peers to:
• Experience bullying, discrimination, rejection by peers and violence.
• Develop mental health problems such as depression and anxiety.
• Engage in suicidal behaviours.
• Find school a source of major distress. (Mackie, Lambert, Patlamazoglou, 2021)
In 2017, Stonewall’s research found that, of the 500 secondary age young trans people they surveyed, 45% had attempted suicide and 84% had engaged in self harm (Bradlow et al. 2017). These figures are reiterated in more recent research which highlights that young people identifying as trans were almost four times more likely to report self-harm, over three times more likely to have thought about suicide and 50% more likely to have attempted suicide out of a large sample of LGBT+ adolescents in the UK (Jadva, et al., 2023).
We understand this as a safeguarding crisis.
Addressing this crisis should be based on sound psychological principles such as SelfDetermination Theory, which emphasises the importance of autonomy and control, positive relationships with others and a sense of growing competence as core to happiness and motivation. Relationships should be fostered based on Dan Hughes’ PACE principles of playfulness, acceptance, curiosity and empathy. We also recognise the importance of recognition in social pedagogy as outlined by Axel Honneth and acknowledge the views of many psychologists such as Franz Fanon (1952) who deem misrecognition of marginalised groups as causing serious psychological harm.
As educational psychologists, we follow humanist psychology in showing unconditional positive regard to all children and young people. We recognise that the factors which promote positive mental health and resilience include feeling acknowledged, validated and accepted. Most of our members are supportive of approaches which promote feelings of recognition, affirmation and belonging (e.g. McDermot, et al., 2023). Such approaches are specifically referenced by UNESCO (2018) as leading to a reduction of bullying and violence against trans, non-binary and intersex young people as well as a means for promoting inclusion.
We therefore call upon any guidance to include specific recommendations of adaptations to support the belonging of gender questioning children and to promote their physical and psychological safety and wellbeing, e.g. policies to eliminate violence and bullying and social exclusion. An example of guidance to reference is that proposed by Brighton and Hove.
Any recommendations and future guidance must be evidence based.
Many of our members also do not believe that enshrining rights for gender questioning children opens up a potential safeguarding need for other children in the community. Instead, we would argue that the focus has to be on schools to modernise and make adaptations in a way that makes all pupils safe. This universal offer would include many of the things we already see in modern workplaces: gender neutral toilets, flexibility around clothing, respect for chosen pronouns, gender affirmation by others, training on inclusive practice for staff and so on.
Whilst parental involvement and engagement is ordinarily good practice when developing an understanding of a child’s needs, this should always be balanced with any potential safeguarding risks. Where it is physically and psychologically safe and appropriate, parents should be involved in developing holistic support for their children. However, children have the right to privacy as enshrined in the United Nations Convention on the Rights of the Child and if they do not want to involve their parents, this should be respected. Furthermore, if a child is deemed ‘Gillick Competent’ they have the legal right to exclude their parents from decisions about their care.
The Legal Rights of Children and Young People
We are concerned that this draft guidance may contravene the legal rights of children and young people. Gender reassignment is a protected characteristic under the Equalities Act (2010). Not respecting chosen pronouns or making reasonable adjustments to adapt the school environment actively discriminates against gender questioning children and excludes them.
Identity Exploration
Schools should be engaging with explorations around gender and identity as a perfectly normal aspect of child and adolescent development. School systems should celebrate and reflect the growing autonomy children have around their own gender identities by acknowledging the fluidity and complexity of understandings of sex and gender and the problematic, oversimplified social construction of a gender binary. For example, some research suggests that having the opportunity to explore identity and use one’s own words to define self is a key protective factor for trans young people’s resilience (Singh, Meng & Hansen, 2012).
Educational psychologists are experts in child development and are well placed to support schools, families and children around any transitions, including those for gender questioning children. A minority of our members referenced the Cass Report in saying that social transition is “not a neutral act,” which they felt could lead to negative outcomes. We firmly believe that EPs should be involved in designing the assessment frameworks and subsequent support packages for gender questioning children. EPs draw upon the evidence base and their expertise around systems and child development and develop tailored responses taking into account a child’s experiences, social surroundings, schooling and home situations.
EPs further consider their practice experience and the research evidence base to reflect on how some neurodivergent children and young people understand gender. We consider that understanding a truly neurodiverse perspective requires an acknowledgement that neurodivergent children’s views should be considered as equally valid and that a diagnosis of Autism, for example, should not be used to take their voices or views away from them.
Summary
• Many members raised the many significant potential harms that the guidance in its current form could bring to a vulnerable, marginalised group of children.
• As psychologists, we call for a more robust, evidence based guidance which puts the physical, emotional and social wellbeing of all children, including those who are ‘gender questioning’, trans or non-binary, at its heart.
• This future guidance could include psychological principles such as unconditional positive regard and developing relationships through playfulness, acceptance, curiosity and empathy.
• Additionally, all education staff should access robust, scientifically informed training on appropriate inclusive and wellbeing promoting approaches to supporting gender questioning, trans and non-binary students.
• We also call for the inclusion of EPs in the assessment and development of support for gender questioning children, at an individual and systemic (i.e. education setting) level.
• Future guidance should direct schools to seek appropriate specialist involvement from EPs with regards to gender questioning children experiencing distress and needing support.
Shocking that gender affirming care seems to be put at the top of the list. Ideology has no place in supporting children.