Sent to First Minister Mark Drakeford on behalf of Merched Cymru and Women’s Rights Network (Wales)
Dear First Minister
We are writing to express our serious concerns regarding Welsh Government’s intention to promote a ban on ‘conversion therapy’ in relation to gender identity.
While we wholeheartedly endorse the UK government’s proposed legislation to ban conversion therapy for sexual orientation, the addition of gender identity (an undefined and unverifiable concept) will not protect children and young people experiencing gender-related distress, and could expose them to serious harm.
The Welsh Government’s precipitous decision to include gender identity in the ban, appears to ignore the recent findings of the Cass Interim Report – an independent, authoritative, and evidence-based review of gender identity services for children and young people. It also ignores voices from the LGB community, and from Tavistock staff, who are concerned that increasing numbers of lesbian and gay young people are identifying as trans due to homophobia, including internalized homophobia.
The Cass Review: Interim Report states that ‘children and young people with gender incongruence or dysphoria must receive the same standards of clinical care, assessment and treatment as every other child or young person accessing health services.’ Currently, this is not the case.
The Interim Report raises a number of concerns in this regard:
- In relation to diagnosis and treatment, Cass noted ‘a lack of consensus and open discussion about the nature of gender dysphoria and therefore about the appropriate clinical response.’
- The poor quality or non-existence of research and lack of follow up data regarding the current treatment of gender-distressed children.
- The pressure that clinical staff are under to adopt an ideologically-led ‘unquestioning affirmative approach’ at odds with the standard process of clinical assessment and diagnosis that is followed in all similar contexts.
The standard process referred to in the Report is holistic, therapeutic care, or what the Society for Evidence-based Gender Medicine call ‘ethical care’. As Cass states, clinical staff are already under pressure to affirm rather than explore, and to accept the young persons’ self diagnosis of trans identity without considering the broader context. There is increasing evidence, for example, that gender-distressed young people are disproportionately neuro-diverse – a fact noted, but not followed up, by the Tavistock Clinic; that many have suffered sexual or other traumas, or have co-morbidities such as anorexia, bulimia, or self-harming behaviours.
The need for an ethical approach to caring for gender-distressed young people is all the more pressing given the serious risks associated with the current medical pathway. Potential side effects (of puberty blockers, cross-sex hormones and surgery), include sterility, loss of bone density, loss of sexual function, and vaginal atrophy. The risks are considerable and yet the efficacy of these radical treatments remains unproven, as highlighted in a NICE report in to the evidence-base for the use of puberty blockers and cross-sex hormones.
As Cass reveals, there is already a climate of fear among clinicians, a concern that anything other than affirmation is unacceptable. A ban on ‘conversion therapy’ for gender-distressed children and young people would potentially criminalise clinicians (as well as parents and teachers) who wish to adopt the holistic ‘watchful waiting’ approach used in all similar contexts. Evidence from countries where a ban is in place for gender identity affirm that this concern is well-founded.
The Equality and Human Rights Commission has also raised concerns about the lack of a sound evidence base for the ban. They agree with Cass that it risked preventing ‘legitimate and appropriate counselling, therapy or support which enables a person to explore their sexual orientation or gender dysphoria’ and ‘criminalising mainstream religious practice such as preaching, teaching and praying about sexual ethics’.
In this regard alone, the Welsh Government should at least wait for the final Cass Report to be published. Our children and young people are surely owed that level of care as a bare minimum.
In addition, the LGB Alliance (and LGB Alliance Cymru) and Lesbian Labour have both spoken out against the inclusion of gender identity in the conversion therapy ban. They point out that sexual orientation and gender identity are two distinct categories which need to be considered separately and that ‘affirming a child as trans when they might otherwise grow up as lesbian, gay or bisexual, is a form of conversion therapy’, of ‘transing away the gay’. If not medicalised, current research suggests that roughly 80% of children and young people grow out of their sense of gender incongruence; a significant number go on to realise that they are LGB. These voices, and the experiences of growing numbers of detransitions, are being ignored by Welsh Government. This is unacceptable.
We call on Welsh Government to wait for the Cass Report to be published, and to take in to account the evidence, expertise and experience of those calling for caution. Those young people struggling with gender distress deserve better than this ideologically-led, evidence-free, political response.
We look forward to your response, and to hearing what steps you and your government intend to take to address the issues raised.
Yours sincerely
Ruth Dineen on behalf of Merched Cymru
Cathy Larkman on behalf of Women’s Rights Network Wales
cc:
Eluned Morgan, Minister for Health and Social Services
Julie Morgan, Deputy Minister for Social Services
Lynne Neagle, Deputy Minister for Mental Health and Wellbeing
Russell George, Shadow Minister for Health
James Evans, Shadow Minister for Mental Health
Gareth Davies, Shadow Minister for Social Services
Judith Paget, NHS Wales Chief Executive
Frank Atherton, Chief Medical Officer Wales
Tracey Cooper, Public Health Wales Chief Executive
Rocio Cifuentes, Children’s Commissioner for Wales
