Dear Charity Commission,
I would like to make the complaint that Action for Children (1097940) is not fulfilling its charitable objects:
“the charity works for the public benefit having as its objects the promotion of the upbringing and care of children and young people in need from all backgrounds, cultures, and faiths or none in particular by: 1. promoting their better care and safeguarding them; 2. providing assistance to them and their families and carers; 3. promoting their health; 4. promoting their education and establishment in life.”
I would consider a successful outcome of my complaint if Action for Children remove their page “Supporting your child with their gender identity” as it presents a misleading narrative regarding this issue, and, despite the Cass Review, continues to signpost children and parents to Stonewall, a charity that continues to promote puberty blockers to children:
Misleading narrative
Action for Children are presenting a misleading narrative of matters of cross-sex identification, they say “Gender dysphoria is when someone feels there is a mismatch between their biological sex and their gender identity.”1
This narrative appears to suggest that transsexuals are in “some literal sense and not just in a figurative sense, women inside men’s bodies” (transsexuals being historically mostly male-to-female), which is also known as the “feminine essence narrative”.2 The narrative does not represent what is in the DSM-5.
Furthermore, the Department of Education have also recognised this narrative as being inappropriate to teach to children in schools: “Schools should not teach about the broader concept of gender identity. Gender identity is a highly contested and complex subject.”3
When one looks at the Diagnostic and Statistical Manual of Mental Illnesses 5th Edition (DSM-5), where “gender dysphoria” and “gender identity” are defined, one can see the actual causes behind “gender dysphoria”, which are connected to atypical sexuality or sexual orientation – not a “mismatched” “essence” or “gender identity”.
In the DSM-5, gender dysphoria amongst pre-pubertal children, both in boys and girls, is associated with later being attracted to the same sex: “For both natal male and female children showing persistence, almost all are sexually attracted to individuals of their natal sex.” The DSM-5 calls this pathway “early-onset” gender dysphoria.4
There is another pathway, which the DSM-5 calls “late-onset” gender dysphoria, which in males “occurs around puberty or in later life”.5
Like early-onset gender dysphoria, this is also connected to sexuality, as individuals, “frequently engage in transvestic behavior with sexual excitement”,6 however unlike the early-onset group, are otherwise heterosexual, “A substantial percentage of adult males with late-onset gender dysphoria cohabit with or are married to natal females. After gender transition, many self-identify as lesbian”.7
Furthermore, the DSM-5 says in men with transvestic disorder a phenomenon called “autogynephilia”, which the DSM-5 defines as the “Sexual arousal of a natal male associated with the idea or image of being a woman”,8 increases the likelihood of of gender dysphoria
Ray Blanchard, who served on the DSM-4 gender identity disorder subcommittee, and J. Michael Bailey, both pre-eminent researchers on this subject, say:
“Parents of gender dysphoric children should know which type of gender dysphoria their child has. To do so it is necessary to learn about all three of the most common types. That is, in order to understand why one’s child is Type X, it is necessary to know why s/he is not Type Y or Type Z. This is not simply academic. There are essential differences between the different types of gender dysphoria.”
Action for Children’s content on “gender identity” does not distinguish between the pathways of gender dysphoria in the DSM-5, but rather construes “gender identity” in terms of the “feminine essence narrative”. Therefore the advice it gives poses a risk to parents of children regarding this issue.
For example, parents of a remarkably feminine boy who identifies as a girl, i.e. what the DSM-5 calls early-onset gender dysphoria, should know that they can discount the experience of adolescent boys and men who are experiencing late-onset, likely autogynephilic, gender dysphoria.
In this case of a remarkably feminine boy, the best course of action is what the DSM-5 calls “watchful waiting”,9 as their gender dysphoria is likely to resolve at the onset of puberty, when they are also likely to be homosexual.
If parents confuse their son’s early-onset gender dysphoria with late-onset gender dysphoria, they will be left with a false impression that their son’s gender dysphoria is unlikely to resolve, misleading them to consider inappropriate medical intervention, or social transition.
Action for Children’s incomplete and misleading narrative regarding issues of cross-sex identification therefore poses a risk of “serious harm to the people the charity helps or other people who come into contact with the charity through its work”, namely children experiencing distress regarding their sex, as their parents are not being provided with all the information required in order to make the best decisions on their behalf.
Social contagion
I raised the subject with Action for Children that teaching children indiscriminately the misleading narrative that they all have a “gender identity”, who for some can be “mismatched”, is causing a social contagion, primarily amongst girls and young women (illustrated below).10
In past generations, this cohort would not have been affected by this issue, being usually neither homosexual nor autogynephilic (autogynephilia not being recognised in females). The gender dysphoria in this cohort is rather an iatrogenic social contagion, caused by charities such as Action for Children, teaching children that they can have a “mismatched” “gender identity”.
Ray Blanchard and J. Michael Bailey call this social contagion amongst girls and young women “rapid onset gender dysphoria” (after research by Lisa Littman):
“To us, the most tragic group, along with their families, includes those who have acquired rapid-onset gender dysphoria. That condition appears to be the tragic interaction of the current transgender zeitgeist (“It’s everywhere, and it’s great!”) and social media with the vulnerability of troubled adolescents, especially adolescent girls. They are at risk for unnecessary, disfiguring, and unhealthy medical interventions.”11
Action for Children’s misleading “mismatched” “gender identity” narrative poses a risk of “serious harm to the people the charity helps or other people who come into contact with the charity through its work”, as girls experiencing distress regarding their sex, and their parents, are being misled into thinking that they could have a “mismatched” “gender identity”, despite not fulfilling the actual diagnostic pathways, which Action for Children do not cover.
Signposting parents and children to puberty blockers
One supposed medical intervention for children experiencing distress regarding their sex are puberty blockers. The Cass Review found no evidence for this treatment:
“The rationale for early puberty suppression remains unclear, with weak evidence regarding the impact on gender dysphoria, mental or psychosocial health. The effect on cognitive and psychosexual development remains unknown.”12
Despite this, Action for Children continue to support parents and children to Stonewall, who make the following claim regarding puberty blockers, without evidence:
“...puberty blockers. This non-permanent treatment gives young people time and space to work out what is right for them, without the distress of the heightened dysphoria that puberty can bring on. It can also help those who know for sure that they do not want to experience the puberty that will occur for them without intervention.”13
Signposting parents and children towards an organisation that promotes a supposed medical treatment without evidence poses a risk of “serious harm to the people the charity helps or other people who come into contact with the charity through its work”.
Despite Action for Children saying that this is a “complex and multi-faceted debate”, they decided to not spend any of their £149 million income (2023) on examining any of the points I raise above, by entering my complaint into their 2nd stage review process.
7th May 2024
Dear Action for Children,
I would like to make a complaint regarding your page on "How can I support my child with their gender identity?"
Your page links to GIDS, which was a service that was closed as it was not considered safe.
Your page links to Stonewall, which says that puberty blockers are a "non-permanent treatment [that] gives young people time and space to work out what is right for them, without the distress of the heightened dysphoria that puberty can bring on." [1]
The Cass Review recently showed this as being unsupported by evidence:
"The rationale for early puberty suppression remains unclear, with weak evidence regarding the impact on gender dysphoria, mental or psychosocial health. The effect on cognitive and psychosexual development remains unknown." [2]
More widely, I don't think what is being repeated and taught to parents about this issue is true. I know this, as I myself experienced what is today called "gender dysphoria" as a teenage boy growing up in the 1990s. I have documented the research around this issue, and the likelihood that teaching children that it is possible to have a "mismatch between [...] biological sex and their gender identity" is causing a social contagion, primarily amongst girls: https://transpolicy.substack.com/p/trans-memo
I am aware that the concerns that I am raising are indicative of quite a serious problem.
[1] https://www.stonewall.org.uk/the-truth-about-trans
[2] https://cass.independent-review.uk/home/publications/final-report/
Yours,
Orlando
9th May 2024
Good afternoon,
Thank you for your email.
We appreciate all feedback and our team will investigate further, we have directed your enquiry to our team who deals with the website and it's contents, one of my colleagues will be in touch as soon as possible.
Have a nice day.
Kind regards,
[...]
Customer Support Officer
[…]
9th May 2024
Dear Action for Children,
Thank you for your reply.
Please feel to email me if you had any queries regarding the issues I have raised.
Yours,
Orlando
Dear Action for Children,
I would like to let you know that your content regarding "gender identity" [1] is now prohibited from being taught to children in schools. [2]
I therefore continue to see that you should remove this content.
[2] https://www.bbc.co.uk/news/education-69017920
Yours,
Orlando
17th May 2024
Dear Action for Children,
Please could I ask for an update regarding my complaint.
I would additionally like to raise a complaint regarding your resource "Everyone's welcome". [1]
It notably does not follow the draft Department of Education guidelines. [2]
Point 45 of the draft guidelines says "Schools should not teach about the broader concept of gender identity. Gender identity is a highly contested and complex subject." Your content presents children with the idea of "Gender identity" as "A person’s internal, deeply held sense of their own gender." "Gender identity" is a term created by Stoller in the 1960s, to describe the developmental stage where children recognise what sex they are. "Gender identity" used to describe a "internal, deeply held sense of gender" is a contested belief that you are teaching to children as a fact. [3]
Your definition of "Trans" as "An umbrella term to describe people whose gender is not the same as, or does not sit comfortably with, the sex they were registered at birth" is a contested theory. People like Debbie Hayton, for example, write about autogynephilia as being the cause of their cross-sex identification. [4]
Point 46 of the draft guidelines says "Material suggesting that someone’s gender is determined by their interests or clothing choices should not be used as it risks leading pupils who do not comply with sex stereotypes to question their gender when they might not have done so otherwise." Your content suggests that choosing what clothing one wears implicates a person's "gender identity" and therefore, their "gender": "A trans young person may change how they dress or the uniform they wear to school to reflect their gender identity".
Point 46 of the draft guidelines says that it is not appropriate to teach children that "gender is a spectrum". Your content says that some people "may also identify as a mix of man and woman".
I don't see any of your content as a benefit to children. The concepts of "non-binary" "gender identity" "gender fluidity" "preferred pronouns" are concepts that have been created by adults, and are cynically being targeting at children, as children are not able to critically challenge these concepts.
I, myself, experienced issues with cross-sex identification as a teenage boy growing up in the 1990s, so I know the research regarding this topic, and do not consider any of your content as the truth about this matter. I again ask you to read my memo: https://transpolicy.substack.com/p/trans-memo and consider the fact that what you are teaching is causing harm to children, particularly to a cohort of girls.
[1] https://media.actionforchildren.org.uk/documents/1166_Gender_Identity_Guide_2022_v2.pdf
[3] “core gender identity, the ‘sense of knowing to which sex one belongs,’ is universal. It is not, however, gender identity as it figures in the received account of being ‘trans’ or ‘cis’: that kind of gender identity is a myth.” Alex Byrne "Trouble with Gender".
[4] https://debbiehayton.com/2022/05/16/my-autogynephilia-story/
Yours,
Orlando
4th June 2024
Dear Action for Children,
I don't think that you have considered anything that I have said, in my complaint to you on the 7th May:
More widely, I don't think what is being repeated and taught to parents about this issue is true. I know this, as I myself experienced what is today called "gender dysphoria" as a teenage boy growing up in the 1990s. I have documented the research around this issue, and the likelihood that teaching children that it is possible to have a "mismatch between [...] biological sex and their gender identity" is causing a social contagion, primarily amongst girls:
https://transpolicy.substack.com/p/trans-memo
It appears that instead, Action for Children have doubled-down on teaching children and parents that matters of cross-sex identification are caused by a "gender identity that’s different to when they were born":
Please could you read this short article which is written by Dr. Blanchard and Prof. Bailey regarding the actual truth behind this issue: https://4thwavenow.com/2017/12/07/gender-dysphoria-is-not-one-thing/
You write that there are an "increasing number of children and young people" facing difficulties around this issue. I think that this obscures the fact that these are disproportionately girls: https://transpolicy.substack.com/p/trans-memo suggesting a social contagion.
You are harming children by teaching them it is possible to have a "gender identity" that "differs" or "does not sit comfortably" with one's "sex assigned at birth". It is not the truth about this matter, and is causing a social contagion amongst girls.
Yours,
Orlando
5th June 2024
Hi Orlando,
I hope you are well.
Thanks you for your email and apologies for the delay in getting back to you.
We have removed the outdated reference to GIDS from our Parent Talk page and we appreciate you bringing this to our attention.
We are currently reviewing the Gender Identity content we have on our platforms.
Kind regards
[...]
Customer Support Officer
5th June 2024
Dear Action for Children,
Thank you for your email.
Please could you keep the following articles in mind when considering your review of content regarding "gender identity":
Prof. Bailey, Dr. Blanchard:
https://4thwavenow.com/2017/12/07/gender-dysphoria-is-not-one-thing/
Trans memo, which covers illustrates and covers the history of the above research and illustrates the current social contagion amongst girls:
https://transpolicy.substack.com/p/trans-memo
Yours,
Orlando
17th June 2024
Dear Orlando,
Thank you for your recent communication. An Action for Children Operational Director has reviewed your complaint and our response and has come to the conclusion that we will not be progressing to stage 2 of our complaint’s procedure. This is because we have addressed your concerns regarding the link on our website, by acting accordingly and removing this, and we would like to thank you again for drawing this to our attention.
The other points that you raise are part of a complex and multi-faceted debate involving a range of perspectives and strongly held beliefs. Our position remains that we will continue to provide families with the advice, guidance and information that they seek, and has been deemed appropriate to support them.
Kind regards,
[...]
Customer Support Officer
Blanchard R. Deconstructing the Feminine Essence Narrative. Archives of Sexual Behavior 2008;37:434-438 Covered further here: https://www.healthsense-uk.org/publications/newsletter/newsletter-127/420-127-orlando.html
DSM-5 p. 455
DSM-5 p. 456
DSM-5 p. 456
DSM-5 p. 456
DSM-5 p. 818
DSM-5 p. 455
Source: segm.org
“Gender dysphoria is not one thing” Bailey, J. M., Ph.D and Blanchard, R., Ph.D., 4th Wave Now. https://4thwavenow.com/2017/12/07/gender-dysphoria-is-not-one-thing/
https://www.stonewall.org.uk/the-truth-about-trans (accessed 15th August 2024)