Charity Commission complaint regarding the Gender Identity Research and Education Society (GIRES)
CRM:0049403
2nd January 2025
Dear Charity Commission,
Complaint regarding the Gender Identity Research and Education Society (GIRES (1068137).
Point of complaint:
GIRES is an education charity, yet is not following charity law to provide information that is accurate, evidence based and balanced.
I would consider the following as the successful outcome of my complaint:
The Charity Commission remove the charitable status of GIRES, until it covers research into matters of cross-sex identification in an accurate, balanced and evidence-based way.
GIRES continue to promote claims regarding puberty blockers that are not based in evidence
I opened a complaint with the Charity Commission on the 24th April 2024 (CRM:0049558),1 that GIRES, and other charities, continue to promote puberty blockers, despite the conclusion of the Cass Review:
“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
I received the response from the Charity Commission on the 9th July 2024 that:
“It is not for the Commission to determine whether information issued and published by charities is correct. We have decided that on this occasion the best way forward is to provide the trustees with regulatory advice and guidance about ensuring that they have regard to the findings, conclusions and recommendations of the Cass Review and ensuring that they have reviewed their charity’s literature, website and guidance in light of them.”
However, as of January 2025, GIRES continue to make claims regarding puberty blockers that are without evidence, and have not reviewed their literature in light of the Cass Review e.g.:
“Gender dysphoria in children & young people: Gender discomfort may emerge in early childhood or adolescence and continue into adulthood. Stress is increased during puberty with the development of unwanted changes to the body. Some young people access safe, reversible intervention to interrupt puberty (hormone blockers), allowing more time to confirm how they wish to live in their adult lives.”3
And in new material:
“For young people, this should include puberty blockers which simply block hormone generation leading to puberty for a period of 3 months. This provides an opportunity for exploration in a safe way with the young person.”4
GIRES are not following charity law to provide information that is accurate, evidence based and balanced.
I opened a complaint with the Charity Commission (CRM:0467599) on the 23rd March 2022,5 which showed that what GIRES, and other charities, were teaching with regards to cross-sex identification was not evidence-based, something which remains the case today. This included the repeated false assertion that matters of cross-sex identification have nothing to do with sexual orientation.
The Charity Commission came to the following conclusion (paragraph 187 CRM:0467599):
“The Commission has considered the issues raised and our assessment is that we lack the expertise and knowledge of complicated psychological and medical issues connected to gender identities to be able to form a definitive view on the issues you have raised. We note the evidence you have put forward from various professionals but it seems to the Commission that the issues raised are matters that are unsettled and are subject to debate, interpretation and disagreement.”
I raised the point in paragraph 197 that it was illogical for the Commission to come to this conclusion, and still choose inaction:
“If the Commission can see, from my evidence, that the assertion that there is “no link between gender identity (disorder) and sexual orientation”, is unsettled, subject to debate interpretation and disagreement” then why do no charities mention this? … Why are charities presenting their assertion uncritically as a fact to the public, particularly to children?”
The Charity Commission’s decision to take no action further contradicts the Charity Commission’s later statement emphasising charity law requirements for education charities:
“Charity law requires that the information provided by education charities, or those with an object to advance education, is accurate, evidence based and balanced.”6
As my complaint CRM:0467599 showed in 2022, the information that GIRES was providing, and continues to provide, regarding matters of cross-sex identification was not accurate nor evidence-based. The Charity Commission certainly knew the information that GIRES was providing was not balanced, as it reflected none of the “debate, interpretation and disagreement” that the Charity Commission said existed.
Failure of trustee to investigate complaint
Cat Burton, below, was the trustee (and chair of trustees) who closed my complaint (paragraph 49 CRM:0467599) after I was at first promised a “full and comprehensive response”.
I note that Cat Burton’s experience of difficulties regarding cross-sex identification appears to mirror my own (paragraph 2 onwards CRM:0467599) starting at the onset of puberty:
“It was daunting contemplating transitioning, I’d buried all my gender issues when I was 14,” she said. “I’d locked them away in a little box in the back of my brain and I would never open this box but something opened it quite late in life - and I realised you only live once.”
Accordingly, I believe that what we feel regarding cross-sex identification is likely the same and connected to autogynephilia.
I covered the political reasons why some transsexuals are interested in suppressing research into autogynephilia in paragraph 16 onwards of my complaint CRM:0467599, beginning “There is historical precedent of activists trying to suppress the research that gender identity disorders are connected to sexual orientation in males”.
In my opinion, Burton is a continuation in the history of activists who want to suppress research that shows that cross-sex identification in males is connected to autogynephilia, and it was for this reason that my complaint was closed.
The “feminine essence narrative” in place of accurate, evidence-based and balanced information
In addition to political reasons for suppressing research into cross-sex identification, the autogynephilic transsexual and researcher Anne Lawrence notes the personal psychological reason for suppressing or denying research regarding autogynephilia:
“The theory of autogynephilic transsexualism forces us to confront the fact that both our essential natures and our motives seem to directly contradict our desired ends. We autogynephilic transsexuals want to be women; but the theory tells us that we are not women and that we don’t even resemble women—not in the least. We would like to believe that our desire to be women springs from our need to express some internal feminine essence; but the theory tells us that we have no internal feminine essence and that our desire to be women actually springs from our paraphilic male sexuality”.7
The “feminine essence” that Lawrence refers to, comes from what is known in research as the “feminine essence narrative”,8 which sees transsexuals being “in some literal sense and not just in a figurative sense, women inside men’s bodies” (transsexuals being historically mostly male-to-female). This narrative is not evidence-based but rather a belief: “essence” could be replaced with “soul”. It is, however, as Lawrence mentions, a narrative that is appealing to males who are in denial regarding autogynephilia.
GIRES’s apparent belief in the “feminine essence narrative” construed as “gender identity” can arguably be seen from GIRES’s NHS training material advocating for puberty blockers (below): “This medication [puberty blockers] allows those who do not wish to pursue this pathway, to discontinue this medication. This may be because they come to understand their discomfort to be related to sexual orientation, rather than gender identity.”
Here, GIRES suggests that it is possible that one can have knowledge of one’s “gender identity” or “essence” is of the opposite sex. This is not based in evidence.
The DSM-5 says that identifying as a different gender (which it sees as the categories of man/woman) is related to atypical sexuality: namely homosexuality or autogynephilia.9 There is no third reason, knowledge of one’s “gender identity”, as GIRES’s content suggests.
GIRES therefore appears to have taken the phrase “gender identity” out of the DSM-5 and reformulated it into the “feminine essence narrative”. This has resulted in unsafe advocacy that is not based in evidence, as can be seen in GIRES’s NHS training material regarding puberty blockers.
In reality, and as conveyed by the DSM-5, there is no knowable “gender identity” that can determine whether or not one is “truly” the opposite sex. There is only the decision to undergo supposed medical treatments, which children cannot consent to, and is a decision that can go badly wrong, even for adults.10
“At first when I was little, I thought I was just a tomboy, but then on YouTube there was videos — there was a video and it said transgender. I looked at it and I realised I’ve always really wanted to be a boy, but I just couldn’t really say it… I’m hoping for the blockers to make the whole package, make me happy, and that will be that, I’ll be perfect.”
GIRES NHS Training video. Co-produced by NHS Surrey and Borders Partnership. Funded by NHS Health Education Kent Surrey and Sussex.
History of autogynephilic activists advocating for unsafe supposed medical treatments
If one is an autogynephilic man, who experiences an identity disorder, and comes to falsely believe that one’s cross-sex identification is explained by being in some way literally the opposite sex, e.g. one has a “feminine essence” or “female gender identity”, then one might be led to believe this can be the basis of prescribing supposed medical treatments, even to children.
If a charity is comprised of such autogynephilic men, then it may similarly campaign to give children these supposed medical treatments, under the false belief that it is possible that they, too, have a “gender identity” of the opposite sex.
This is dangerous, as the DSM-5 does not say that it is possible that children can have a “gender identity” of the opposite sex, and that children with “early-onset gender dysphoria” will in most cases desist with cross-sex identification at the onset of puberty, where they will have a high likelihood of being homosexual.11
It is my opinion that GIRES has characteristics of such a charity mentioned in paragraph 31, and that GIRES advocating for puberty blockers for children can be placed in the context of the long recognised problem of activists with a history of late-onset gender dysphoria, i.e. autogynephilia, advocating for unsafe medical treatments, including for children:
“Yet a number of vocal transgender activists who have histories typical of autogynephilic gender dysphorics do not hesitate to pressure parents, legislators, and clinicians for acquiescence, laws, and therapies that do not distinguish among types of gender dysphoric children. Moreover, they not infrequently claim inside knowledge based on their own experiences. Yet their experiences are irrelevant to the two types of gender dysphoria that they don’t have. And even with respect to autogynephilia, these transgender activists are nearly all in denial.”12
I furthermore see that the NHS’s apparent uncritical acceptance of GIRES’s advice, which is arguably not based in research, but rather the “feminine essence narrative” construed as “gender identity”, has resulted in their “gender identity” services harming children. I see the apparent belief in this false narrative as the root cause as to why the Tavistock Clinic had to be shut down as unsafe.13
Failure of the Charity Commission
I raised the risks that arise from not differentiating the different types of gender dysphoria with the Charity Commission in paragraph 18 onwards of my complaint CRM:0467599, however this risk was ignored. I again tried to raise this risk again in paragraph 202 in my appeal (CRM:0467599) however this was similarly ignored.
Had the Charity Commission asked GIRES in 2022 to abide by education charity law, and had the Charity Commission also in 2022 followed its Regulatory and Risk Framework, then perhaps it would not have taken until 2024 and the Cass Review to find that charities like GIRES were promoting puberty blocking treatments with weak evidence and unclear rationale.
However it is remarkable, that even with a clear statement from the NHS regarding the lack of evidence and rationale for prescribing children puberty blockers, the Charity Commission continue to allow GIRES, and others, to make false claims regarding puberty blockers, despite it now having received multiple complaints.
It is worth saying, that it is not that the public, including me, who are wrong in their concerns. It is rather the Charity Commission that has a history of failure in addressing legitimate concerns.
In 2014, the Public Accounts Committee found that the Charity Commission was not fit for purpose:
“The Commission too willingly accepts what charities tell it when it is investigating alleged abuses. It too often fails to verify or challenge the claims made. Some of the most serious cases of abuse have not been properly investigated. It has been too slow in removing or suspending trustees and in pursuing investigations promptly.”14
The Charity Commission further has a long history of allowing false medical claims to be made by charities:
“HealthSense maintains pressure on the Charity Commission regarding charities that mislead vulnerable people about health and disease… This is a small amount of progress from an effort that so far has taken over 10 years. For most of that time the Charity Commission has brushed aside complaints, claiming that they are not qualified to make judgments about evidence in health care... Several charities which had received “regulatory advice” from the Commission continued to make highly misleading claims at least a year later.”15
My most recent complaint to the Charity Commission regarding Fumble (CRM:0049126) is representative of the way in which complaints are “brushed aside”, despite obvious risks remaining to vulnerable supposed beneficiaries.16
It is clear that given the deficiencies of the Charity Commission, that the stage has been set for some time for the harm that is today being caused by charities making false statements regarding the nature of cross-sex identification, and it is the most vulnerable in society who are paying the price.
These are children, mostly girls, (below) who have come to believe they have a “mismatched” “gender identity”. Some of these children and young people have then gone on to be harmed by puberty blockers, cross-sex hormones and medical procedures, prescribed by clinicians who apparently also share this false belief.
Men Trapped in Men’s Bodies: Narratives of Autoynephilic Transsexualism, Lawrence, A. (Springer, 2013) p. 203. https://annelawrence.com/book/
Blanchard R. “Deconstructing the Feminine Essence Narrative”. Archives of Sexual Behavior 2008;37:434-438
Most recently covered with the Charity Commission in paragraph 33 of my complaint regarding Fumble. (CRM:0049126) https://transpolicy.substack.com/p/complaint-to-the-charity-commission
“Ms Kane, who was born male, had surgery in 1997 to become Samantha, before having it reversed and taking on the identity of Charles Kane in 2004.” “Trans laird sues NHS for refusing to carry out third sex change surgery” Telegraph 18th December 2024.
DSM-5 p. 455
Michael Bailey J and Blanchard R. “Gender dysphoria is not one thing.” 4th Wave Now https://4thwavenow.com/2017/12/07/gender-dysphoria-is-not-one-thing/
Many clinicians from the former “Gender Identity Development Service” still seem to believe in the “feminine essence” “gender identity” narrative, as evidenced by this open letter: “Gender identity and sexuality are separate and differentiated aspects of identity that emerge and coalesce at different points across identity development.” https://tavistockandportman.nhs.uk/news/gender-identity-development-experts-publish-open-letter-with-future-service-development-recommendations/
Les Rose, “Abusing the Public’s Trust in Charities” https://www.healthsense-uk.org/publications/newsletter/newsletter-123/362-123-rose.html
The Charity Commission took no action after Fumble silently deleted its link recommending children and young people to GenderGP. If the Charity Commission had followed its Regulatory and Risk Framework, it would have asked Fumble to issue a statement recommending that children and young people who had previously accessed the GenderGP service it recommended, should stop doing so, as it would leave them at risk of receiving a criminal conviction, and at risk of receiving medical treatments which have unclear rationale and weak evidence for their use. This is not to mention the fact that Fumble’s content encourages children and young people to misdiagnose themselves with gender dysphoria in the first instance.