Charity Commission complaint regarding puberty blockers, Stonewall and GIRES
CRM:0049125
25th January 2025
Complaint regarding misleading claims regarding puberty blockers and Stonewall (1101255) and the Gender Identity Research and Education Society (GIRES) (1068137)
Dear Charity Commission,
The action taken by the Charity Commission in response to my previous complaint regarding this issue CRM:0049558 has been shown to be ineffectual, and charities continue to promote and make misleading claims regarding puberty blockers.
Therefore I would consider a successful outcome of this complaint to be for the Charity Commission to now issue a regulatory alert, warning charities to stop promoting and making misleading claims regarding puberty blockers.
I last complained to you on the 24th April 2024, that what Stonewall and GIRES are saying regarding puberty blockers is unsupported by medical research and conflicts with the findings of the Cass Review (CRM:0049558).
Regarding puberty blockers, the Cass Review concluded: “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.”1
The Charity Commission replied on the 9th July 2024:
“As you may be aware, the Independent Review of Gender Identity Services for Children and Young People (‘The Cass Review’) commissioned by NHS England and NHS Improvement in Autumn 2020 published its final report in April 2024. The Cass Review set out its recommendations on a range of issues which affect children and young people who are questioning their gender identity or experiencing gender dysphoria. This has resulted in changes to NHS guidelines, in particular with regard to the clinical approach to care and support. 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. Please note it is not the Commission’s practice to keep those who raise concerns informed or updated.”
However despite this, five months later, and eight months after my initial complaint, Stonewall continue to state: “... 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.”2
And GIRES continue to state: “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
In October 2024, GIRES issued further unsubstantiated claims regarding puberty blockers:
“Everyone should have access to gender-affirming care (if they want it). 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
In the Charity Commission’s recent email to me on the 10th January 2025,5 the Commission said that it “provided Stonewall Equality Ltd with advice”, which is presumably the advice the Charity Commission issued around July 2024 above. The Charity Commission further said “we will not be taking any further action at this stage”.
This is not acceptable, as it has now been five months since the Charity Commission issued its advice, and yet Stonewall, and GIRES continue to make misleading claims regarding puberty blockers, so have evidently ignored the Charity Commission.
Since my initial complaint in April 2024, successive governments have supported the law banning puberty blockers, and issued guidance which says that puberty blockers, and the international and private suppliers who want to continue to supply them, pose a high and acute risk to the health of children:
“Children aged under 18 obtaining puberty blockers as a treatment for gender incongruence and/or gender dysphoria when the evidence is weak on its impact and/or benefit is a patient safety issue. In the wake of the Cass Review final report’s publication, some international providers stated their intention to continue prescribing puberty blockers to children in the UK, thus the risk to these children is high. The restrictions are considered necessary to mitigate the acute risk that children unable to obtain puberty blockers through the NHS will seek them through alternative routes, including private providers and international providers. This poses a risk to their health and wellbeing...”6
The Charity Commission can be seen as disregarding its Risk and Regulatory Framework by choosing to take minimal and ineffectual action against charities that continue to encourage children and parents to take and/or procure puberty blockers, as puberty blockers pose a high, acute risk to the health of children, and leave those who want to procure them at risk of receiving a criminal record.
Please could the Charity Commission now follow its Risk and Regulatory Framework and escalate this issue into a regulatory alert, as this issue poses a particular risk to the supposed beneficiaries of more than one charity.
Yours,
Orlando Woolf.
6th February 2025
Dear Charity Commission,
Please could you escalate my complaint regarding Stonewall, GIRES and Fumble (CRM:0049125) to your CEO, David Holdsworth.
The Charity Commission writes:
"A charity can raise people’s awareness of an issue to build support for a campaign, provided this furthers the charity’s purposes. Engagement in campaigning is a means by which many charities work to further their purposes."
If Stonewall and GIRES want to campaign for a clinical trial regarding puberty blockers, then they are welcome to. However making false claims regarding medical treatments does not come under campaigning; that comes under making false claims regarding medical treatments.
The Charity Commission has now received very clear advice in this area from the NHS in the form of the Cass Review, as mentioned in my complaint. I think it can now be argued, that the Charity Commission itself has taken a political stance on a medical issue, in its choice not to issue a regulatory alert regarding charities that are continue to make false claims regarding puberty blockers. This isn't acceptable.
The Charity Commission writes, "We have not identified any evidence that Stonewall or GIRES are encouraging or enabling children to obtain puberty blockers".
I have provided evidence in my complaint CRM:0049125 [this complaint]. To make false claims regarding the benefits of a medical treatment, is to encourage the public, and children, to seek that treatment out. This is only a web-search away.
The Charity Commission writes, "We can see that Fumble has reviewed the content on the website and taken action. It is not the role of the Commission to become involved in how the trustees handled the changes made to their website. This is a decision for the trustees to make."7
The Charity Commission is not following its Risk and Regulatory Framework.
If a supermarket sells a product that is harmful for consumption, then it will issue a product recall. A charity should similarly issue a statement to discontinue using a service, that it had previously recommended, if this service now puts its users at risk of receiving a criminal record, and receiving a supposed medical treatment, which the government says poses an "acute risk" to the "health and wellbeing" of children.
As it stands, the parents and children who had previously received advice from Fumble to use GenderGP, are being left completely in the dark regarding this issue. Now, both Fumble and the Charity Commission show a complete lack of concern regarding the risk this poses to supposed beneficiaries.
Yours,
Orlando
C-151015 & C-152187
