Keeping children safe in education (as long as they're cis)

The UK government has just published draft guidance: ‘Keeping children safe in education 2026  (KCSIE)’

What’s not to like about a document with those intentions?

Any initiative that aims to safeguard our children by addressing, amongst other things: child-on-child abuse, bullying, mental health concerns, self-harm, and suicide risk, risk of domestic abuse and children missing from education has to be a good thing. Right?

Well, no. Not if you’re a trans child. Or the supportive parent of a trans child. Or god-forbid, a trans adult who dares to live authentically despite a shitty experience at school that almost broke you.

KCSIE may as well be titled, ‘Keeping cis-children safe in education.’ Or, more accurately, ‘Keeping children safe in education, except trans-children who must be explicitly harmed.’

Because KCSIE, when applied to trans children, risks exacerbating all the issues it aims to improve.

So, what does it actually say?

It says a lot that isn’t explicitly related to trans children. It says schools must identify and prevent mental health harms, that suicide risk is a safeguarding emergency requiring immediate action, that staff must identify children exhibiting withdrawal, distress, and changes in behaviour and intervene early to minimise risk (paragraphs 44-47).

Yet, in relation to trans children, problems soon arise. It prohibits trans students from using toilets or changing facilities that match their gender identity and guards against other aspects of social transition like clothing or name changes, except on ‘rare’ occasions. It denies them participation in same-sex sports. And if after all this a trans child is brave enough to want to go on a school trip, a trans girl cannot share overnight accommodation with her girlfriends, a trans boy can’t share accommodation with his mates.

You don’t have to be a psychiatrist, as I was for over ten years, to understand that it is asking the impossible to reduce suicide risk while simultaneously acting on policies known to increase that risk.

Gender critical people will argue I am an overinvolved parent pushing my trans agenda. They will both ignore my history of briefly and minimally sharing some of their 'reasonable concerns' and ignore the substantial international evidence to support my change of heart. Evidence which shows that denying trans students' access to facilities matching their gender identity isn't protecting them - it's actively harming them.

Yet KCSIE shows no acknowledgment that denying transition-related support could cause mental health harm. No discussion of trans students' elevated suicide risk. No guidance on how to support trans students' wellbeing or respond to their distress from these draconian measures.

It purports to be all about safeguarding children. Bullying and its prevention is mentioned over and over again – online bullying, racial bullying, sexual harassment _ but it has a massive blind spot when it comes to trans children, where it mandates they be bullied by the very staff charged with their care.

As I contemplate all this, I can’t help but think of Alice, my trans daughter who died by suicide on 26^th May 2022.

She didn’t fully come out as trans until three months after her seventeenth birthday, after she took an enormous overdose that could have killed her. When it didn’t we were given the gift of knowing her as she needed to be known. As Alice.

This extract from my memoir describes her return to school in year 13, three months after that first overdose.

“Early in September, there was much excitement when some of Alice’s friends arranged a trip to Primark to kit her out with some suitable clothes for school. The girls all shared the same changing room; she came home laden with outfits. She’d developed a penchant for short dungaree dresses (she had great legs).

I think that might be a little too short for school, I said. I laughed because I’d never had to say that to Kate.

It’ll be all right, she replied, laughing too.

(Later) we had a coming-out Mad Hatter’s tea party, just the five of us, no other guests, to officially welcome Alice into the family. Alice, dressed in her new Primark outfit, was in a sunny mood, buoyant and optimistic.

She was so engaged in life in those weeks, preparing to go back to school fully, as Alice, for the first time. She would be studying physics, maths, drama and psychology. She was excited, not apprehensive. She arranged to go in with her friend Iona on her first day, for moral support. For a child who’d had so much anxiety for so long, it was quite something to observe her transformation. I dropped her off at Iona’s, so they could go in together. The teachers knew Alice was coming back as Alice (we’d popped into see the head of sixth form the day before and he had been fully supportive). But apart from an inner circle of six close friends, Alice hadn’t told anyone else. She was in a group of around eight lads who she played Dungeons and Dragons with on Saturday evenings. None of them knew. I didn’t know that they didn’t know. I’d have been beside myself with worry if I had. And just like that, she started her first day in year 13 as Alice, in a skirt and sweatshirt, hair bleached blonde, eyeliner copiously applied, as if it were the most natural thing in the world.

I went to pick her up at the end of the day in the usual spot. There was a big public car park near her school and children poured across the recreation ground to meet their parents there. I arrived early for a change and took Pippin (Alice's dog), as my excuse to mill around on the playing fields, so I could come to Alice’s aid if there was any trouble. When I saw her, she smiled and gave me a low wave, hand at her hip, just like she always used to. She looked fine, all the other kids were just walking along, not paying her any attention at all. A little hope crept in.”

This guidance leaves no room for hope. I feel despair for all the trans youth and their families who will be affected by it. And for all the trans adults who are affected by it indirectly. It retraumatises them; it retraumatises me. Square and simple, this guidance is mandating conversion practices.

But those with gender -critical ideology who have influenced and probably helped draft KCSIE, simply don’t see this as trans children being harmed but as cis children being protected from trans children. Let’s take a moment to note this quite categorically. This guidance starts from the premise that trans children make cis children unsafe. What risk do trans children pose? The guidance might not say it explicitly, but the bottom line is this, in the minds of gender critical people trans people, including children are predatory sex pests (yes, this is children we are talking about here, but this is the framing, nonetheless).

They also harbour a belief that these policies will protect trans children from themselves. To gender critical people trans children don’t really exist, the mantra ‘no such thing as a trans child’ never far from their lips. Trans children are really mentally unwell cis children and subjecting them to these measures will somehow fix that. They won’t be trans at all. Happy days!

Well, let’s find out from research if that’s actually true.

In 2021 Turban et al conducted a piece of research that showed harassment, not social transition, causes harm.

The US study asked 27,715 transgender adults about their mental health. The initial finding was that those who had socially transitioned as adolescents had worse mental health outcomes in adulthood. BUT when the researchers asked them to retrospectively report on harassment they experienced during their school years based on their gender identity and controlled for K-12  harassment (K-12 equates to reception through to Year 13 in the UK) this association completely disappeared.

It’s not social transition that harms. Trans youth who socially transitioned in supportive, non-harassing school environments had good outcomes. Trans youth who socially transitioned but faced harassment and discrimination at school had poor long-term mental health. It’s being harassed at school during the years when you're socially transitioning which causes the long-term harm. Schools need to provide safe and affirming environments for social transition to have positive outcomes. Without protection from harassment, even supported transitions can lead to poor long-term mental health.

But the UK KCSIE draft guidance mandates policies that could constitute or enable the exact K-12 harassment described by Turban et al.

• Exclusion from toilets and changing rooms and forcing trans students into bathrooms/changing rooms that don't match their gender identity

• Not allowing them to participate in ways consistent with their identity – in sport and on school trips

• Being prevented from dressing according to gender identity

• Teachers/staff refusing to use correct names/pronouns

  
  

All these actions can lead to situations where trans children are outed, singled out as different, leading to: bullying, teasing, name-calling related to gender identity/expression, physical harassment or violence, peer rejection and social isolation, verbal abuse and threats.

But KCSIE isn’t interested in all the evidence. Only some of it. The UK government has wedded itself to the Cass Review which has become its bible of youth gender health care. Now it is using Cass to justify restrictions on trans children in schools. Hilary Cass has endorsed the guidance, saying it "reflects the recommendations of my review".

But the Cass Review's actual findings are much more nuanced and uncertain than KCSIE draft guidance suggests. The Cass review stated: "Social transition is not a neutral act…”and “social transition demonstrates no clear evidence of positive or negative health outcomes in children.”

Absence of evidence is not evidence of harm but KCSIE interprets this as: “social transition may have significant effects on the child” framing it entirely in the negative and failing to engage on any level that it might be profoundly wonderful for the child. Social transition should be extremely rare, it says.

Who defines rare? Some teachers may be more inclined to support a child that another would refuse to affirm. Who decides?

Cass recommended: "children and their families be advised on the risks AND benefits of social transition, and that this “is not a role that can be undertaken by staff without appropriate clinical training".

But KCSIE tells schools to make decisions about social transition as safeguarding matters, not clinical ones.

Finally, Cass said nothing about keeping trans children out of bathrooms, but KCSIE makes this the centrepiece of its approach.

And anyone with half an eye out for trans rights will know the Cass review has been heavily criticized by large swathes of the international medical community. These critiques can be found elsewhere, but I choose to highlight this simple observation from a piece of Australian research: "Disturbingly, the Review speculatively conceptualised the continuation of trans identity into adulthood as a potential harm of social transition"

This is the nub of the matter. Transition is considered a bad outcome.

Within hours of the KCSIE draft guidance being published social media was awash with heart wrenching stories, not hard evidence, not research, but anecdotal tales that moved me to tears. One mother spoke of how her cis gay son survived childhood bullying by taking refuge in the girls’ loos at school. Here he was safe and saved from further physical assaults. A trans adult spoke of coming out to her mother aged fifteen, of being verbally abused. Being at a Catholic school she was afraid to come out to her teachers, but about a year later, with the situation at home no better, she took a teacher into her confidence. School became a safe space, she could be herself, and this was enough to get her through the hours of harm at home. But if that happened now, her mother would be told. KCSIE puts the parent first. If it comes into effect these stories will become fairy tales, stuff of myth and legend, or worse than that, they'll morph from tales of love, support, hope and understanding to tales of hate, harm and shame. It’s soul destroying.

That the UK has become the most repugnant playground bully when it comes to caring for its trans population is a matter of intense distress to me. So that in my darker moments I can experience a fleeting sense of relief that Alice isn’t here to see how far things have fallen since she died almost four years ago. For if she couldn’t cope then, how would she cope now?

Suicide doesn’t happen in a vacuum. Mental distress builds and builds.

I'm so tired of the elevated rates of depression, anxiety, self-harm, and suicidal ideation in trans youth being attributed to some sort of internal failing of their own making, somehow inherent to being trans. Yes, trans youth face a severe mental health crisis - with suicide attempt rates far higher than cisgender peers. Maybe, just maybe, it wouldn’t be such an issue if trans existence wasn’t treated by many of the non-trans majority, certainly the majority in power, as something quite unfathomable to them. Something they deny and dismiss, something they clearly want to go away.

When bullying and lack of societal and medical support is shown again and again to contribute to trans peoples struggles with their mental health, it’s hard not to look at the KCSIE document and draw the conclusion that the people who wrote it simply don’t care if trans children die. As long as cis children are ok. It's impossible for me to get in the head of those who wrote it. How they can believe on any level that it's reasonable and proportionate way to deal with trans children?

But when I search for opinion, I find many think the guidance needs to go further.

John Denning head of the Christian Institute says, “It is profoundly harmful for a child to reject the reality of their God-given body and to try to live as if they are something they are not. Safeguarding guidance should ban schools from ever facilitating this. Sadly, this draft guidance stops short, leaving some children at risk.”

Sex Matters welcomes the guidance but is still dissatisfied that some social transition might be allowed “It is alarming that once again schools are being encouraged to take a “doctor knows best” approach” it says in a statement on its website. Wtaf? This sentence alone should make anyone with an ounce of critical thinking stop in their tracks.

This stance is repeated in newspaper headlines running with sensationalist headlines that do not represent my reality. “LABOUR OPENS DOOR TO TRANS CHILDREN IN PRIMARY SCHOOLS’ screams the Daily Mail.

At first Alice’s social transition at school was positive. But the toilet situation was not dealt with appropriately. At that meeting with the deputy head the day before Alice started back in year 13, it was agreed that if she needed to go to the loo she would use the staff toilet. I am ashamed I didn’t push back against this, but I remember Alice accepted quite easily. She was a compliant child, not good at asking for what she needed. I remember asking, Are you sure? Will this be ok? and her giving me a timid little smile, I’ll be fine. The same words she said to reassure me before I went out, leaving her with the time and freedom to take her first overdose.

It wasn’t fine. It was stigmatising. At the time I didn’t grasp how problematic it was. When schools deny trans students basic dignity, their institutional discrimination signals to other students that trans people are “less than” anti-trans harassment is acceptable they learn trans people can be targeted. It signals that trans students are problems to be managed, not children to be protected   and creates a permission structure for harassment and violence.

Nothing good will come from this guidance if it makes it on to the statute books.

Let me leave you with another passage from ‘Her Name Is Alice’.

“Alice was finally being listened to, was under the care of a psychiatrist. School was going well, she denied any problems with staff or students regarding her transition and attended every day, smiling and bright.

In late September, the first of Alice’s friends turned eighteen. Bea hosted a fancy-dress party at her house. The theme was a character named for the first letter of your name. Alice was very excited. She planned, of course, to go as the most famous Alice of all, Alice in Wonderland. She ordered a slightly slutty outfit from Amazon. She was so pleased with it; she went to the party full of adolescent joy.

In the small hours of the morning, around daybreak I got a call. Please come and pick me up. Alice was dishevelled, her make-up a mess, she’d surely been crying. Her costume was covered in red and brown splodges. What’s happened? I asked. Nothing, she said. She went to bed and slept off her hangover. When she came down again, she asked how to get the stains out of her outfit.

What is it? I asked.

Ketchup and brown sauce, she said.

How did that get there? I asked.

It doesn’t matter.

It does, I said. What happened?

I fell asleep, and when I woke up I was covered in it, she said.

Who did this to you?

I don’t know, just leave it.

But Alice, this is awful, we can’t let people treat you like this, I said.

I just want to get it out of my dress, she said.

She buried any distress about the assault on her person, appeared only upset that her outfit was spoiled. And because she buried it, eventually I did, too. I did not try and find out who it was, to speak to a parent or the school. It was forgotten but not forgotten.

After this incident, Alice’s attendance at school started to slide, and she began to withdraw again. This became a pattern, peaks and troughs, peaks and troughs. And when she entered a trough, you never knew how deep it would go, or how long it would last.”