Responding to the Consultation on Flourishing for All: Anti-Bullying Guidance

Christian Concern are encouraging parents, teachers, and supporters to respond the Church of England’s guidance on anti-bullying in schools, after the guidance continues to remain in thrall to gender ideology

The Church of England (CofE) has released new draft guidance for its schools on tackling bullying.

Flourishing for All is set to replace Valuing All God’s Children, with the stated aim of Part B of the document being to tackle “homophobic, biphobic and transphobic bullying”.

All bullying is wrong. But like the previous guidance it is in thrall to trans ideology and risks genuine Christian faith being wrongly branded as bullying.

Please use the guidance below to respond to the consultation before the deadline on 31 July. It is organised into a Part A and Part B, with a section at the end entitled ‘About You’.

Do not cut and paste answers but reply in your own words having considered some of the bullet points.

Feedback on Part A: Our vision for flourishing and anti-bullying

A1. Does Part A make it clear why anti-bullying is an essential aspect of ensuring flourishing?

We suggest you answer No.

• It is framed around eradicating homophobic and transphobic bullying in a way which leads to bullying of Christian families and their children who do not want to promote, affirm or celebrate same-sex relationships or gender ideology. This is not flourishing for all, the very aspiration of the document. Christian families and their children are already being silenced, bullied and harassed due to the notorious previous guidance. The proposed guidance does nothing to address this.
• The vision of ‘flourishing for all’ (e.g. cited on page 6 and elsewhere), precludes the fact that teaching of Christian truth is how the church historically believes such flourishing occurs. The document is infused with the belief that a gender identity is real. This is a false and harmful belief that faithful Christians should not endorse. It is also out of step with the Government’s draft guidance on gender questioning children, which refers to this specific worldview as a highly contested ideology and warns of its effects in relation to social transitioning.

A2. Does Part A make it clear what bullying is?

We suggest you answer Yes.

A3. Does Part A make it clear what the legal and statutory duties of schools with regards to bullying are?

We suggest you answer No.

• There is no mention of the bullying and harassment of children and staff in CofE schools who respect all people but do not want to promote, celebrate and be required to affirm same-sex relationships or gender identity ideology. The religious freedom of faithful Christians to be morally opposed to same-sex marriage and sexual relationships must be clearly stated.
• The Public Sector Equality Duty (PSED), as prescribed by the Equality Act 2010, requires schools to have due regard to eliminating unlawful discrimination and that they foster good relations between those with different protected characteristics. The draft guidance, as written, stigmatises Christian (and other faith-based) beliefs which do not accord with the worldview as framed by the document. The unintended consequence of the document could be that many Christians are treated less favourably than others, in how bullying prevention is promoted and how faithful Christians are viewed for holding dissenting views to those of the guidance. At worst, this could result in unlawful indirect or direct discrimination by schools who lean on this guidance. At the very least, Flourishing for All (FFA) is promoting a dereliction of duty in relation to the PSED owed to those with the protected characteristic of religion or belief by the way it is phrased.
• Sex-based bullying is not addressed as there is no definition of male or female, man or woman. Sex is not assigned by doctors or parents, as indicated in the glossary, it is recognised. This guidance is underpinned by an acceptance of gender ideology-based language which refuses to define sex. In fact, the guidance directs schools not to use ‘outdated terms’, without defining these terms. The glossary identifies terms which are to be promoted and does not have ‘men’ or ‘women’ defined. Amongst other issues this means bullying of young men or young women for their sex cannot be properly addressed.

A4. Does Part A set out a clear Christian vision for anti-bullying?

We suggest you answer No.

• The overarching aspiration to be ‘Deeply Christian’, is totally absent from this document. Christian teaching and principles are sacrificed in the name of ‘inclusivity’, which will result in the exclusion of Christian staff and families who do not want to promote, affirm or celebrate same-sex sexual relationships or controversial gender identity ideology, which is in contradiction to Church of England doctrine.
• A Christian vision for flourishing must include, at the very least, an acceptance of the Church of England’s doctrine of the trustworthiness of the Bible and its patterns for human flourishing. A Christian vision must also include an acceptance that those who hold those beliefs should be able to express them and not have those members of the school community go against their conscience for risk of bullying. This includes expression of the Church of England’s own doctrine that marriage is between a man and a woman.
• The guidance is not ‘Deeply Christian’ because a diluted and truncated form of the gospel, is its foundation. Humans are created in God’s image and designed to have life to the full as is frequently stated. However, they are also in need of a saviour due to their fallen nature, and to recognise and to repent of their sin, so they can truly flourish now and for eternity. Without this being communicated in CofE schools there can never be a clear Christian vision.
• It is stated that, “Flourishing requires every member of a school community to be valued as having inherent worth, especially the most vulnerable.” However, this document views contested opinions about gender as of equal worth to Church teaching about identity. Christian flourishing requires that lies are not entertained and reinforced in CofE schools in the teaching and pastoral care of children, by the members of its community.
• While the Bible is quoted at points, it is only referenced in out of context ‘proof texts’ to enforce that there should be no expressed Christian disagreement regarding what flourishing is defined to look like in school communities. The most basic, fundamental, biblical truth about gender, that God creates us ‘male and female’, is quoted nowhere in the document and should be stated clearly.
• The guidance even promotes compelled speech by stating that: “Remaining silent on the topic, or avoiding it, can send a hurtful message to pupils and/or adults who are LGBT+” This forces pupils and staff who believe CofE doctrine on marriage and sexual ethics to violate their consciences by endorsing sinful practices. As the recent EAT ruling in Forstater v CGB Europe made clear, such a policy could amount to unlawful discrimination.

A5. Does Part A explain clearly why Flourishing for All will address a range of protected characteristics?

We suggest you answer No.

• The protected characteristic of traditional Christian belief is not referenced. This lack of clarity means Christians in Church of England schools who believe CofE doctrine on marriage and sexual ethics will continue to be bullied and harassed for their beliefs should they be expressed.
• The guidance must state, as the draft government guidance on Gender Questioning Children does, that ‘no teacher or pupil should be compelled to use these preferred pronouns’. Christians should be free to use creational and biological pronouns in accordance with their conscience and since no pupil can legally change their gender until they are 18-years-old.
• The glossary educates the reader about pronouns, without any value judgement, that, “Some people may prefer others to refer to them in gender neutral language and use pronouns such as they/their.” This promotes acceptance of the changing of pronouns, without challenge, as part of supporting social transitioning. It is far from neutral language. The guidance should make clear that compelled speech regarding pronouns in CofE schools will not result in flourishing for all and should be guarded against.
• While “LGBT+ parents/ carers can bring useful insight to the development and revision of anti-bullying policies,” Christian parents who believe CofE doctrine on marriage and sexual ethics are not encouraged in the same way to bring ‘useful insights’ on how they can have their views and their children’s views respected, so that they don’t experience bullying or discrimination. This will silence sound, scientifically truthful, biblical Christian teaching by schools and individuals. Protecting children from bullying should certainly not result in the discrimination against, and even the bullying of, those who hold to the traditional Christian beliefs expressed in CofE doctrine. Being a Christian is also a protected characteristic.

A6. Is anything in Part A factually inaccurate?

We suggest you answer No.

A7. Do you think Part A is useful for Church schools?

We suggest you answer No.

• There needs to be a clear presentation of the traditional gospel message which the Church of England has held to for centuries, combined with a clear explanation that to hold this view is acceptable and when expressed will not be viewed as an inappropriate viewpoint to explain in all school community circumstances.
• There needs to be a clear statement of CofE doctrine on marriage and sexual ethics and defence of these beliefs. There needs to be encouragement for schools to teach and expound CofE doctrine on marriage and family.
• There needs to be a clear statement that marriage is between one man and one woman for life and that children flourish best when raised by their biological parents held together by the commitment of marriage.
• There needs to be a clear statement that CofE doctrine teaches that sexual expression outside of heterosexual marriage is sinful and therefore harmful for those who practice it.

A8. Do you think Part A is useful for:

Non-Church schools; Diocesan Boards of Education; Multi-academy trusts; Churches and clergy; Organisations working with schools; Parents; Other (please specify)

A8a. If you ticked other, please specify.

We suggest you use your own personal experience here and refer back to your previous answers where you may have expressed it is not useful. Consider using points we have provided which you have not yet referenced.

A9. Is there anything else you would like to say about Part A?

Please use you own case studies and stories as this can help form a powerful and persuasive argument to the reader. Please also refer to Christian Concern cases in CofE such as those referenced in our articles.

Feedback on Part B: Guidance for preventing and tackling homophobic, biphobic and transphobic bullying

B1. Does Part B make it clear why tackling homophobic, biphobic and transphobic (HBT) bullying is an essential aspect of ensuring flourishing?

We suggest you answer No.

• It does not make clear how tackling HBT bullying is essential to the flourishing of all children as it fails to account for the protection of those in the school community who do not wish to promote, celebrate or affirm same-sex sexual relationships or gender identity ideology, due to their Christian beliefs in accordance with CofE doctrine. Such faithful Christians in CofE schools are also being silenced and often harassed.
• The guidance states: “Under current government guidance, schools are advised to undertake a period of ‘watchful waiting’ following any request from a gender questioning child or young person to socially transition at school. If a school follows this path, it is critical that the school proactively engages with the child or young person so they know they have been heard…”. It should be made much clearer that ‘watchful waiting’ is a helpful, non-affirming path towards long term flourishing, and that it should be expected that most children will revert to identifying with their biological sex when not affirmed in the opposite gender.

B2. Does Part B make it clear what HBT bullying is?

We suggest you answer No.

• Part B creates a form of blasphemy. Polarised debates although challenging are not always bullying. “This protection includes ensuring that they are kept safe from polarised debates about the care or place of gender questioning children and transgender people in society. This is absolutely essential in order to uphold and preserve the psychological safety of this highly at risk group”. Engaging in such debates in school, from one side of that debate, will therefore become a form of blasphemy. This is exemplified by the following statement in the guidance which includes the banning of sharing viewpoints. “Nor does it mean that it is acceptable for homophobic, biphobic or transphobic language or viewpoints to be shared within the school.” No school should prohibit expression of the Christian belief that we are all created male and female as expressed in the Bible.
• Holding and expressing a viewpoint should not be classed as bullying. The Court of Appeal has already held that expressing Christian beliefs in not discriminatory. So much less so, should it be viewed as bullying. The guidance states that, “It is extremely important to recognise that Church of England schools educate those of all faiths and none, including those with very varied understandings of Christian teaching on a range of subjects. In order to do this, a school will need to teach pupils how to respect different viewpoints, disagree well in their interactions and understand that families and individuals can hold beliefs that differ from one another yet still live together well.” But the guidance says that they cannot have a polarised debate with any disagreement of anyone who believes in gender identity ideology and that identifies as ‘trans’ and so a staff or community member’s viewpoint is silenced. The DfE’s draft guidance on gender questing children supports the position that people who oppose gender identity ideology should have their views respected.
• The bullying defined is extended to that of adults. “To this end, Church schools should ensure their classrooms are places of constant nurture and compassion: where all are treated with dignity, where differences are appreciated and respected, and where all are provided with the utmost standard of care and protection. This includes gender questioning children and transgender adults.” This will lead to infallible transgender adults in schools. This aspect of the guidance must be removed.
• The guidance under point 3 suggests that children could be criticised for bullying LGBT adults. “It is vital, both for the wellbeing of the adults themselves and for the messages this sends to children and young people, that any HBT bullying behaviour towards adults is tackled thoroughly.” The schools will now be policing bullying of adults in the school community, potentially from the children who hold a different viewpoint and express that. This is unacceptable.

B3. Does Part B make it clear what the legal and statutory duties of schools with regards to HBT bullying are?

We suggest you answer No.

• There is no mention of the bullying and harassment of children and staff in CofE schools who respect all people but do not want to promote, celebrate and be required to affirm same-sex relationships or gender identity ideology.
• The guidance makes no reference to the legal free speech rights of individuals in schools and is anti-free speech in its tone. The guidance is against supporting any genuine Christian who wants to speak of God’s good pattern for our lives in school. In practice, any dissent from LGBTQ ideology is branded as homophobic, biphobic or transphobic and silenced under this guidance. In fact, the guidance goes even further: “remaining silent on the topic, or avoiding it, can send a hurtful message to pupils and/or adults who are LGBT+.” It appears vocal endorsement and affirmation is required without exception. This is most likely illegal.
• No statutory or other legal obligation arises specifically towards HBT bullying, when compared to any other form of bullying. The Equality Act, which includes the PSED, does not create a hierarchy of rights. That means that deeply held Christian beliefs cannot be treated less favourably than the perceived needs of pupils who identify as gay or trans.
• Both the law and relevant DfE guidance require that all forms of bullying be treated with equal seriousness. The DfE’s Keeping Children Safe in Education (2023) notes that while HBT bullying may occur in some school settings, that each school should look at their specific circumstances rather than form a universal rule. Other forms of prejudice-based bullying may also occur (e.g. sex, race, or religious motivated bullying) in schools.

B4. Does Part B set out a clear Christian vision for tackling HBT bullying?

We suggest you answer No.

• The guidance says that some people are “non-binary” (p27). If the guidance was truly about how to tackle bullying while maintaining a Christian vision of ‘flourishing’, it would give advice on how to uphold the Biblical truth that we are made male or female, an identity given to us by the highest authority, our Father God. It would explain how to uphold this truth with gentleness and respect to children and adults who have been led astray by harmful gender ideology. Instead, it simply accepts the language of the world, leaving children to work out their own sexual and gender identity themselves.
• A clear Christian vision includes not only the kind of acceptance and inclusion the Jesus shows to the woman caught in adultery, but also the command to go now and ‘sin no more’ expressed at the end of this story.
• A Christian vision for flourishing is deeply rooted in promoting the family and marriage between one man and one woman for life as the foundation of family. In the vast majority of cases children flourish best when brought up by their biological parents who are united in marriage. This should be clearly stated.
• The overarching aspiration to be ‘Deeply Christian’, remains absent from this document. Christian teaching and principles are sacrificed in the name of ‘inclusivity’, resulting in the exclusion of Christian staff and families who do not want to promote, affirm or celebrate same-sex sexual relationships or gender identity ideology, which is in contradiction to Christian teaching.
• A Christian vision for flourishing must include, at the very least, an acceptance of the traditional Christian beliefs in the trustworthiness of the bible and it’s patterns for human flourishing. In other words, acceptance of CofE doctrine. A Christian vision must also include an acceptance that those who hold those beliefs should be able to express them and not have those members of the school community go against their conscience for risk of bullying.
• The guidance is not ‘Deeply Christian’ as a diluted and truncated form of the gospel is its foundation. Humans are created in God’s image and designed to have life to the full as is frequently stated. However, they are also in need of a saviour due to their fallen nature, and to recognise and repent of their sin, so they can truly flourish now and for eternity. Without this being communicated in CofE schools there can never be a clear Christian vision.
• While the bible is quoted at points, it is only referenced in out of context ‘proof texts’ to enforce that there should be no expressed Christian disagreement regarding what flourishing is defined to look like in school communities. The most basic, fundamental, biblical truth about gender, that God creates us ‘male and female’, is quoted nowhere in the document and should be stated clearly.

B5. Does Part B set out clear actions for Church primary schools to take to both prevent and tackle HBT bullying?

We suggest you answer No.

• It is unclear whether, as stated in the draft government Gender Questioning Children guidance, gender identity teaching is precluded from being promoted in CofE schools. “In the primary phase, there would not usually be a reason for differences in viewpoint around sexuality and gender to be discussed in the classroom.” The removal of transgender ideology from primary schools should be made clear and extended to books and resources which might promote contested ideas about sex and gender. Schools may seek to use such resources to create an inclusive environment for those who believe in transgender ideology, and must be dissuaded from doing so.
• The fact that there is no legal requirement to teach LGBT themes in primary school is not referenced, and there is a bias towards its inclusion in primary schools. This is exemplified in the statement: “Ensuring the statutory guidance for Relationships and Sex Education and Health Education is implemented. This would usually include ‘teaching awareness and respect towards LGBT people.’ If a school cannot show that they have properly consulted their community about this, this will be taken into account by Ofsted inspectors when making the leadership and management judgement”. This is threatening in its tone and inappropriately biased.

B6. Does Part B set out clear actions for Church secondary schools to take to both prevent and tackle HBT bullying?

We suggest you answer No.

• The use of extreme caution regarding external organisations, as in the government’s guidance on planning RSHE, should be mentioned in Part B. “Any discussion on the range of viewpoints people may hold about sexual orientation and gender identity should be thoroughly planned as part of the school’s curriculum and not be entered into in an ad hoc way. This planning should involve members of the LGBT+ community as well as church and faith groups.” The ‘extreme caution’ should also be applied to any visiting speakers who may be considered to speak on these topics.
• In providing pastoral support, the new guidance states schools should be, “Creating safe spaces for those who are (or perceived to be) LGBT+ to meet with peers with similar identities. This allows them to build trusting positive relationships and build psychological safety.” The growth of LGBTQ+ clubs in secondary schools where affirmation from LGBTQ+ adults prevails will surely open the door to indoctrinating teaching into queer theory and harmful gender identity beliefs being endorsed through Church of England schools. Such groups should not be given a place in CofE secondary schools, and this should be made clear in the guidance.

B7. Is Part B useful for navigating difference when dealing with HBT bullying?

We suggest you answer No.

• There is no recognition in this document of a parent’s legal right to withdraw a child, when they are not happy about what is being taught in the sexual education realm. Parental rights in this matter must be included.
• Regarding clergy it is advised that “it is critical that viewpoints which are homophobic, biphobic or transphobic are not presented since to do so would be harmful to both pupils and adults.” Clergy should be encouraged to sensitively represent the traditional Church of England doctrine on sex, identity and gender in Church of England schools.

B8. Is anything in Part B factually inaccurate?

We suggest you answer Yes.

• The Christian theology underpinning this document is factually inaccurate because of what it omits. The bible does not say that we are merely made in God’s image but that we have a sin problem and are in need of repentance and conversion. A half truth is no truth at all.
• It is factually wrong to state that sex is: “assigned to them at birth.” Biological sex is recognised at birth.
• It is factually wrong that: “Remaining silent on the topic, or avoiding it, can send a hurtful message to pupils and/or adults who are LGBT+” No evidence is provided for this outrageous statement. No one should be compelled to endorse sinful behaviour that contravenes CofE doctrine on marriage and sexual ethics.
• It is factually wrong to state that some people “are non binary”. This is a highly contested belief. It is not the case that people are born non-binary.

B9. Do you think Part B is useful for Church schools?

We suggest you answer No.

• There needs to be a clear presentation of the traditional gospel message which the Church of England has held to for centuries, combined with a clear explanation that to hold this view is acceptable and when expressed will not be viewed as an inappropriate viewpoint to explain in all school community circumstances.
• Church of England schools should teach Church of England doctrine on marriage and sexual ethics and that obedience to this doctrine is the best way for people to flourish. In the vast majority of cases children flourish best when raised by their biological parents united in marriage. This should be clearly taught and promoted in all church schools.

B10. Do you think Part B is useful for:

Non-Church schools; Diocesan Boards of Education; Multi-academy trusts; Churches and clergy; Organisations working with schools; Parents; Other (please specify)

B10a. If you ticked other, please specify

B11. Is there anything else you would like to say about Part B?

Please use you own personal experience as this can be a powerful and persuasive argument. Please also refer to Christian Concern cases in CofE such as those referenced in this article. 

Feedback on the document as a whole

Do you have any comments on the document as a whole? For example, comments on the proposed scope of the document.

• The glossary of this new document is shaped by gender identity ideology. For example, “Cisgender This is a term introduced to refer to people who identify exclusively with the sex assigned to them at birth.” This is written as though sex is something ‘assigned’ and not real and permanent. “Watchful waiting: An approach by which a child/young person’s gender journey is observed (without intervention) to see how their gender identity and expression naturally evolves”. This is all set in the context of a gender journey, and assuming gender identity is real. This is deeply inappropriate.
• Intersectionality as a concept is highly contested and is not a Christian or biblical understanding of personhood. The CofE has totally bought into ‘Intersectionality’ quoting documents such as ‘Intersectionality of privilege’ https://www.dpag.ox.ac.uk/work-with-us/equality-diversity-inclusion/anti-racism-working-group/anti-racism-resources-march-2023-intersectionality-of-privilege . It wants ‘intersectionality’ training for staff as seen in the guidance on key actions to be, “Supporting staff to understand the cumulation of discrimination, intersectionality and trauma”
• Section 89(1)(b) of the Education and Inspections Act 2006 requires that head teachers in maintained schools have regard for preventing all forms of bullying. By disproportionately focusing on HBT bullying, other forms of bullying are at risk of being viewed as less serious. FFA’s singular focus on inclusivity also may lead to moral bullying, if not physical or verbal bullying, of Christians who hold Biblical views on homosexual behaviour and God’s creation order as pertains biological sex.
• The Department for Education’s Frequently Asked Questions section for its July 2017 Guidance on Preventing and Tackling Bullying echoes this position. In a question about whether schools should prioritise tackling certain forms of bullying over others, the guidance is clear that: “All bullying, whatever the motivation or method, is unacceptable and should not be tolerated.”

Please use you own personal experience as this can be a powerful and persuasive argument. Please also refer to Christian Concern cases in CofE such as those referenced in this article.

The final ‘About You’ section relates to your personal details.

When asked about whether you have a protected characteristic, it is worth stating that you are a committed Christian who believes in the traditional CoE doctrine on marriage, sex and gender, as taught in the Bible and throughout history by the church. This religious characteristic is protected.

You may choose to complete this document anonymously if you wish to do so.

Please submit your response by 31^st July. https://churchofengland.tfaforms.net/f/antibullyingjuly24