Say no to inappropriate Sex Education

Christian Concern’s Head of Education Steve Beegoo provides guidance for parents to respond to the latest government guidance on sex education in schools

Draft Statutory Guidance

Statutory Guidance Consultation Document (Respond by 11^th July 2024)

Website for Submission

The Prime Minister ordered a review into Relationships, Sex and Health Education (RSHE) delivery in 2023. Having received the review report, the scale of the concerns regarding what our teachers have been showing our children became very clear.

Mr Sunak said in announcing new draft guidance:

“Parents rightly trust that when they send their children to school, they are kept safe and will not be exposed to disturbing content that is inappropriate for their age.

“That’s why I was horrified to hear reports of this happening in our classrooms last year.

“I will always act swiftly to protect our children and this new guidance will do exactly that, while supporting teachers to teach these important topics sensitively and giving parents access to curriculum content if they wish.”

The Prime Minister effectively conceded that many children have not been safe at school because of what their teachers have been teaching them.

Christian Concern has repeatedly called for a change of direction on Sex Education, exposing much of this harmful content.

Along with the new draft guidance, released on 16 May, there is a public consultation.

This is an opportunity for Christian parents, teachers, leaders and organisations to share their views and experiences and to oppose inappropriate Sex Education.

Even if there is a new government, they should be informed by the public response to this consultation, which is due to close on 11 July.

Please use the guide below to help you respond to the consultation.

General Points

1) This draft guidance is an attempt to rein in Sex Education which has become disturbingly inappropriate across all ages and was always at odds with much of Christian teaching. Parents are able to withdraw their children from Sex Education, secured in law, for good reason.

2) The Sex Education delivered by those with a state worldview is based on a secular and therefore perceived ‘neutral’ belief that:

• individual autonomy and children’s rights are sacrosanct
• ‘human rights’ are the sole foundation for morality
• information only ever empowers
• so long as there is ‘consent’, it is moral
• sexual experimentation and expression of children is to be expected and not confined to monogamous adult heterosexual marriage
• we should teach children to protect themselves from sexually transmitted diseases and pregnancy, in all ways except for abstinence
• abortion is a neutral act
• facts about sex and relationships can be communicated in a moral vacuum.

3) The government is proposing adjustments, limitations, and clarification on what is required to be taught at different ages about sex, sexuality, rape, pornography, abuse, gender identity, suicide, revenge porn, abortion, contraception and many other issues. These topics reflect the problems in our society that stem from the sexual revolution and the rejection of God. Different children will have very different levels of exposure to these issues, and some may not have been exposed at all.

4) Therefore, the age at which children are taught in schools about these issues is the age at which we agree as a nation that innocence about such issues should be taken away for all children of that age. To be clear, Year 3 is 7 years old, Year 7 is 11 years old, and Y9 is 13 years old. There are fundamental assumptions that, for example, all 11-year-olds will have seen or will not be protected from seeing violent pornography and so must be taught about it and forewarned by teachers. This can subtly normalise certain concepts to children by unwise or activist teachers. There is a real danger that raising awareness of these topics leads to a child being curious and being led towards the harms they are being warned about.

5) Teachers always communicate their worldview in how they teach about these issues. Where they are not Christian, they are unlikely to be supportive of a biblical understanding of sex, marriage or pregnancy. It should be expected that parents cover these sensitive and controversial areas at a time of their choice with their children, within a Christian moral framework, and not leave it to teachers.

Understanding the above is important in answering the questions in the consultation. Do not cut and paste answers but be sure to write in your own words, including your own views and experiences, incorporating the thoughts above where appropriate. Keep answers in the comment boxes to below 250 words where possible.

Responding to the questions

Questions 1-10

These are identification and confidentiality questions.

Question 11

Do you agree that we move away from a rigid commitment to review the guidance every three years?

We suggest you answer ‘No’, as regular review, at least every three years, is essential to avoid the continual descent into inappropriate content which can occur in a ‘progressive’ society. Regular review is also essential for assessing the appropriateness of the guidance to the teaching of different age cohorts as they move from primary to secondary education.

Question 12

Do you agree that the changes to length and style of the guide make the guidance easier to understand and follow?

We suggest you answer ‘Yes’, as the organisation of the document is generally better.

Questions 13-16

13. Do you agree that these changes will do enough to ensure that schools are transparent with parents and that parents have sufficient control regarding what their child is learning? 15. Do you agree with our proposed approach to increased transparency on RSHE material?

We suggest you answer ‘No’ to Q13 and ‘Yes’ to Q15. The approach is helpful but the changes do not go far enough. In 14 and 16 you can explain your answer using these points:

• School libraries and story books chosen by librarians and teachers are a major source of sexualised or gender-ideology based content. Schools should be required to be transparent to parents regarding the contents of their libraries, providing a list of books and authors.
• Unless Ofsted is required to monitor this as part of regulations related to inspection, schools will not be regularly held to account and will not take this guidance seriously enough. Many schools and unions, such as the NEU, have said they will ignore such advice already.
• Parents should not have to sign anything when merely viewing RSHE materials.
• The explanation regarding copyright in paragraphs 26 and 27, does not describe clearly enough that parents can copy materials where they find that the content is disturbing or contentious for the purposes of making a complaint, informing other parents or taking legal action
• Welcome the clarity that ‘all materials’ should be able to be viewed by parents.

Questions 17-19

Do you think this flexibility will help to ensure that pupils are adequately safeguarded? 18. Do you think this flexibility is warranted?

We suggest you answer ‘No’ to both 17 and 18. In the box provided under 19 we suggest you explain that:

• The ‘flexibility’ advised will potentially lead to all children in a cohort (where an issue has arisen) to being taught about issues which they are not mature enough to understand.
• Circumstances such as sexual abuse, suicide or the sharing of pornographic images by primary aged children may be sadly relevant for individual children, but should only be addressed by school staff with those children and their parents as safeguarding needs dictate, or the school will risk exposing the other children to ideas which they do not need to try to understand. The schools risk disturbing and traumatising other children unnecessarily.
• This flexibility alone therefore does not provide adequate safeguarding for all Parents, rather than children, should be advised appropriately as to serious issues where they have arisen with a classmate and where they may have been exposed, so the parent can support their child.

Questions 20-21

Do you agree with changes to the lesbian, gay and bisexual content in the LGBT section (note that the next section provides an opportunity to comment on text about gender identity and gender reassignment)?

This section references two paragraphs which are copied here:

Lesbian, Gay, Bisexual and Transgender content

40. Pupils should understand the importance of equality and respect and should learn about the protected characteristics, including sexual orientation and gender reassignment, by the end of their secondary education.

Sexual orientation

41. We expect the majority of primary schools to teach about healthy loving relationships. Primary schools have discretion over whether to discuss sexual orientation or families with same-sex parents. At secondary, there should be an equal opportunity to explore the features of stable and healthy same-sex relationships, and secondary schools should ensure that this content is integrated into RSHE programmes of study rather than delivered as a standalone unit or lesson.

We suggest you respond ‘No’ to Q20. In Q21 you could make the following points:

• State your own views as a Christian regarding homosexual practices and their negative health and moral implications. See our issues page for more details.
• The discretion given to primary schools to discuss sexual orientation will inevitably lead to children learning vocabulary and considering issues which they are unable to effectively discern.
• Common sexual orientation vocabulary such as lesbian, is unable to be explained accurately without speaking of sexual attraction, preference and intimacy. For example when ‘lesbian’ is described even in the simplest of terms as ‘two females who love each other’, young children are prone to take on these identities themselves erroneously, as sexual attraction and expression cannot and should not be explained or sought to be understood by pre-pubescent children.
• Just as stated on p16 of the consultation document regarding gender identity, ‘discussing such theories with pupils could prompt some pupils to start to question their gender’, so discussing these sexuality issues with children, will cause them to ask about their sexuality. This is clearly inappropriate. Encouragement to consider any sexual conduct, which would be unlawful and harmful, should not be promoted to children by teachers through such explanations.
• The nature of ‘integrated’ programmes of RSHE regarding sexual orientation (rather than standalone units) in secondary school is counter to paragraph 14, which helpfully states that there should be clear differentiation of Sex Education from Relationships Education.
• Integrated programmes are used by schools to bring sexual themes and topics to children in order to circumvent parental rights to withdraw their children from sex education contrary to their faith perspective. Such integrated programmes should not be promoted.
• There is an inextricable link between the LGBT worldview, sexual politics, and campaigning which has no place in schools.
• 80A of the Education Act 2002 places no statutory obligation on schools to teach LGBT material apart from the legal concept of marriage and its importance. The guidance should respect the limits set for what must be taught as prescribed by parliament.

Questions 22-23

Do you agree with the proposed changes related to gender identity and gender reassignment in the guidance?

We suggest you say ‘Yes’ with caveats. Many other organisations and activists will be responding ‘No’, and we want the government to be supported in removing teaching about gender identity from schools by receiving a positive cumulative response to this question. In 23 we suggest you make the points that:

• School libraries and story books chosen by teachers are a major source of gender-ideology based content. Schools should be required to audit the contents of their libraries and remove all books based on gender ideology. Schools should provide a list of books and authors to parents.
• Unless Ofsted is required to monitor this as part of regulations related to inspection, as they are required to do regarding other extreme ideologies, then schools will not be regularly held to account and will not take this guidance seriously enough. Many schools and unions, already shaped by true believers in gender ideology, have said they will ignore such advice already.
• The teaching of gender identity belief has directly resulted in the exponential growth in the number of children referred to GIDS for serious gender incongruency. The Cass Review highlights how damaging this has been and should be used in safeguarding training for all teachers.

Questions 24-25

Do you agree that the revised content on addressing prejudice, harassment and sexual violence is a helpful response to evidence of the prevalence of sexual abuse in schools?

The secondary content on pages 24-28 are being referred to with this question. We suggest you answer ‘No’ to Q24. In 25 you could make the general points stated above especially regarding the age issues should or should not be taught. Additionally you may want to make the following points:

• The best way to respond to the prevalence of sexual abuse and violence occurring in schools, is not to have even more teaching about sex, stirring up thinking about sex in the secondary aged children. They should be at school to focus their attentions on their academic studies. The quantity of the content is too great, creating an unbalanced focus within the school.
• The statements in the content table do not explain clearly enough that having sex is unlawful before the age of 16. This is consistently omitted but should be regularly emphasised throughout, just as the age of criminal responsibility is being specified to children as being the age of 10 in paragraph 35. It should be included in the secondary curriculum at point 7 of the ‘Respectful relationships’, point 4 of ‘Being Safe’ and also made explicit in point 2 of ‘Intimate and Sexual Relationships’.

Questions 26-27

Do you agree with the restriction on teaching sex education only in years 5 or 6?

The primary content on pages 17-22 is being referred to here. We suggest you answer ‘Yes’, to the increased restriction, however making key points of concern regarding primary content in 27. You could make the general points stated above especially regarding the age issues. Additionally you may want to make the following points:

• Being taught in primary such skills as ‘how to critically consider their online friendships’, sends a message that they should be having these friendships at primary age. This conflicts with other messages such as those of point 7 in the ‘Online Relationships’ section, that there is a clear minimum age of 13 for joining most social media sites. Online friendships should not be made normative for children.
• Teaching young children outside of any moral framework that families, ‘sometimes look different from their family, but they should respect those differences’, teaches children that only a relativistic attitude is appropriate, where all difference must be viewed as positive and never disagreed with. Some differences may be deemed by Christian parents and therefore their children, as immoral or unhealthy. Abusive and dysfunctional familial relationships may also look ‘different’.
• The fact that parents are not specifically referenced in ‘Respectful Relationship’ as those they should show respect to is unethical and deeply disturbing. Being respectful and obedient to parents should be a key message taught by teachers to primary aged children and must be included and regularly emphasised.
• Paragraph 50 regarding primary children with special educational needs and disabilities is not strong enough, and the phrase ‘extreme caution’ should be used in relation to their primary education. The age restrictions should be much higher, and these topics should not be covered in special schools for primary children.

Questions 28-37

There now follows a sequence of question asking if you agree with the age limit specific but grouped areas of secondary content from pages 24-27. We suggest that all the age limits are too low, and we should not teach all children at age 11 (Year 7) or 13 (Year 9) the content described. This is very likely to occur even though the content states ‘not before’. We suggest you answer ‘No’ to all questions because we advise that each content point would be more safely presented by teachers two years later than the guidance states, if taught at all.

In Q37 you have the opportunity to make points on each of the areas listed, suggesting your own view on appropriate age limits for ‘Online and Media’, ‘Respectful Relationships’, and ‘Being Safe’ topics, in line with the advice above.

Question 38-39

Do you agree with the age restriction on the secondary ‘Intimate and sexual relationships, including sexual health’ topic?

You will need to refer to the secondary content on page 28. Note the statement, ‘Explicit discussion of the details of sexual acts should only take place in so far as it is necessary to teach these topics and should not be taught before year 9’. We suggest you answer ‘No’. In 39  you could make the general points stated above especially regarding the age at which issues should be taught. Additionally you may want to emphasise the following points:

• That the nature of these topics would only be appropriate at Y11.
• The law about the age of consent is referenced without stating in any of the content that it is illegal to engage in sexual activity before the specific age of 16.
• That the approach remains very sex-positive, and that the law is merely listed as something which might be ‘taken into account’, when giving consent to sexual activity. This is not strong enough and would not be the approach in any other teaching on the law. It is in stark contrast to the drug-negative approach on page 36 in reference to drug taking.
• That teaching ‘impartial’ information about abortion outside of any moral framework to 13 year olds is inappropriate due to Christian beliefs on the issue. Abortion undercuts everybody’s ‘right to life’, and attempts to teach abortion ‘neutrally’ is very likely to have a negative impact on the well-being of disabled children.
• Paragraph 50 regarding children with special educational needs and disabilities is not strong enough, and the phrase ‘extreme caution’ should be used in relation to teaching regarding their sexual health. The age restrictions should be much higher, if these topics are to be taught at all.

Questions 40-44

There now follows a sequence of questions asking if you agree with the age limit specific, but grouped, areas of ‘Health and Wellbeing’ content from pages 29-38 which covers both primary and secondary. We suggest that all the age limits are too low, and we should not teach all children at age 7 (Year 3), 8 (Year 4), or 12 (Year 8), the content described. This is very likely to occur even though the content states ‘not before’. We suggest you answer ‘No’ to all questions because we would advise that each content point would be more safely presented by teachers two years later than the guidance directs, if at all.

You may also want to make the following points in comment box 44.

• There may be occasions where specific individual children need to be taught about some of these concepts due to safeguarding needs or personal health concerns; for example a 9 year old who starts menstruating, or a 12 year old who is addicted to online gambling or who has experienced suicide in their family. This does not require the whole cohort to be taught about these issues at the currently stated ages.
• The reference to ‘males and females’ is welcome and is important to state in point 1 of ‘Developing Bodies’ for secondary, but this language should also be used in point 4 to specify the scientific basis to sex, and not that there is any real choice to be ‘men or women’ in regard to fertility.
• Paragraph 50 regarding children with special educational needs and disabilities is not strong enough, and the phrase ‘extreme caution’ should be used in relation to their health and wellbeing needs in regards to any teaching in these area.

Questions 45-46

Do you agree with changes to the Health and Wellbeing section of the guidance?

We suggest that you answer ‘Yes’. There is no need for detailed comment in 46.

Questions 47-48

Do you agree with the proposals on suicide prevention as set out above?

This question relates to the content on page 33. We suggest you answer ‘No’ due to the age limits stated. You may want to make the following point:

• There may of be occasions where specific individual children need to be taught about some of these concepts due to having experienced suicide in their family. This does not require the whole cohort at age 12 to be taught about these issues in school.

Questions 49-50

Do you agree with this additional content?

Other departments in government have sought to increase the content of RSHE. The additional content referred to is:

• Loneliness
• Gambling
• Prevalence of ‘deepfakes’
• Antimicrobial resistance
• Healthy behaviours during pregnancy
• Illegal online behaviours including drug and knife supply
• Personal safety, including road, railway and water safety
• Vaping
• Menstrual and gynaecological health including endometriosis, polycystic ovary syndrome (PCOS), heavy menstrual bleeding
• Parenting and early years brain development
• Virginity testing and hymenoplasty
• Bereavement

We suggest you answer ‘No’, making the following points in 50:

• To require this quantity of content, given the time schools have to cover these areas, is unrealistic and would only result in a surface level of teaching and very limited understanding.
• These areas could be addressed dynamically and thoughtfully should issues arise with particular cohorts (in the event of the death of a teacher), individual children (those engaged in vaping) or in society at large (in the event of a pandemic).

Question 51

Is there anything else in the draft statutory guidance that you would like to comment on?

Here is an opportunity to provide your personal experience and concerns. Do use the general points listed at the start of this resource to help you consider points you may wish to make.

Question 52

Do you have any comments regarding the potential impact of the guidance on those who share a protected characteristic under the Equality Act 2010, whether negative or positive? How could any adverse impact be reduced and are there any other ways we could advance equality of opportunity or foster good relations between those who share a protected characteristic and those who do not?

Religion is a protected characteristic under the Equality Act 2010, and so your Christian beliefs and practices should also be protected in law. In addition, Article 2 of Protocol 1 of the EHRC states, “In the exercise of any functions which it assumes in relation to education and to teaching, the State shall respect the right of parents to ensure such education and teaching in conformity with their own religious and philosophical convictions”. All maintained schools have a statutory duty to promote community cohesion covered in their Public Sector Equality Duty (PSED).

We suggest you take time to answer this final section as fully as you are able in 250 words, taking on board the following points.

There are many arguments regarding areas of ‘adverse impact’ for Christian families. To begin with, it is impossible to be truly ‘impartial’ in teaching children this information, as the guidance directs, from such a sex-positive, consent-based initial position.

Christian families should be fully respected when schools cover topics such as abortion, contraception, same-sex marriage or how to access family planning clinics. Schools are likely to continue to override the rights of parents under Article 2 Protocol 1 of the EHRC, and the Equality Act 2010, unless specific and clear guidance is given regarding these rights for Christian parents, respecting their right to withdrawal where sexual issues are addressed, even when integrated in different parts of the curriculum.

We welcome the ‘must’ in paragraph 13, emphasising the requirement to consult Christian parents over the RSE policy. This is a statutory requirement far too many schools are either unaware of or which they flout.

The Equality Act 2010, states that religion is a protected characteristic, alongside sex, gender reassignment and sexuality. It is not subordinate to other protected characteristics. Discrimination against those with religious perspectives is unlawful, and schools should be reminded of this, especially where they have welcomed political LGBT activists and organisations . Schools should be reminded that while the content of the curriculum is explicitly excluded from the provisions of the Equality Act, the way in which it is delivered must not result in unlawful discrimination against those with Christian belief. (See ‘The Equality Act and Schools’)

The Relationships Education, Relationships and Sex Education, and Health Education (England) Regulations 2019 require substantial and meaningful engagement with parents about the content and policy, so that parents with Christian beliefs can be involved in a full dialogue about the teaching their children will receive. Schools should be encouraged to fully engage with this to understand the feelings and perspectives of Christian parents as the new guidance is introduced.

In order to answer how any ‘adverse impact’ could be reduced you could state that senior leaders and governors in all schools should be reminded by the Department for Education of the legal position of parents with regard to RSHE and religious belief (The Equality Act, Human Rights Act, RSE legislation). They should be expected to complete an internal audit of families with religious beliefs, potentially by heads of year, and a plan of action should be developed for engagement with those families and staff who may hold traditional Christian beliefs to ensure the PSED is adhered to.

Schools should be asked to request advice and support from local Christian community leaders for example through their local Standing Advisory Council for Religious Education (SACRE), a local authority body. There should be a review of curriculum provision for bias against traditional religious beliefs, supported by such SACRE advisors, especially where resources are used from external agencies. Political external agencies such as Stonewall, Just Like Us, Mermaids and Educate and Celebrate, are responsible for much of the damage being done to community relations in their disrespect for Christian beliefs and practices.

Quoting Christian Concern cases can help you argue for the ongoing need to make clear to schools that they should not ride roughshod over the Christian perspectives of parents. The cases of Izzy Montague, Nigel and Sally Rowe, Calvin and Nicola Watts and Kristie Higgs all highlight the issues for Christian parents.

It is also worthwhile noting that the current discretion enjoyed by schools in choosing and developing their RSHE programmes has been part of the problem and has led to a massive disparity between how different schools approach themes important to Christian parents. Parents should not be required to be detectives to ensure that their children’s morals and well-being are being protected.

Please submit your response by 11 July to https://consult.education.gov.uk/rshe-team/review-of-the-rshe-statutory-guidance/