Dear Mandu,
We are writing to you in the strongest possible terms to raise serious concerns about the consultation process and the involvement of the National Centre for Social Research (NatCen).
It comes to us to remind the team at the central office that WEP is a democratic political party and has a duty to function as such.
So far this consultation appears to be top down, with a striking lack of transparency, balance, diligence and accountability.
As members of WEP, we are committed to ‘doing politics differently’. To create productive political spaces where women can discuss and formulate relevant and effective policies to improve the situation of women and girls. ‘Doing politics differently’ must be a meaningful phrase and not a cynical platitude. ‘To be inclusive’ means to include us.
As the WEP Code states:
We are non-partisan. WE are diverse and inclusive. WE are making change happen so that all may thrive
We would like to raise the following issues, and expect a timely and full response:
1.The Selection Process and Scoping Committee - transparency and accountability
i) We ask for a full disclosure of the decision-making process behind selecting a third party to design the consultation.
ii) We ask for a full disclosure of the bidding process and how WEP selected The National Centre for Social Research (NatCen).
iii) What processes of due diligence and scrutiny were carried out in selecting NatCen?
iv) What contractual (or otherwise) terms and conditions and fees have been agreed upon?
v) We would like to see all discussion notes and meeting minutes pertaining to the discussions with NatCen. We would also like all minutes from the Scoping Committee.
vi) Have ‘observers’ been agreed upon as referred to here, and what was the selection process or reason for not including them?
vii) How will transparency and accountability be delivered in regards to discussions in the Advisory Group? We would like the minutes of the Advisory groups meetings so far.
2. NatCen - suitability concerns
We are deeply concerned that WEP has commissioned/ selected the National Centre for Social Research (NatCen) to design the consultation process. WE believe NatCen cannot be seen to be impartial on questions regarding sex and gender identity, and is therefore an inappropriate choice of contractor for WEP and the consultation process.
i) Nancy Kelley, NatCen’s Deputy Chief Executive and Director of the Policy Research Centre is the new CEO of Stonewall. She took over this role from the 1st of June this year. As we know, Stonewall has been lobbying the government to remove ‘sex’ as a protected characteristic and to replace ‘gender reassignment’ with ‘gender identity’ in legislation (Equality 2010). Their submission is here. It states:
“A review of the Equality Act 2010 to include ‘gender identity’ rather than ‘gender reassignment’ as a protected characteristic and to remove exemptions, such as access to single-sex spaces”
ii) NatCen de-platformed Alice Sullivan (Prof Sociology at UCL) because she had spoken out about the importance of sex-based data. Dr Sullivan, director of one of the UK’s biggest social science projects, was due to speak at a seminar earlier this year alongside officials from the Office for National Statistics (ONS), which is organising the 2021 census. Dr Sullivan was invited to speak about the importance of sex-based data for women and girls. Circulated among the six-strong leadership team, the emails say the NatCen LGBT group “suggested she not take part or that the event be cancelled”. It was scrapped days later. See here.
WEP must not be complicit in the silencing of female academics. Moreover, WEP leadership must take a strong and active stand against it.
iii) NatCen has a political agenda that does not acknowledge the need for sex-based data. This bias does not put them in a position to oversee a consultation that will be examining this very issue. Although there are strong arguments for collating data on the basis of gender identity, there is also a clear need for data on the basis of sex. These arguments must be heard for the membership to fully understand the ramifications of conflating sex and gender in data gathering. For example:
‘... we currently have no reliable data on the size of the trans population either in the population as a whole or within sub-groups, and crucially, it is impossible to predict how this may change over time. It is unlikely that the trans population will be evenly distributed, for example, by age, sex and geography. This means that the effects on data reliability are likely to be greater at the sub-group level. This can have extreme consequences for particular subgroups, e.g. 1 in 50 male prisoners in England and Wales identify as transgender (HM Inspectorate of Prisons, 2019). The Tavistock and Portman NHS Trust claims that between 1.2% and 2.7% of children and young people are ‘gender-diverse’ (NIHR, 2019)....
...We need accurate data, disaggregated by sex in order to understand differences in the lives of women and men, and in order to tackle sexism. Sex matters from the start of life, as illustrated by international differences in the sex ratio at birth due to son preference (Chao et al., 2019). Sex is a powerful predictor of almost every dimension of social life: education (Stoet et al., 2016), the labour market (Joshi et al., 2019), political attitudes and behaviour (Green & Prosser, 2018), religion (Voas, 2015), crime (Ministry of Justice, 2017), physical health (Koblinsky et al., 2018), mental health (Ploubidis et al., 2017), cultural tastes and consumption (Sullivan & Brown, 2015) – the list goes on. It is difficult to think of an area of life where sex is not an important dimension for analysis. Women have historically been second class citizens when it comes to data (Perez, 2019), and a ‘male as norm’ attitude was still apparent in much quantitative social science as recently as the 1980s.’
Sex and the census: why surveys should not conflate sex and gender identity. 2020. Dr Alice Sullivan
Read the full report here.
It is also key to point out that sex-segregated data forms the basis for policy and budget decisions made by our government, charities and other NGOs. Therefore, conflation of sex and gender does not only negatively affect women and girls, but potentially trans-identified people too.
iv) NatCen has little credibility in this field. NatCen added a transexual category to a question on sexual orientation in The British Social Attitudes Survey 2005. This is further cited and criticized in the EHRC technical note, 2012. See here.
To summarise, the issues raised cast serious doubt on the suitability of NatCen to facilitate a balanced and open consultation. We would go further and state NatCen’s position is in direct conflict with the objectives of our consultation.
Our Caucus and the members and supporters it represents are profoundly disappointed in this development. We are also sure that more broadly, WEP members would share our concern that members' time and membership money is being spent on a consultation that lacks transparency, balance and due diligence from the outset.
3. Language and Terms of Debate
i) We have sought clarification to the language used to facilitate the discussions around gender, self-ID and sex. Central Office has yet to respond on this issue. It is crucial that we differentiate between ‘sex’ and ‘gender’. This difference has long been acknowledged by WEP, for example the speech made by Sophie Walker as leader to conference in 2018 where she clearly stated that sex and gender were different and should not be conflated.
Can you confirm that sex and gender will be seen as independent and defined terms?
ii) We would also like to remind central office that in our constitution, that:
‘The Policy Committee may not develop policy proposals that contravene the core objectives of other policies that have been agreed at the Party Conference’.
(7.6.4.)
Conflating sex and gender is clearly at odds with WEP policies around equal pay, for example. It impacts not only on pay data, but also in equal pay cases where gender identity can skew pay comparators in the workplace. We cannot explore these issues if language and meaning is obscured.
Do you acknowledge that developing policy around self-ID undermines the objectives of existing policies agreed at conference?
We believe that the judgements made by WEP, as outlined above, are the clear consequence of WEP pushing a top-down agenda. They are a direct result of a failure to meaningfully engage WEP membership, fully engage in membership expertise and engage with legitimate concerns. It is a fact that poorly designed policy mechanisms will result in poor policy.
We can not emphasise more the need for WEP central office to engage with our Caucus on these discussions. A failure to do so is to fail the marginalised women and girls whom we seek to represent.
Again, we ask that this communication is circulated to both the steering and policy committees in time for the meeting this Saturday. We anticipate a timely and full response.
In good faith,
WEP Women's Sex-Based Rights Caucus www.wepsbr.com @WepWomen