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  • Sophie Manning

Government consultation on sex education – Outspoken responses



A crucial turning point for sex education in the UK was 7 November 2018, the deadline for the Department for Education's consultation about its proposed new guidance for relationships and sex education (RSE).

The last time sex education was updated was the year 2000 – before the advent of smartphones and online porn. This consultation allowed everyone – adults, young people, parents, teachers – to have their say on what is important to include in sex ed, and to emphasise the need for questioning and changing our culture by tackling such issues as:

  • gender equality

  • the impact of pornography

  • consent

  • sexual harassment

  • LGBT inclusivity, sexual orientation, family diversity

Below are the consultation questions followed by responses from Outspoken Sex Ed as well from Teaching Lifeskills, which is run by Outspoken co-founder Yoan Reed…

Do you agree that the content of Relationships Education in paragraphs 50-57 is age-appropriate for primary school pupils?

OUTSPOKEN SEX ED: Disagree. The term “age appropriate” is often a question of “stage not age”, given that some subjects need to be brought up preemptively, before onset, or on a sliding scale of preparedness or timeliness.

There should be reference to the importance of gender equality.

After “families of many forms” add: “including those headed by adults who are LGBT, single, mixed race, foster/carer etc”.

These points should be made:

• “Establishing personal space and boundaries, showing respect and understanding the difference between safe and unwanted touching are the forerunners of learning about consent.”

• “The fact that children will find or be shown pornography should be addressed, including advice about developing safeguarding practices and resilience and talking to a trusted adult about disturbing images so that children can process and contextualise their reactions.”

• “Learning correct names for body parts from the start of primary school is a form of early intervention, a safeguarding measure that arms children with self-knowledge and the ability to articulate what happens with their body. This awareness and expressiveness serves as a deterrent to possible perpetrators and signals a child’s potential for confiding in a trusted adult.”

Delete “virtues” – the use of this word in inverted commas introduces moralistic judgement and religious implication. Appearing eight times in the guidance, this loaded word is not appropriate, and in the Foreword it is associated with “self-sacrifice” – a behaviour or attitude which can make children vulnerable to abuse. Instead use the terms “values”, eg equality and respect, and “skills”.

TEACHING LIFESKILLS: Agree.

Yes. It does, however, omit some very important content areas and lacks effective guidance on the timeliness of content.

Content: Although the content set out in the draft guidance is age-appropriate it does not fully include all the important educational aspects of relationships and health. The most important omissions from the draft are the topics of learning about the body that includes the correct names for genitalia (vulva, vagina, penis, testicles), and human reproduction (womb, ovaries, eggs, sperm, ejaculation) as part of the human life cycle. Without this learning, children are not able to learn about their bodies’ natural development or use correct language to voice concerns about those areas of their bodies. This poses a serious impact on their safeguarding and self-knowledge. In addition, the draft content mentions the need for children “to respond safely to adults they may encounter who they do not know” which in terms of safeguarding misses the point of children keeping safe from adults who they DO know. We know from current research and from sexually abused victim accounts that child sexual abuse mainly occur within families and family relationships and thus, the guidance expanding on this particular point.

In regards to what pupils should know about respectful relationships “that in school and in wider society they can expect to be treated with respect by others, and that in turn they should show due respect to others, including those in positions of authority.” the guidance needs to reflect the fact that the people who pose a risk of abuse to children are most often people who are in a positions of authority and this point therefore need to be amended.

In regards to what pupils should know about online relationships “the rules and principles for keeping safe online, how to recognise risks, harmful content and contact, and how to report them.” needs to include reference to teachers being able to talk about the harmful exposure of pornography that some pupils’ experiences during primary school. From my practice experience, and supported by current research, some primary school pupils have accessed or been exposed to online pornography and are disturbed and/or fearful of the consequences of these experiences. The guidance should acknowledge the lived experiences of pupils and allow teachers the opportunity to offer advice on “rules and principles” not just on harmful online content, but specifically mention “pornography” so that teachers feel enabled to approach the topic and respond to the needs of pupils and guide them to effective support and reporting.

In regards to what pupils should know about families and people who care for me: “that others’ families, either in school or in the wider world, sometimes look different from their family, but that they should respect those differences and know that other children’s families are also characterised by love and care for them.that stable, caring relationships, which may be of different types, are at the heart of happy families, and are important for children’s security as they grow up.that marriage/civil partnership represents a formal and legally recognised commitment of two people to each other which is intended to be lifelong.”

Should include the terminology of LGBT to protect the pupils whose family represent LGBT.

Timeliness: With the flexibility given to schools to form their own curriculum the guidance does not offer enough structure to ensue that content is delivered at critical developmental points in children’s primary education. The “end of primary” must be broken into age groups, year groups or key stages so that schools have more guidance in planning curriculum to meet the needs of the pupils at age and developmentally appropriate stages. For example: Young children will naturally be interested in learning about their own bodies and how they came to be (where babies come from) and it is paramount that children learn about the physical and emotional changes in puberty before they encounter them. For example, many girls experience menarche before the end of primary school and need relevant education about menstruation before they experience this. Without effective stage/age guidance, schools may not feel able to answer children’s questions and risk deliver important content too late.

Do you agree that the content of Relationships Education as set out in paragraphs 50-57 will provide primary school pupils with sufficient knowledge to help them have positive relationships?

OUTSPOKEN SEX ED: Strongly disagree.

Include guidelines on:

• using correct names for body parts (eg vulva, testicles, clitoris)

• critical thinking about gender equality, norms, expectations, stereotypes

• integrating LGBT inclusivity and visibility (eg using LGBT examples and resources, assuming some children are LGBT, signposting resources)

• the impact of exposure to pornography

• acknowledgement of sex as enjoyable

• menstruation and masturbation discussion – with girls and boys

In the "End of primary school table", add a bullet point discussing FGM, because primary school-aged girls are at high risk.

“those in positions of authority” could be construed as encouraging acquiescing to coercion or abuse – so delete this phrase.

Under "Being safe" add: “how to develop safeguarding practices and resilience around pornography and talk to a trusted adult about encountering disturbing images in order to process and contextualise their reactions”.

Under “Online relationships”, include pornography as an example of “harmful content”.

Under “Changing adolescent body”, add: “the importance of self-knowledge around desire and pleasure, and the role of masturbation in self-care, physical health and mental wellbeing for both girls and boys”.

Change the heading “Managing tricky questions” – it presupposes that teachers will be uncomfortable and not able to communicate openly or answer factually.

TEACHING LIFESKILLS: Neither agree or disagree.

Agree to some extent. Again, the draft guidance does not offer schools enough structure referring to timeliness, nor enough content to effectively deliver comprehensive relationships education.

Content: Point 55. Please use more specific language in the guidance, such as “LGBT, children in care, adopted children, children from different cultures” so that the family circumstances of all children are safe from discrimination and stigmatisation.

Point 56. “A growing ability to form strong and positive relationships with others depends on the deliberate cultivation of resilience and positive character attributes, or “virtues”, in the individual. Relationships Education is most effective when set in a school-wide context where resilience and virtues are actively developed, promoted and practised. This includes helping pupils to believe they can achieve, stick at tasks, work towards long-term rewards and persevere despite knocks. Positive virtues pupils should develop include honesty, integrity, self-control, courage, humility, kindness, forgiveness, generosity and a sense of justice.”

Please replace “virtues” with “values” as the former is a loaded term that can be interpreted as both moralistic and judgemental. For pupils who are experiencing any form of harmful relationship “virtues”, such as self-control and forgiveness, will not empower them to seek help. The guidance must refer to a common values framework in relationships education and RSE, such as British Values and SMCS to ensure a uniform approach to values – not virtues.

Point 57. As with my response to point 10, there are gaps in the content that will give comprehensive safeguarding guidance to schools. Positive relationships include the need to be able to differ between safe and unsafe relationships to which point the draft guidance does not refer to the correct names for genitalia. Schools need a guidance that supports teachers to safely and consistently use the correct terminology in order to teach pupils effectively and equip them with the knowledge, skills and tools to teach them bodily autonomy and safeguard themselves in all kinds of relationships. This includes learning about the criminal practice of FGM which most often happens to girls at risk when they are in primary schools (or younger).

Pupils should know about online relationships and being safe: As in my previous response, both sections need to make referral to pornography as this will reflect the lived experience of some primary school children.

Do you agree that paragraphs 61-64 clearly set out the requirements on primary schools who choose to teach sex education?

OUTSPOKEN SEX ED: Neither agree nor disagree. Paragraphs 61-64 emphasise sex education not being compulsory rather than setting out the benefits to children.

Sex education should be compulsory in primary school because:

• children have a right to comprehensive sex education, as set out in the UNCRC (UN Convention on the Rights of the Child)

• sex education, starting from a young age, is vital for children’s development, safeguarding and mental health, especially as an antidote to pornography

• sex education is interrelated with and should not be separated from Relationships Education

There is tension between assessing and meeting children’s needs (a sex-education programme “tailored to” age and physical and emotional maturity) and the preparedness/timeliness of preemptively anticipating readiness, eg before onset.

It should not be up to individual schools “to determine whether they need to cover any additional content on sex education to meet the needs of their pupils” – because all children need the skills, vocabulary and resilience that sex education gives them.

Primary schools need to “support” children’s “emotional and physical development” during “the transition phase” to secondary – but it is not clear how Relationships Education, Health Education and the national science curriculum are differentiated or can provide clear, effective progression.

Add “sexual” after “physical” to read: “pupils’ ongoing emotional, physical and sexual development”.

TEACHING LIFESKILLS: Neither agree or disagree.

The draft guidance offers a muddled picture of what is required of schools as the three subjects of relationships education, health education and science are inherently interrelated but differentiated/divided by the guidance without a clear picture of where and when schools should teach topics within the subjects. To make this clearer, the guidance should clearly set out to support schools in writing a curriculum that builds on a spiral format and with signposting to age, year or key stages learning outcomes. Underpinning such a guidance requires the department to define sex education as a subject starting in relationships education at primary and developing into secondary. This will clearly place sex education on a learning platform that recognises its importance and gives schools a position in which they can promote sex education rather than focus on what should NOT be taught. In comparison, the current 2000 SRE Guidance has a positive presentation of sex education that recommends all primary schools to teach sex education and, to progress the proposed guidance, this positive and proactive approach needs to be upheld.

To this point, 62. “The content set out in this guidance covers everything that primary schools should teach on relationships and on health, including puberty.” And 63, “The Department continues to recommend therefore that all primary schools should have a sex education programme tailored to the age and the physical and emotional maturity of the pupils.” are problematic statements because puberty includes learning about body genitalia, sperm and eggs and where babies come from and should be taught gradually and before onset – this is not clearly signposted within the draft guidance or the science curriculum.

There is conflict within point 63. “As well as consulting parents more generally about the school’s overall policy, primary schools should consult with parents before final year of primary school about the detailed content of what will be taught.” and “Meeting these objectives will require a graduated, age-appropriate programme of sex education.” The former assumes that sex education will only be delivered in year 6 and, the latter, that sex education should be delivered in an age-appropriate manner.

Point 64. Please highlight the importance of parental engagement in children’s education by making this a separate point within the guidance.

Do you agree that the content of RSE in paragraphs 65-77 is age-appropriate for secondary school pupils?

OUTSPOKEN SEX ED: Strongly agree. However, delineation by key stage or year (as with programmes of study for other curriculum subjects) will help teachers deliver content in good time to meet young people’s needs. How can RSE “provide progression” without teaching sex education?

Delete “virtues” and add reference to critical thinking and to “skills and values such as equality and respect”.

Add reference to consent.

After “committed relationship”, add “whether heterosexual or LGBT". The use of "stable and healthy" in connection with same-sex relationships in paragraph 71 is judgemental. Change “coming to terms with their sexual orientation or gender identity” to “asserting their sexual orientation or gender identity".

FGM should not be sandwiched into a paragraph on "grooming, sexual exploitation and domestic abuse, including coercive and controlling behaviour". It is important to address FGM as a practice – and in the context of the law, coercion, bodily autonomy and women’s disempowerment – but also in primary school, when girls are at high risk. This should be mandatory.

A new paragraph should address the impact of pornography:

• via neuroscience (the developing adolescent brain)

• as an industry

• as exploitative for performers

• as perpetuating unrealistic expectations of bodies and sex

• the damaging effects on body image, self-esteem

• in the context of love and intimacy

• as perpetuating sexual harassment and the degradation of and violence towards girls/women (see the Women and Equalities Committee report “Sexual harassment of women and girls in public places” from October 2018)

Under “Respectful friendships”: after “cyberbullying” add “prejudice-based bullying such as anti-LGBT bullying”

Under “Intimate and sexual relationships”: add “and the importance of consent".

Under “Online and media”, after “explicit material” add “such as pornography or ‘sexting’”.

After “violent sexual behaviours” add “sexual harassment and the degradation of women”

Paragraphs 65-77, referencing pressure and implying blame, must be rewritten to emphasise gender norms and inequalities.

TEACHING LIFESKILLS: Agree. However, as in primary school table of content, the content for secondary need to be structured to give guidance on the timeliness of delivery by age, year or key stage in order for a school to develop a spiral RSE curriculum. In addition, it is paramount that pupils are consulted on the topics so that their needs are considered as per best practice.

65. Effective RSE is more than just delivery of information and needs to be delivered by trained and confident teachers and be based on experiential teaching methods for pupils to develop skills and tools as well as knowledge.

70. As with my response to primary school, please change “virtues” to “values” as the former is a loaded term that can be interpreted as both moralistic and judgemental. For pupils who are experiencing any form of harmful relationship “virtues”, such as self-control and forgiveness, will not empower them to seek help. The guidance must refer to a common values framework in relationships education and RSE, such as British Values and SMCS to ensure a uniform approach to values – not virtues.

72., 74. and & 75. It would be helpful for the guidance to link and reference to the specific legislation and laws that are relevant to RSE, for example, Equality Act 2010, Female Genital Mutilation Act 2003, Sexual Offenses Act 2003 and Keeping Children Safe in Education 2018.

77. As previously responded, in regards to what pupils should know about online and media and being safe, the guidance for secondary needs to include reference to teachers being able to talk about the harmful exposure of pornography and sexting that many pupils experience. From my practice and experience, and supported by current research, many pupils have access or are exposed to online pornography and are disturbed and/or fearful of the content and their experiences. The guidance should acknowledge the lived experiences of pupils and allow teachers the opportunity to offer advice on “rules and principles” not just on harmful online content, but specifically mention “pornography” so that teachers feel enabled to approach the topic and respond to the needs of pupils, guide them to effective support and reporting while developing pupils’ critical thinking.

Do you agree that the content of RSE as set out in paragraphs 65-77 will provide secondary school pupils with sufficient knowledge to help them have positive relationships?

OUTSPOKEN SEX ED: Strongly disagree.

Sex positivity should be emphasised.

There is no mention of:

• the interrelatedness of pleasure and consent

• the importance of improving girls’ self-knowledge around desire

• intimacy in the context of a loving relationship

There should be inclusivity and visibility around LGBT issues such as identity and sexual orientation, with reference made to LGBT relationships when citing positive and healthy relationships generally.

There should be an emphasis on gender equality, norms, expectations and stereotyping.

Noticeably absent is talk of how pornography perpetuates:

  1. unrealistic expectations of bodies and sex

  2. sexual harassment and everyday sexism

  3. the degradation of and violence towards women

TEACHING LIFESKILLS: Disagree. Although the guidance talks about the positive aspects of healthy relationships it does not include reference to sex positivity or pleasure, gender equality or LGBT.

70. Please replace “virtues” with “values” as the former is a loaded term that can be interpreted as both moralistic and judgemental. For pupils who are experiencing any form of harmful relationship “virtues”, such as self-control, self-sacrifice, and forgiveness, will not empower them to seek help. The guidance must refer to a common values framework in relationships education and RSE, such as British Values and SMCS to ensure a uniform approach to values – not virtues.

75. FGM occurs more frequently in primary years and needs to be taught earlier than secondary level. It is not possible for a school to “guess” the likelihood of FGM posing a risk to pupils, but rather, reference to the criminal act of FGM and where to go for help and support should be part of teaching about safeguarding at both primary and secondary.

Do you agree that paragraphs 36-46 on the right to withdraw provide sufficient clarity and advice to schools in order for them to meet the legal requirements?

OUTSPOKEN SEX ED: Disagree.

Children have a right to comprehensive sex education, as set out in the UNCRC.

The term “excused from sex education” – which evokes politeness and being shielded from something unpleasant – should be changed to the more forcible “withdrawn from sex education”.

Parental withdrawal of their children from sex education and RSE is commonly regarded as a possible red flag, risk indicator or child-protection concern.

Although parents have a responsibility as “sex educators” to their children, there is no way to assess or monitor the sex-education issues parents might discuss at home, or whether they will talk openly with their children.

Reinstate and update the 2000 SRE Guidance stipulation about schools providing materials and resources for parents who exercised the “right to withdraw”: “The DfEE will offer schools a standard pack of information for parents who withdraw their children from sex and relationship education.”

However, rather than underscoring parents’ wish to withdraw their children from sex education, head teachers should use the new guidance as a vehicle for being positive about RSE. It provides an ideal platform for head teachers to:

• give parents confidence and reassurance about the content and usefulness of RSE for young people

• promote the benefits and protective/preventative aspects of RSE

• stress the disadvantages of young people not receiving RSE with their peers – as set out in the 2000 SRE Guidance

• discuss the the benefits of parental engagement:

  1. in school: in terms of reinforcing RSE lessons

  2. at home: in terms of safeguarding and critical thinking, mental health and resilience, and a stronger parent-child connection

Will children be informed of their right to be included in sex education?

As outlined by leading sexual-health charity Brook, it is not feasible for schools to deliver RSE if children are opting back into RSE at staggered points throughout the year before they turn 16.

It would be helpful to have examples of what criteria the head teacher might use when refusing parental withdrawal.

TEACHING LIFESKILLS: Strongly disagree.

41.– 45. In its efforts to uphold the parental right to withdraw children from sex education outside national curriculum science, the department must make the headteacher’s approach to withdrawal uniform across primary and secondary, and place emphasis on the responsibility of parents to teach their children sex ed if they choose to withdraw them from learning at school. This includes parental access to learning about sex education and RSE, the content, timing, and resources as well as a discussion with the head teacher.

43. This paragraph does not give enough guidance to schools in how to proceed in the situation where a pupil has been withdrawn from sex education/RSE and who is approaching the age of 16. It is logistically difficult for schools to:

1. assess the needs of a pupil who has been withdrawn from sex education/RSE. Does the child have to request RSE themselves? Are schools required to ask the child?

2. Will the parents have a right to be further consulted and informed of their child’s wish to have sex education/RSE? What role and responsibility are afforded the school, the child, the parents?

Do you agree that the content of physical health and wellbeing education in paragraphs 86-92 is age-appropriate for primary schools pupils?

OUTSPOKEN SEX ED: Disagree. Girls and boys have a right to learn about puberty and menstruation before age nine – before possible early-onset menstruation and before puberty hits.

There should be an emphasis on:

• critical thinking about body image in relation to self-esteem

• digital and media literacy in relation to gender equality, norms, expectations and stereotyping

In terms of developing “the language to talk about their bodies, health and emotions”, these topics fall within the category of physical health and mental wellbeing:

• personal space, boundaries, showing respect, safe vs unwanted touching (as cornerstones of consent)

• puberty – before early-onset puberty

• menstruation – for both girls and boys

• masturbation – for both girls and boys

Change “practising service to others” to “collaborating with and helping others”.

Add:The fact that children will find or be shown pornography should be addressed, including advice about safeguarding practices, developing resilience and talking to a trusted adult about disturbing images to process and contextualise their reactions.”

Under “Internet safety and harms” add reference to pornography and "sexting". Also add: "What to do when they encounter pornography and disturbing images so they can develop safeguarding practices and resilience and talk to a trusted adult to process and contextualise their reactions”.

Do you agree that the content of physical health and wellbeing education as set out in paragraphs 86-92 will provide primary school pupils with sufficient knowledge to help them lead a healthy lifestyle?

OUTSPOKEN SEX ED: Strongly disagree.

In order to help children to establish good decision-making around self-respect and healthy relationships, there needs to be more emphasis on:

• body image and body diversity

• self-esteem

• critical thinking when it comes to pressures and influences from the internet, the media, social media, advertising, gaming and pornography

• gender equality, norms, expectations and stereotyping (including the limitations of masculinity, such as not showing emotion, and girls/women not being strong or capable)

• menstruation – taught to both girls and boys

• masturbation, for both girls and boys, as an important part of self-care, physical health and mental wellbeing

• exposure to pornography and the impact of porn in terms of:

1. developing safeguarding practices

2. developing resilience

3. talking to a trusted adult in order to process and contextualise their reactions

Questioning our culture and the pressures we all are under will hep children to become resilient critical thinkers.

Do you agree that the content of physical health and wellbeing education in paragraphs 93-99 is age-appropriate for secondary school pupils?

OUTSPOKEN SEX ED: Agree. Although menstruation should initially be taught in primary school, secondary school is an opportune time to have more in-depth discussion about the emotional, physical and sexual changes of the changing adolescent female body during the menstrual cycle.

This can tie in to discussion of girls’ self-knowledge around how their body works in terms of their periods and pleasure/desire.

Secondary school is also an opportune place to discuss period poverty, its social and cultural ramifications and recent empowering movements and campaigns such as #FreePeriods, headed up by Amika George, and #PeriodPositive.

It is important that boys also learn about menstruation.

All children should learn about how different bodies function.

Do you agree that the content of physical health and wellbeing education as set out in paragraphs 93-99 will provide secondary school pupils with sufficient knowledge to help them lead a healthy lifestyle?

OUTSPOKEN SEX ED: Strongly disagree. There should be mention of:

• consent

• pleasure – in particular in relation to:

1. girls’ self-knowledge and desire

2. how pleasure and consent are interrelated

3. sex

4. masturbation

5. mutual sexual pleasure

• sex positivity (eg acknowledgement that sex is enjoyable)

• intimacy in the context of a loving relationship

• how pornography perpetuates:

1. negative body image and self-esteem

2. unrealistic expectations of bodies and sex

3. degradation of and violence towards girls/women

4. sexual harassment and everyday sexism

• neuroscience in terms of:

  1. the developing adolescent brain

  2. the carving of neural pathways

  3. impulse control and addictiveness around watching porn or gaming

• body diversity, body image and self-esteem

• critical thinking and increased digital and media literacy around:

  1. pressures and influences from the internet, the media, social media, advertising, gaming and pornography

  2. gender equality, norms, expectations and stereotyping – which includes cultural conditioning about the limitations of masculinity (eg aggression; not showing emotion) and the objectification of women via the male gaze, self-objectification via focusing on appearance – and how these affect our attitudes and behaviour

  3. how sexual harassment is part of a continuum with other forms of degradation and violence towards girls and women, and “the most common form of violence against women” (see the Women’s and Equalities Committee report “Sexual harassment of women and girls in public places” from October 2018)

Knowledge is power; self-knowledge is power.

Do you agree with the approach outlined in paragraphs 36-46 on how schools should engage with parents on the subjects?

OUTSPOKEN SEX ED: Disagree. The new guidance should highlight the benefits of parental engagement in their children’s sex-education learning not only in terms of improving safeguarding, mental health and the parent-child connection at home but also in terms of reinforcing effective, meaningful delivery in school.

Parental engagement in their children’s sex-education and RSE learning plays a fundamental part in both a whole-school approach and an effective home-school partnership.

Therefore a new paragraph should be added, citing some of the following principles:

• Parents are the missing link in their children’s sex-education learning

• Statistics show that children and parents want to be able to talk openly about sex-education issues, but parents often lack the skills, tools, language and confidence

• Open communication between children and parents:

  1. shores up effective delivery of sex education in school

  2. empowers parents to empower their children at home

• Parental engagement in sex education and RSE:

  1. reinforces safeguarding and critical thinking

  2. improves children’s mental health

  3. strengthens the parent-child connection

Reinstate the 2000 SRE Guidance concept and practice: “Groups of parents have been trained as peer parent sex educators. They work to support other parents and to help develop school/parent partnerships.”

Group work with a trained facilitator allows parents – through experiential learning – to:

  1. compare notes and share sex-education opinions and experiences with peers

  2. practise saying awkward words out loud

  3. feel empowered to initiate conversation at home

Reinstate 2000 SRE Guidance wording “Parents are supported in their role as sex educators.” Crucially:

  1. it places parents as children’s primary educators about sex and RSE

  2. it affirms parents as “sex educators” – by contrast, this draft guidance calls parents “first educators” (paragraph 36) and “prime educators” (in the Foreword) “on many of these matters” – with no explanation of what “these matters” entails

Change “about relationships” to “about relationships and sex”.

TEACHING LIFESKILLS: Strongly disagree.

The continued right, set out in the draft guidance, for parents to withdraw their child from sex education is in stark contrast to children’s right to sexual, reproductive health education as set out in UNCRC, to which the UK is a signatory. In addition, the change in nomenclature from the SRE Guidance 2000 “parents as sex educators” to the proposed “parents as first educator’s is a regressive move and poses a weakened profile of parental responsibility to develop children’s sex education at home.

From my own practice and research parental engagement in sex education is the missing link in children’s sex education development at home. To support and strengthen parental responsibility to be their children’s primary sex educator, the draft should recognise parents as such - not by affording parents the right to withdraw their child from sex education but by supporting their role with strategically developed opportunities linking children’s sex education at school with parental opportunities to engage and learn about their child’s education.

Paragraphs 108-109 in the guidance describe the flexibility that schools would have to determine how they teach the content of their Relationships Education/RSE/Health Education. Do you agree with the outlined approach?

OUTSPOKEN SEX ED: Strongly disagree. It is beneficial to broaden the curriculum for community needs (eg gang-culture considerations) but not to narrow it, ie along religious lines or not including discussion of FGM.

Too much leeway is given to schools about how, and what, they teach in Relationships Education and RSE.

This contradicts cross-party commitment and consensus to legislation for a compulsory core area of subjects.

For developing their curriculum, schools should be required to consult children and young people on their needs regarding sex-education and RSE content and skills and when they are taught – often it is too biological, too little and too late.

All schools must emphasise:

• children’s rights

• safeguarding and resilience

• critical thinking around pressures and influences from the internet, the media, social media, advertising, gaming, pornography

• gender equality, norms, expectations and stereotyping (to change mindsets early around behaviour and attitudes – boys as aggressive or not showing emotion; objectifying focus on girls’ appearance, not capabilities)

• awareness of the impact of pornography in terms of:

  1. unrealistic expectations of bodies/sex

  2. body image

  3. self-esteem

  4. negative behaviour/attitudes

  5. degradation of and violence towards girls/women

  6. sexual harassment and everyday sexism

  7. neuroscience implications around the developing brain, impulse control, addictiveness

• preventing sexual harassment (“the most common form of violence against women”)

• consent (including interrelatedness with pleasure)

• pleasure (in relation to sex, masturbation, mutual sexual pleasure, girls’ self-knowledge around desire)

• importance of parental engagement in their children’s sex education

• sex positivity (including intimacy in the context of a loving relationship)

• neuroscience of the developing adolescent brain (eg carving neural pathways)

• LGBT inclusivity around orientation/identity and family diversity

• diversity of families headed by adults who are LGBT, single, mixed race, foster/carer etc

• preventing prejudice-based bullying (eg race, sexual orientation)

• FGM, “honour-based violence” and forced marriage (in terms of the law, coercion, bodily autonomy, women’s disempowerment)

TEACHING LIFESKILLS: Neither agree or disagree.

In essence, I agree. However, the draft guidance should emphasise the importance of creating a curriculum that is needs-based and schools should be required to evidence how they have consulted pupils on those needs. Further guidance on how schools respond to Ofsted on this must be made clearer.

The draft guidance suggests a list of resources for schools, however, this list is not comprehensive and does not feature resources from the leading organisations, such as the Sex Education Forum. Schools need to have a clearer list of reputable sources that can be consulted when drafting and designing their own programme. This list needs to be representative, evidence-based and medically accurate.

Furthermore, to ensure a programme of learning meets the needs of the pupils, is based on best practice and is sustainable, teachers need to be able to access training regarding the content, planning and delivery of relationships education, sex education, RSE, and health education.

Do you agree that paragraph 44 provides clear advice on how headteachers in the exceptional circumstances will want to take the child’s SEND into account when making this decision?

OUTSPOKEN SEX ED: Disagree.

As set out in the UNCRC, all children have a right to education about healthy relationships and reproductive and sexual health. Therefore all SEND students should receive – and be included in – accessible and developmentally appropriate sex education and RSE, including use of correct names for body parts and discussion of gender equality, consent, pleasure and pornography.

As people with disability, SEND students are disproportionately at risk of domestic and sexual violence and abuse.

This is a safeguarding issue.

TEACHING LIFESKILLS: Strongly disagree. The paragraph does not clearly provide guidance on how a head teacher should make decisions regarding exceptional circumstances. The guidance should offer a list of examples that replicate such exceptional circumstances and reference clearly the link between sex education and RSE, children’s right to sexual and reproductive health education, and safeguarding.

Do you agree that paragraphs 30-32 provide sufficient detail about how schools can adapt the teaching and design of the subjects to make them accessible for those with SEND?

OUTSPOKEN SEX ED: Disagree.

TEACHING LIFESKILLS: Disagree. It is clear that the draft guidance recognises the need to differentiate the needs of all pupils, including those with SEND. However, without giving schools realistic examples of how provisions can be adapted and without adequate training opportunities for all teachers, meeting the needs of SEND pupils will continue to be a difficult task for schools.

Do you have any further views on the draft statutory guidance that you would like to share with the department? Do you think that the expectations of schools are clear?

OUTSPOKEN SEX ED: This draft guidance is less accessibly presented than the 2000 SRE Guidance, in which ideas were expressed clearly and in separate points. Here paragraphs are often crowded with ideas which are sometimes not connected.

Learning objectives for key stages or by year (as with programmes of study for other curriculum subjects), should be clearly spelled out to help primary- and secondary-school teachers in delivering content in good time to meet children’s needs.

It is not clear how much of the timetable should be given to the new statutory subjects.

There is an avoidance of the word “sex” except in relation to “sex education”.

Crucially, the word “sex” is missing in the statement that parents are their children’s “first educators” (paragraph 36) and “prime educators” (Foreword), rather than their “sex educators”, as set out in the 2000 SRE Guidance.

Pornography and “sexting” are mentioned only once and among “including for example” topics – a shocking omission given the ubiquity of easily accessed porn, often by age 11, and the normalisation of “sexting”.

Nowhere does pornography or “sexting” arise in the context of body image, self-esteem, mental wellbeing, gender equality, sexual harassment, everyday sexism or even online safety.

Under “National curriculum for computing”, add: “how to become resilient about the impact of pornography on their expectations of sex and bodies and on their attitudes and behaviour”.

Not enough reference is made to LGBT identity (eg defining terms like lesbian, gay, bisexual, trans) or family diversity (eg marriage equality). There are no examples of how to make LGBT inclusivity and visibility “integral” to education.

Between “relationships” and “sex” add “sexual orientation”.

About schools being "free to determine how they address LGBT-specific content": change “the Department recommends” to “it is required” (as per schools’ legal duty under the Equality Act to eliminate discrimination and promote equal LGBT opportunity).

TEACHING LIFESKILLS: Although the draft guidance offers a clear list of content, these need to be listed with reference to either age, year or key stage. Without a more structured list pupils are at risk of receiving inadequate relationships education, RSE and health education in relation to their developmental and age appropriate needs.

As a whole, it is difficult to comprehend the draft guidance as the sections are not coherently linked, and, at times, appears repetitive. A teacher who will be given the task of delivering any of the three differentiated, and yet inherently linked, subjects will have a difficult task in consulting the guidance and to make sense of what is required.

The language and general tone of the draft guidance need editing to make it a comprehensive and go-to document that meets the need of school and their pupils. It appears that, in the quest to make sex education/RSE statutory, too much emphasis has been put on flexibility and individual schools’ ability to form their own curriculum. The result is a draft guidance that is reactive instead of offering a proactive and positive approach to sex education, and too weak to be effective and comprehensive enough to meet its purpose.

The guidance is an opportunity for the government to make provisions of sex education, a child’s right underpinned by UNCR and to which the UK is a signatory, available to all children. Furthermore, it offers an opportunity to fill the gap between the hitherto inadequate requirements of schools, parental engagement to further sex education at home, and children’s lived experiences. To this point, the guidance needs to reflect the purpose it set out to achieve.

Do you agree that more is required on financial education for post-16 pupils?

OUTSPOKEN SEX ED: Agree.

The department believes that primary schools should be able to access appropriate resources and training in order to teach effectively. Do you agree that the resources and support currently available to primary schools will be sufficient to enable them to teach the new subjects?

OUTSPOKEN SEX ED: Strongly disagree.

There is a manifest need for a commitment to funding for – and investment in – teacher training and delivery of sex education.

Investment will be needed in teacher training, lesson plans and resources not just initially but also in terms of updating materials in an ongoing way in order to maintain high standards.

Training by qualified professionals will ensure that teachers learn how to:

• select high-quality, evidence-based resources

• adapt resources

• overcome barriers to tackling sex-education subjects, which can be a lack of:

1. skills

2. language and vocabulary

3. confidence

The guidance should recommend an extensive, diverse list of resources.

As part of a whole-school approach, teachers and staff should be briefed on the benefits of open communication around sex-education topics.

Like many parents, teachers can find these topics difficult, awkward or sensitive.

If teachers don’t feel comfortable being open, that uneasiness will be transmitted to children – the opposite of the desired effect of fostering open communication and spiralling RSE knowledge throughout education.

Teachers often need the confidence – and resources – to confront the pressures and influences children are under from the internet, the media, social media, advertising, gaming and pornography.

Teachers should be alert to the importance of open communication as early intervention, ongoing prevention and a safeguarding measure. They should be encouraged to have a willingness to discuss such topics as:

• boundaries and personal space as forerunners of consent

• correct names for body parts (eg vulva, testicles, vagina, clitoris)

• critical thinking and digital and media literacy

• body diversity, body image and self-esteem

• gender equality, norms, expectations and stereotyping

• menstruation and masturbation (taught to girls and boys)

• sex positivity

The department believes that secondary schools should be able to access appropriate resources and training in order to teach effectively. Do you agree that the resources and support currently available to secondary schools will be sufficient to enable them to teach the new subjects?

OUTSPOKEN SEX ED: Strongly disagree.

There is a manifest need for a commitment to funding for – and investment in – teacher training and delivery of RSE.

Investment will be needed in teaching training, lesson plans and resources not just initially but also in terms of updating materials in an ongoing way in order to maintain high standards.

Training will ensure that teachers learn how to:

• select high-quality, evidence-based resources

• adapt resources

• overcome barriers to tackling sex-education subjects, which can be a lack of:

1. skills

2. language and vocabulary

3. confidence

The guidance should recommend an extensive and diverse list of resources.

As part of a whole-school approach, teachers and staff should be briefed on the benefits of open communication around RSE topics.

Like many parents, many teachers can find these topics difficult, awkward or sensitive.

If teachers don’t feel comfortable discussing these topics, that uneasiness will be transmitted to young people.

Teachers often need the confidence – and resources – to confront the pressures and influences young people are under from the internet, the media, social media, advertising, gaming and pornography.

Teachers should be alert to the importance of open communication as ongoing prevention and a safeguarding measure. They should be encouraged to have a willingness to discuss such topics as:

• critical thinking

• gender equality, norms, expectations and stereotyping and how they affect attitudes and behaviour

• body diversity, body image and self-esteem

• consent

• pleasure – in relation to

  1. girls’ self-knowledge and desire

  2. interrelatedness of pleasure and consent

  3. mutual sexual pleasure

• sex positivity

• intimacy in the context of a loving relationship

• how pornography perpetuates:

  1. unrealistic expectations of bodies and sex

  2. sexual harassment and everyday sexism

  3. degradation of and violence towards girls/women

• neuroscience and the developing adolescent brain

Do you agree that the draft regulations clearly set out the requirements on schools to teach the new subjects of Relationships Education, RSE and Health Education?

OUTSPOKEN SEX ED: Strongly disagree.

There is not enough detail or specificity about what these subjects entail and how they intersect with the national science curriculum. More content should be spelled out, particularly around:

• critical thinking

• gender equality

• pleasure (in terms of girls’ self-knowledge, masturbation, sex, mutual sexual pleasure)

• LGBT identities and families

• sex positivity

• the impact of pornography

It is difficult to delineate the transition between Relationships Education and RSE when sex education is not compulsory in primary school. The differentiations among the national science curriculum, Relationships Education, RSE and Health Education are ambiguous.

There is possibly ambiguous overlap around stating:

• “Puberty should be covered in Health Education”

• that puberty and correct names for body parts should be covered in the national science curriculum

There is an evasiveness – in wording or intent – in citing “main external body parts” when some female genitalia, such as the vagina and clitoris, are internal.

Too much weight, deference and amplification is given to the vocal minority opposing RSE on religious grounds, and too much leeway is given to faith schools to teach according to their tenets.

Reinstate a key concept in the 2000 SRE Guidance: “Teachers and all those contributing to RSE are expected to work within an agreed values framework.”

We are required to set out in the regulations the circumstances in which a pupil (or a pupil below a specified age) is to be excused from receiving RSE or specified elements of it. The draft regulations provide that parents have a right to request that their child be withdrawn from sex education in RSE and that this request should be granted unless, or to the extent that the headteacher considers that it should not be. Taking into account the advice to schools on how headteachers should take this decision, in paragraphs 41-46, do you agree that this is an appropriate and workable option?

OUTSPOKEN SEX ED: Strongly disagree.

Sex education, starting from a young age, is vital for children’s development, safeguarding and mental health, especially as an antidote to pornography.

Parents’ wishes for their children to be prevented from learning about RSE topics should not override their children’s right to comprehensive sex education as set out in the UNCRC.

Parents should not be given the option of withdrawing children from RSE.

Rather than underscoring parents’ wish to withdraw their children from sex education, head teachers should use this guidance to reassure parents and:

• stress the disadvantages of children not receiving RSE with peers (as in the 2000 SRE Guidance)

• promote the benefits and protective/preventative aspects of RSE

• discuss the benefits of parental engagement

The use of the term “excused” softens the more forcible reality of being “withdrawn”. It evokes not only politeness but also the idea of shielding children from something unpleasant.

Reinstate the 2000 SRE Guidance stipulation around providing materials and resources: “The DfEE will offer schools a standard pack of information for parents who withdraw their children.”

Although parents have a responsibility as “sex educators” to their children, there is no way to assess or monitor the sex-education issues parents might discuss at home, or whether they will talk openly with their children

As outlined by the charity Brook, it is not feasible for schools to deliver RSE if children are opting back into RSE at staggered points throughout the year before they turn 16. We agree with the Brook proposal in which “schools are required to end the right of withdrawal from Easter of year 10 and to provide a programme of RSE during the course of that final term which would serve us revision for all students and a chance to catch up for students who have not participated in RSE to date. This would remove the logistical problems for schools, remove the need for children to pro-actively opt-in to RSE potentially against the wishes of their parents; and would ensure that most children will have received their entitlement to RSE and are all prepared for further study in year 11 and later.”

Do you have any other views on the draft regulations that you would like to share with the department?

OUTSPOKEN SEX ED: The new guidance is an ideal platform for setting out the benefits of sex education and RSE both as protective/preventative measures and as promoting physical health and mental wellbeing.

Sex education and RSE are powerful antidotes to the impact of pornography, the normalisation of “sexting”, the rise in child-on-child sexual abuse and the prevalence of sexual harassment – which is “the most common form of violence” and which “affects nearly every woman in the UK” (strikingly put forward in the October 2018 report from the Women and Equalities Committee, “Sexual harassment of women and girls in public places”).

LGBT-inclusive education must start from primary school so that children acquire knowledge, compassion and understanding about themselves and others.

To develop their curriculum, schools should be required to consult children and young people on their needs regarding sex-education and RSE content and skills and the timing of when they are taught – often it is too biological, too little and too late.

Critical thinking and raising awareness about respect and gender equality are vital forms of early intervention and ongoing prevention for combatting negative behaviour and attitudes.

Knowledge is power.

The new guidance should:

  1. focus on stage, not age – ie preparedness and timeliness

  2. emphasise skills development, not just knowledge and information

  3. focus less on marriage, and include marriage equality

This guidance should highlight the benefits of parental engagement in their children’s sex-education learning both at home – in terms of improving safeguarding, mental health and the parent-child connection – and in school, in terms of reinforcing the effective delivery of meaningful content.

Crucially missing is discussion of:

• children’s rights

• pornography

• consent

• pleasure

• critical thinking

• gender equality, norms, expectations, stereotyping

• sexual harassment

• sex positivity (including intimacy in the context of a loving relationship)

• neuroscience of the developing adolescent brain

In our digital world, the need for open communication around sex-education issues is increasingly urgent.

Tables (6-8) in section F of the draft assessment set out the assumptions we have made in estimating the cost burden for schools to implement the new requirements. Do you agree with our assumptions and the estimated additional costs to schools?

OUTSPOKEN SEX ED: Disagree.

Delivering high-quality RSE will need to go beyond a drop-down day and instead be integrated via a curriculum throughout the year and via a whole-school approach.

As pointed out by EVAW (End Violence Against Women), both investment in teacher training by qualified professionals and the delivery of Relationships Education and RSE – including cost implications such as key skills for responding to disclosure of abuse – will entail considerable funding.

Of concern is the “no annual recurring costs” estimate.

There should be an extensive list of recommendations around resources, including those cited as “free of charge”, so that schools can distinguish among them and select high-quality resources.

As pointed out by the Sex Education Forum, the government should commit to ring-fenced funding to support schools to develop high-quality RSE.

Are there any other cost burdens on schools, which you believe should be included in the regulatory impact assessment?

OUTSPOKEN SEX ED: As pointed out by Brook, there should be time and funding allocated so that school leadership is made aware of the need for high-quality RSE and so that teachers are given high-quality training. Consultation with experts (eg in gender-based violence or gang culture) should be factored in.

#relationshipsandsexeducationRSE #government #pornography #pleasure #consent

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