Our Duty is broadly supportive of the new Statutory Guidance for RSHE published for consultation.
https://consult.education.gov.uk/rshe-team/review-of-the-rshe-statutory-guidance
The consultation closed on 11th July 2024
Our response is italicised below.
The first ten questions are around describing you or your organisation. The substantive consultation questions start with Question 11.
Review Timetable
11 Do you agree that we move away from a rigid commitment to review the guidance every three years?
No
Structure of the guidance
12 Do you agree that the changes to length and style of the guide make the guidance easier to understand and follow?
Yes
Schools’ relationships and sex education policies
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?
No
14 If you would like to explain your answer, please do so here. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Curriculum materials must be made available to any interested party (not just parents).
15 Do you agree with our proposed approach to increased transparency on RSHE material?
No
16 If you would like to offer any comments to explain your answer, please do so here. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Curriculum materials must be made available to any interested party (not just parents). Age limits on teaching certain subjects
Flexibility for age limits
17 Do you think this flexibility is sufficient to ensure that pupils are adequately safeguarded?
Yes
18 Do you think this flexibility is warranted?
Yes
19 If you would like to explain your answer to questions 17 or 18, please do so here Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Sexual orientation
20 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)?
No
21 If you have any comments to explain your answer, please do so here. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Transgender topics do not belong with Lesbian, Gay and Bisexual topics. LGB is a harmless and natural development possibility whereas transgenderism is an unnatural product of malign, external influences.
Gender reassignment
22 Do you agree with the proposed changes related to gender identity and gender reassignment in the guidance?
Yes
23 If you have any comments to explain your answer, please do so here: Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
It is important that the point is made that discussing gender identity such theories with pupils could prompt some pupils to start to question their gender. This recognition that giving legitimacy to a disputed concept in an educational setting should highlight the unfortunate accident of ‘gender reassignment’ being a protected characteristic in the Equality Act – it does not belong there.
Addressing prejudice, harassment and sexual violence
24 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?
Yes
25 If you would like to explain your answer, please do so here. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Primary sex education
26 Do you agree with the restriction on teaching sex education only in years 5 or 6?
Yes
27 If you would like to make any comments to explain your answer, please do so here. It would be helpful if you could share your own views on appropriate age limits for this topic, for example if you think they are too low or too high. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
It is crucial that society guards against the premature sexualisation of children. Consequently, sex education in primary school should normally consist only of the basic biology of puberty (where girls might need more detail given the timing of menarche) and mammalian reproduction.
Secondary topics: Online and Media, Respectful Relationships, including friendships, and Being Safe
28 What constitutes harmful sexual behaviour and why, and that such behaviour is unacceptable, emphasising that it is never the fault of the person experiencing it. This should not be taught before year 7. Do you agree with this age limit?
Yes
29 We have placed an age limit on the following content in the secondary Respectful Relationships, including Friendships topic: That some types of behaviour, including within relationships, are criminal, including violent behaviour and emotional abuse, such as controlling or coercive behaviour. Schools should not, however, teach about the details of violent abuse before year 9 as it is important that pupils are not introduced to distressing concepts when they are too young to understand them. Do you agree with this age limit?
Yes
30 We have placed an age limit on the following content in the secondary Online and Media topic: About circulating images and information and how to safely report to trusted adults the non-consensual creation or distribution of an intimate image. Pupils should understand that making, keeping or sending naked or sexual images of someone under 18 is a crime, even if the photo is of themselves or of someone who has consented, and even if the image was created by the child and/or using AI generated imagery. Pupils should understand the potentially serious consequences of asking for naked, semi-naked or sexual images, including the potential for criminal charges and severe penalties including imprisonment. This topic should not be taught before year 7. Do you agree with this age limit?
Yes
31 We have placed an age limit on the following content in the secondary Online and Media topic: The impact of viewing harmful content, including pornography, that presents a distorted picture of sexual behaviours, can damage the way people see themselves in relation to others, and can negatively affect how they behave towards sexual partners. This can affect pupils who see pornographic content accidentally as well as those who see it deliberately. The risks of inappropriate online content can be discussed in an age-appropriate way from year 7, however, the details of the sexual acts in question should not be discussed before year 9. Do you agree with this age limit?
Yes
32 We have placed an age limit on the following content in the secondary Being Safe topic: The concepts and laws relating to harmful sexual behaviour, including sexual harassment, revenge porn, upskirting and taking/sharing intimate sexual photographs without consent, public sexual harassment, and unsolicited sexual language / attention / touching. This should not be taught before year 7. Do you agree with this age limit?
Yes
33 We have placed an age limit on the following content in the secondary Being Safe topic: The concepts and laws relating to sexual exploitation, grooming, stalking, and forced marriage. This should not be taught before year 7. Do you agree with this age limit?
Yes
34 We have placed an age limit on the following content in the secondary Being Safe topic: The concept and laws relating to sexual violence, including rape and sexual assault. Whilst it’s important for pupils to understand the key principles around sexual offences and violence, for example the importance of understanding what consent means, schools should not teach about this in any sexually explicit way before year 9. Do you agree with this age limit?
Yes
35 We have placed an age limit on the following content in the secondary Being Safe topic: The physical and emotional damage which can be caused by female genital mutilation (FGM), virginity testing and hymenoplasty, where to find support, and the law around these areas. This should include that it is a criminal offence to perform or assist in the performance of FGM, virginity testing or hymenoplasty, or fail to protect a person under 16 for whom someone is responsible from FGM, or to take girls who are UK nationals abroad for FGM, regardless of whether it is lawful in that country. This should not be taught before year 9, except for where schools have identified a greater risk of FGM at an earlier age or have pupils who have been affected by FGM and need support. Do you agree with this age limit?
Yes
36 We have placed an age limit on the following content in the secondary Being Safe topic: The concepts and laws relating to domestic abuse including controlling or coercive behaviour, emotional, sexual, economic or physical abuse, and violent or threatening behaviour. Schools should not teach about the details of violent abuse before year 9 as it is important that pupils are not introduced to distressing concepts when they are too young to understand them.Do you agree with this age limit?
Yes
37 If you would like to offer any comments about the age restrictions in the secondary Online and Media, Respectful Relationships, including Friendships, and Being Safe topics please do so here. It would be helpful if you could share your own views on appropriate age limits for these topics, for example if you think they are too low or too high. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
These age limits are very likely too low for some communities and, as suggested in the guidance, might be too high for others. Nevertheless, as a general principle they seem about right. The health of a community might be measured by how late its schools can leave teaching some of these subjects. Consequently, discretion in delay ought to be encouraged where it is appropriate. i.e. reiterate the point that these are lower limits and not targets.
Secondary topic: Intimate and sexual relationships, including sexual health
38 Do you agree with the age restriction on the secondary intimate and sexual relationships, including sexual health topic?
Yes
39 If you would like to offer any comments about this age restriction, please do so here. It would be helpful if you could share your own views on appropriate age limits for these topics, for example if you think they are too low or too high. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Discretion in delay ought to be encouraged where it is appropriate. i.e. reiterate the point that these are lower limits and not targets.
Health and wellbeing
40 Why social media, some apps, computer games and online gaming, including gambling sites, are age restricted. This should not be taught before year 3. Do you agree with this age limit?
Yes
41 We have placed an age limit on the following content in the primary Online Safety and Harms topic within health education: The risks relating to online gaming, video game monetisation, scams, fraud and other financial harms, and that gaming can become addictive. This should not be taught before year 3. Do you agree with this age limit?
Yes
42 We have placed an age restriction on the whole of the primary Developing Bodies topic within health education. This should not be taught before year 4. This covers; growth, change and the changing adolescent body, this topic should include the human lifecycle. Puberty should be mentioned as a stage in this process; the key facts about the menstrual cycle, including physical and emotional changes.Do you agree with this age limit?
Yes
43 The secondary Health and Wellbeing topic is now clear that, given the sensitivity and complexity of content on suicide prevention, direct references to suicide should not be made before year 8. (Note that there is more detail on suicide prevention content in the curriculum provided in the ‘Suicide Prevention’ section shortly). Do you agree with this age limit?
Yes
44 If you would like to offer any comments about these age restrictions, please do so here. It would be helpful if you could share your own views on appropriate age limits for these topics, for example if you think they are too low or too high. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Health and wellbeing
45 Do you agree with changes to the Health and Wellbeing section of the guidance?
No
46 If you would like to offer any comments to explain your answer, please do so here. Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
The general gist of the Health and Wellbeing guidance is sound. However, it could be improved by highlighting the importance of, and hence teaching that will lead to, resilience, self-worth, self-respect, honesty, integrity, courage, kindness, and trustworthiness. Or put another way, prevention is better than cure: a school that needs a mental health worker is an unsafe, failing school.
Suicide prevention
47 Do you agree with the proposals on suicide prevention as set out above?
No
48 If you would like to offer any comments to explain your answer, please do so here Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
Suicidal ideation is known to be one of many socially transmitted harmful ideations in adolescence. All these harmful ideations, including self-harm, eating disorders, transgenderism, and suicide, become more prevalent when they are discussed by adolescents. Consequently, extreme care must be taken to contextualise any such discussions appropriately. As a general rule, discussions of socially transmitted harmful ideations are best avoided, and when necessary, limited to the affected parties.
Additional topics
49 Do you agree with this additional content?
No
50 If you have any comments to explain your answer, please do so here Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
The majority of these additional topics would seem to be those that could be dealt with on an ‘as and when relevant’ basis. Perhaps separate briefing papers for education staff would be a more appropriate approach to take to avoid making the statutory guidance too long and potentially irrelevant.
Exceptions would be ‘Personal safety, including road, railway and water safety’ and ‘Vaping’ (to which Smoking could be added). Both these topics apply to all children everywhere and so merit inclusion.
When teaching children about RSHE it is best to focus on those aspects that students can take personal responsibility for at their age (even if all they can do is tell a grown-up). Subjects that are outside their locus of control are best left to adults, or at least until they arise in GCSE curricula. Teaching children about threats to their safety that they have no mechanism for countering will introduce anxieties and hence be detriments to their mental health.
General comments
51 Is there anything else in the draft statutory guidance that you would like to comment on? Please try to limit your response to under 250 words. Please do not add any details which may easily identify you or your organisation. :
The guidance includes the following in its opening paragraphs: “High quality, evidence-based teaching of relationships, sex and health education (RSHE) can help prepare pupils for the opportunities and responsibilities of adult life, and can promote pupils’ moral, social, cultural, mental and physical development. Effective teaching will support young people to cultivate positive character traits, including resilience, self-worth, self-respect, honesty, integrity, courage, kindness, and trustworthiness.” To these, perhaps we could add a moral framework, knowledge of how to determine right from wrong, ethics and a sense of justice; and replace ‘kindness’ with consideration for others. With these noble aims clearly defined, we could then examine ways in which curricula can empower students to develop these positive character traits in the round. Doing so would equip them to be resilient to the next harmful fad that arrives before it can take hold, and to other unexpected events too uncommon to specify in teaching materials.
In summary – build resilience – and embed that aim in every aspect of RSHE. Develop measures for wellbeing, and build an evidence base for what works and what does not.
