TransActual and the Feminist Gender Equality Network (FGEN) today rejected the conclusion of a report on data collection by academic Prof Alice Sullivan as biased, inadequate and potentially harmful to all citizens of the UK, whether trans or not.
Calling on the Secretary of State for the Department of Science, Innovation and Technology (DSIT) Peter Kyle MP to reject this report, TransActual’s Strategy Director Keyne Walker said: “These recommendations would do nothing to support the Government’s stated objectives regarding equality and diversity nor on data use. It represents a deviation from the Government’s stated position, and would be a u-turn should it be implemented.
“Worse, the experience of those working in the field suggests that far from improving data quality, the measures promoted by this report would make data collected on sex and gender far less reliable.”
The Sullivan Review is rooted in factually incorrect assertions about the binary nature of sex and gender and antipathy towards trans people despite lip-service towards respect for diverse gender identities.
The Review’s recommendation for both sex and gender characteristics to be collected is presented as in the interest of the welfare of trans people. However the recommendations would effectively mean that trans people have no right to privacy, likely breaching human rights law, as well as codifying the incorrect dog-whistle assertion that sex is binary and immutable.
Despite its claims of impartiality, it was produced by leading members of an anti-trans campaign group and reflects their arguments.
As such, it is an unsuitable basis for policymaking and we encourage DSIT to reject its findings entirely.
Bias
The biased nature of this review was already clear. Not just from the leading questions used by the survey which presuppose that gender diversity and those researchers engaged in work to understand it are part of a sinister plot to silence and abuse ‘gender critical feminists’. But also from the way that Sullivan was commissioned by Michelle Donelan, then Conservative Secretary of State for DSIT, who then refused to answer any basic questions about the review’s ethics application.
The most clear sign of bias however is the choice of lead author. Prof. Alice Sullivan is a prominent anti-trans activist and advisory group member of the leading anti-trans lobby group, Sex Matters, notable for her work on UK literacy. The report also contains legal advice written by the husband of the Chair of the Sex Matters’ Trustee Board, Naomi Cunningham, and research was commissioned for the review to an organisation led by fellow member of the Sex Matters’ advisory group Lucy Hunter Blackburn. There is no evidence of the involvement of any trans person in the conducting of this analysis.
Harmful
Implementing the Sullivan Review’s recommendations would do significant harm to all people, whether trans or not. It would also undermine the government’s aim of delivering a functional cross-agency data system. To be functional, data used by government and organisations must reflect people’s lived realities. This includes gender and in some contexts, such as in medicine, assigned sex at birth and trans status.
As we previously set out in a letter to SoS for DSIT Peter Kyle MP , data collection of this nature would be unproductive. It would be harmful to the maintenance of accurate datasets and data processing, and looks very much like an attempt to redefine settled law regarding gender and equalities and it would likely result in breaches of human rights law and GDPR. It is also likely to discourage trans people from participating in research and responding to surveys, including the census.
This Review is providing an academic gloss on what is a political call to strip trans people of our hard-won rights to privacy, dignity, and respect in public spaces.
Government response
The current DSIT ministerial team led by Peter Kyle MP now have a choice to make. So far they have been clear that similar policies “would be an unjustifiable invasion of people’s privacy” and possibly incompatible with human rights law. Now they must clearly reject the previous government’s culture-war approach to data and the anti-trans movement’s lobbying attempts by publicly disregarding the recommendations of this report and engaging with feminist LGBTQ+ organisations and people with lived experience in their approach to new data standards surrounding sex and gender.
Dr Kevin Guyan, Chancellor’s Fellow at the University of Edinburgh and Director of the Gender + Sexuality Data Lab, said: “The Review of Data, Statistics and Research on Sex and Gender is a hangover from the former Tory government’s mission to address ‘wokeism in science’.
“Led by prominent ‘gender critical’ academic Professor Alice Sullivan, with research conducted by ‘gender critical’ campaign group Murray Blackburn Mackenzie, the Review – unsurprisingly – recommends that all research and data exercises (in all contexts) should ask a binary question about ‘biological sex’.
“This catch-all approach to data collection goes against a fundamental principle of research design: methods should be chosen based on the specific question(s) under investigation.
“The Review’s similarities to what is currently unfolding in the USA are stark. DSIT, the UK Government, researchers, funders and public bodies need to recognise this Trumpian intervention for what it is: an attempt to erase trans and non-binary people from existing in data.”
Further information
TransActual are working towards a world where trans people can live safely, in dignity and with access to the healthcare that we need. We’re a national, trans led and run organisation founded in 2017. TransActual works for trans people in the UK across politics, healthcare provision and providing community resources.