This will be welcomed by school leaders, who have been struggling without official guidance. 

KCSIE sets out the legal duties of schools and colleges in England to safeguard and promote the welfare of children under 18. This latest version will be finalised and come into operation in September 2026 following a consultation. 

Sex Matters welcomes the integration of this guidance into the statutory safeguarding framework. CEO Maya Forstater said:

“We welcome the news that the long-awaited guidance for schools on ‘gender-questioning children’ has been integrated into the statutory safeguarding framework. This is the right way to think about how to ensure the safeguarding and wellbeing of all children and young people in school. 

“Putting this guidance into the statutory framework makes clear that schools have the same legal duties towards all children, and it ensures that the guidance can be updated. 

“The guidance gives non-negotiable red lines for every school and every child: schools must know, record and be able to refer to each child’s sex, and must not allow any child to use opposite-sex toilets, changing rooms or dormitories on school trips. 

“However, schools are still being left with the dangerous idea that they can facilitate ‘social transition’ – which remains undefined – and that they should negotiate this on a case-by-case basis. 

“It should be clear by now that allowing children and parents to think that a child who starts their education recognised as being a girl can somehow graduate ‘as a boy’ or vice versa is a dangerous fairy tale that gives children unrealistic expectations that simply cannot be fulfilled.”

What does the guidance say?

The guidance says that schools should consider developing a policy on what to do when children request to socially transition, and should take a careful approach:

“Schools and colleges should consider whether pupils would be best supported by a policy on social transition which explains the steps that a school or college will go through when a child requests support. When considering any request for support with social transition, schools and colleges should ensure that their decision-making process is documented and records are kept.”

It also says that schools should always recognise that children’s best interests are paramount, and that this is not always the same as what the child wants:

“This means that the first step when considering a child’s request for support with social transition will be to consider what is in the best interests of the child and other children, and a decision relating to social transition may not be the same as a child’s wishes.”

The recommendation to adopt a clear policy is welcome and in line with the model policy approach proposed by Sex Matters. 

However, the guidance does not say what it means by the phrase “socially transition”. Sex Matters’ recommendation is that schools have clear policies on sex-based rules and record-keeping and that they should respond to children experiencing mental distress not with a “social transition” plan but with education and care plans which aim to ensure the child can continue to access education.

The guidance draws some bright lines, categorically ruling out many of the things a child seeking to “socially transition” might want: 

“Schools must not allow pupils into toilets, changing rooms, or boarding or residential accommodation designated for the opposite sex, with no exceptions. Similarly, where schools have implemented single-sex sports as being necessary for safety reasons, there should be no exceptions and pupils must not be allowed to participate in sports designated for the opposite sex.”

But it leaves the question of what it means by “social transition” vague and open to negotiation. It also anticipates that some children may attend school “in stealth”, with teachers and other pupils believing them to be the opposite sex. This is not consistent with safeguarding these children or their peers. 

Schools are being told that they should “always consider any clinical advice the family has received”, but the Department for Education has set no limits for clinicians or the NHS in this regard. It has failed to explain to them that children cannot expect to be treated as the opposite sex within a school setting. Dr Hilary Cass’s expert review focused on clinical decision-making, and did not consider decision-making by schools, or other children’s rights and welfare, and the government is pushing ahead with putting a new cohort of children on puberty blockers in the name of medical research.  

It is alarming that once again schools are being encouraged to take a “doctor knows best” approach, when doctors and medical researchers have been encouraging children and families to have unrealistic expectations of what can safely,  reasonably and lawfully be accommodated by schools. 

The KCSIE guidance consultation is open for 10 weeks and Sex Matters will be responding. 

The post Guidance released on “gender-questioning” children  appeared first on Sex Matters.

The Supreme Court’s judgment relates only to people with gender-recognition certificates (GRCs), who must be adults. But the Supreme Court confirmed what should have been obvious all along. Neither a certificate nor a strong wish to be the opposite sex or personal steps such as changing name, clothing or hairstyle, taking hormones or having cosmetic surgery can change a person’s sex. 

Children who are distressed about their sex should be protected from harm and from bullying. But if a child, their parents (or even their doctor) asks if the school can allow a child to use opposite-sex facilities and refer to them and treat them as if they were the opposite sex, the answer should always have been No. 

School leaders, teachers and school staff need to know, record and use information on every child’s sex. They cannot safely pretend that some children have changed sex. 

Policies adopted by local authorities such as Brighton and Hove City Council that are based on the idea that schools must try to avoid “outing” a child’s sex are unworkable and unlawful, and put children at risk. 

Our model policy enables a school to set out clearly why it needs to record and refer to each child’s sex, and then to say confidently:

As a school we follow the Equality Act 2010 , as clarified by the Supreme Court in 2025 and have also taken notice of the findings of the Cass Review. We welcome all children and young people, and we seek to provide an inclusive environment. We aim to act safely, effectively and compassionately to support all pupils to access education, pursue their interests, use the school facilities and participate in the life of the school.

As set out in this policy, we cannot safely or legally record or refer to a child as anything other than the sex that they are. The school cannot admit a child as if they were the opposite sex, agree to treat their sex as confidential or misrepresent their sex verbally or in writing. This would be incompatible with our legal obligations, behaviour policy and safeguarding, and would undermine the smooth running of the school and its ability to provide fair and safe access to education to all our pupils.

Official guidance for schools in England is expected from the Department for Education before pupils return in September. It should direct schools that they are not to pretend that people can change sex, because they are not keeping children safe if they do so. 

We have sent our updated model policy to the Secretary of State for Education, Bridget Phillipson MP.

Download our updated model policy:

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Our model policy largely aligns with the legal analysis produced by Karon Monaghan KC and the draft guidance produced by the Department for Education: schools should be clear that pupils are not allowed to use opposite-sex facilities, compete in opposite-sex sports, or attend opposite-sex RSHE or PSHE lessons – or to be admitted to a single-sex school on the basis of their “gender identity”. This is increasingly uncontroversial as a legal analysis, and it is expected that the government will finalise its guidance soon. 

But the question of “pronouns” is often seen as more of a grey area, and one where there may be legal challenges. While pupils may of course experiment with alternative pronouns in their friendship groups, the question is whether the school should require staff to use a pupil’s preferred pronouns and enforce a requirement for other pupils to use them too. 

 The draft DfE guidance says this should be rare, but it may happen:

“Agreeing to a child’s request to have others use different pronouns about them is a significant decision. Primary school aged children should not have different pronouns to their sex-based pronouns used about them. 

“For older children, schools do not need to specify pronouns to be used about each pupil and can decline a request to change a child’s pronouns… schools and colleges should only agree to a change of pronouns if they are confident that the benefit to the individual child outweighs the impact on the school community. It is expected that there will be very few occasions in which a school or college will be able to agree to a change of pronouns.”

Gender-ideology activist organisations say that this must be a matter of routine. They argue that the approach of the DfE’s draft guidance is unlawful.

Stonewall says:

“Not using a trans pupil’s chosen pronouns (no matter their age) could be considered discrimination or harassment under the Equality Act 2010 as noted in the example on page 65 of the EHRC’s Technical Guidance for Schools in England.”

Mermaids says that not allowing primary-age children to “change their pronouns” is egregious and that:

“Refusing to use new pronouns for a student could amount to unlawful discrimination if the trans student is treated less favourably because they are trans (e.g. consistently and intentionally being misgendered).

“A blanket policy on primary students’ inability to change their pronouns is likely to be unlawful discrimination. The guidance must therefore be amended to enable pronoun changes at all ages, and advise schools of the legal risks they face if they institute blanket policies to refuse pronoun changes.”

Our model policy does not present pronouns as a matter for negotiation at all. It deals with them as part of a coherent system of communication, along with other words like male/female and boy/girl. 

The model policy explains:

“Rules, routines and behavioural expectations are set out both in written policies and statements and in verbal instructions issued by teachers and other staff. We use consistent, clear sex-based language (boy/girl, male/female, he/she) in order to communicate expectations to all pupils, in line with our behaviour policy.”

And: 

“We will not consider requests to wear opposite-sex uniform, use opposite-sex toilets, showers or changing rooms, or participate in opposite-sex sports and other separate lessons, or for a pupil to be referred to by staff with opposite-sex language, since any of these will encourage the expectation that the status of the child’s sex, and requirement to follow sex-based rules, have changed or will change during their school career.”

Is it lawful for schools not to adopt pupils’ preferred pronouns? 

As Karon Monaghan sets out in her advice on the Brighton & Hove toolkit, the legal question is about indirect discrimination. Indirect discrimination is defined by Section 19 of the Equality Act: 

(1) A person (A) discriminates against another (B) if A applies to B a provision, criterion or practice which is discriminatory in relation to a relevant protected characteristic of B’s. 

(2) For the purposes of subsection (1), a provision, criterion or practice is discriminatory in relation to a relevant protected characteristic of B’s if—

1.  A applies, or would apply, it to persons with whom B does not share the characteristic,
2.  it puts, or would put, persons with whom B shares the characteristic at a particular disadvantage when compared with persons with whom B does not share it,
3.  it puts, or would put, B at that disadvantage, 
4. and A cannot show it to be a proportionate means of achieving a legitimate aim. 

That is, schools are allowed to have rules, but if those rules disadvantage pupils with particular protected characteristics, the school must be able to justify them as “a proportionate means of achieving a legitimate aim”. 

Monaghan says that compelling a teacher, a member of staff or another child to use a child’s chosen pronouns “may be uncomfortable, confusing and sometimes offensive” but that this must be balanced against the risk that “a persistent failure to use chosen pronouns may indirectly discriminate against trans identified children under the EqA and the Convention rights… in some circumstances”. 

She concludes that the question is more finely balanced than in the examples such as toilets, changing rooms and residential accommodation where the direct harm to others is clearer; it could go either way depending on the circumstances. She says that a school that has adopted a child’s preferred pronouns and has a “no misgendering rule” may find it relatively easy to overcome the hurdle of establishing that there is a legitimate aim for the practice (“trans inclusion”) which would justify the rule and overcome a gender-critical discrimination claim by a teacher. 

On the same day that Monaghan completed her advice, a judgment was delivered by an employment tribunal that supported her analysis. The case of Kevin Lister v Swindon New College concerns a maths teacher at an further-education college who had been dismissed after complaints that he refused to use a trans-identifying A-level student’s chosen name or preferred pronouns and instead “adopted a gender neutral communication style by gesturing”. He also gave unwanted advice and talked about a family member who had attempted to take their own life through an incident of alcohol misuse. He told another student that transition was a “disaster situation” and that the student would “ruin her life”. 

The school investigated the complaints, recognising the teacher’s right to hold and express gender-critical beliefs, but also the need to balance that against “the rights of trans-students to access education in an environment that was no less favourable than their peers and did not violate the[ir] dignity”. Lister’s claim of belief discrimination failed. 

That Lister’s conduct was judged to be unprofessional and not in line with the college’s policy does not mean that schools must in general have policies of adopting preferred pronouns (and other non-sex-based language). It is up to schools and colleges to consider and develop their policies in light of safeguarding and other obligations. 

A school that has adopted a standard policy of always using clear sex-based language would be able to argue that it has a legitimate aim (clear sex-based rules that support safeguarding and communicating expectations of behaviour). This could be used to overcome a gender-reassignment discrimination claim by a pupil unhappy that the school does not entertain pupils’ requests to be known by alternative pronouns. 

It is important for schools to understand (particularly in the continuing absence of clear government guidance) that there is no risk-free option in relation to sex-based language. A policy of using clear sex-based language may be challenged as indirectly discriminating against children with the protected characteristic of gender reassignment, and defended on the basis that it is a proportionate means of achieving legitimate aims relating to safeguarding and the clarity of rules and communication. But the enforcement of a policy of requiring teachers and other pupils to use preferred pronouns is certainly an interference requiring justification in those individuals’ article 10 rights, and may also amount to direct discrimination on grounds of gender-critical belief or unjustifiable indirect discrimination on grounds of gender-critical or religious belief.

What a school should not do is leave expectations unclear, fail to think through how language and rules relate, and leave it to individual pupils and teachers to negotiate conflicts informally.

What does the EHRC’s technical guidance say? 

Both Stonewall and Mermaids refer to the Equality and Human Rights Commission’s technical guidance on the Equality Act for schools to back up their argument that not adopting a child’s preferred pronouns is unlawful (they say it is direct discrimination). This is the example:

“A member of school staff repeatedly tells a transsexual pupil that ‘he’ should not dress like a girl and that ‘he’ looks silly, which causes the pupil great distress. This would not be covered by the harassment provisions, because it is related to gender reassignment, but could constitute direct discrimination on the grounds of gender reassignment.”

This vignette is not about “pronouns” but “unwanted conduct related to a protected characteristic”. The legal point it is illustrating is that harassment provisions relating to sexual orientation, gender reassignment and religion or belief in the Equality Act do not apply to pupils in school – but nevertheless unwanted conduct related to these characteristics resulting in a pupil suffering a disadvantage could be brought as a direct-discrimination claim. 

As we have pointed out before, this example is unhelpful and vague and we hope it will be updated by the EHRC. Repeatedly ridiculing a pupil as looking silly could indeed be direct discrimination. But teachers will often have to explain rules to pupils that are “unwanted” by the child, but not detrimental. 

It is necessary for teachers to use clear sex-based language and categories to explain and enforce rules such as “No boys in the girls changing rooms” or “That is not correct uniform; go home and change”. These rules may cause a child who wishes they were the opposite sex distress, but that is not direct discrimination. 

The DfE should produce a model policy that makes this clear – not leave the situation ambiguous, to be battled over by individual teachers and pupils in the classroom.

Read more about our model policy for schools, and why it’s needed

The post What about pronouns at school?  appeared first on Sex Matters.

Statutory safeguarding guidance says that schools should make sure that all staff are aware of issues that can put children at risk of harm, and be trained to spot and report indicators of abuse, neglect and exploitation, inside and outside the school and college, inside and outside home, and online, as well as mental-health problems. 

The previous Stonewall-influenced version of KCSIE said there were no such potential harms in relation to a child adopting a transgender identity. The new version of the statutory guidance, following the Cass Review, says:

“… caution is necessary for children questioning their gender as there remain many unknowns about the impact of social transition and children may well have wider vulnerabilities, including having complex mental health and psychosocial needs, and in some cases additional diagnoses of autism spectrum disorder and/or attention deficit hyperactivity disorder.” 

The new guidance points school leaders to the DfE guidance on gender-questioning children. This non-statutory guidance is still to be finalised, but the statutory safeguarding guidance now reflects its core message that schools should take a cautious approach and consider the broad range of a child’s individual needs, in partnership with the child’s parents (other than in the exceptionally rare circumstances where involving parents would constitute a significant risk of harm to the child), including any clinical advice that is available and how to address wider vulnerabilities.

Bayswater Support Group has published a useful analysis of safeguarding concerns, including: 

• overlooking and failing to address other issues
• likelihood that a student may take harmful physical steps to change their body
• exposure to inappropriate or inaccurate online information 
• adult influence and parental alienation.

Sex Matters’ model policy for schools has been developed to be in line with the new safeguarding statutory guidance. 

Gender-identity lobby groups condemn guidance

Transgender lobby groups including Stonewall, Mermaids, the Good Law Project, Gendered Intelligence and AllSorts condemned the cautious approach of the DfE guidance, saying that it “seeks to deny the existence of transgender pupils”, discourages them from “coming out and being their authentic selves”, and could lead to young people being “forcibly outed to parents and teachers”. 

A company that calls itself the “Family Planning Association” called for the Education Secretary to reverse the changes to KCSIE, saying: “The changes remove all reference to trans children” and “Teachers are asked to follow non-statutory, possibly discriminatory draft guidance”. But while the company bears the same name as the respected Family Planning Association charity, it turns out that it is a printing company in Derby that bought the charity’s assets when it went bust in 2019. It has continued to provide sex and relationship education materials to schools under the same brand. 

Stonewall itself has clearly seen the writing on the wall, and is trying to move its brand out of this dangerous territory. Over the summer it quietly announced it was closing down its Schools Champions programme and would not be offering training to schools any more. But while Stonewall has backed away from providing guidance to schools, it has signposted schools to organisations such as Diversity Role Models, Gendered Intelligence, Just Like Us, Mermaids and The Proud Trust.

Teenage activists at risk

Meanwhile the DfE has had a vivid doorstep demonstration of the safeguarding risk.

A group of teenagers spent several days camping outside the department’s London office, climbing its front wall in a protest calling for children to be enabled to socially transition in school and for puberty blockers to be prescribed on demand. The children spent their time colouring in paper coffins with ghoulish messages for the Health Secretary, Wes Streeting.

The group of mainly teenaged girls (“transmascs”) solicited £13,000 of donations online and was joined by several adult men identifying as “trans fems”, as well as other adults who responded to a public online invitation to come and watch over them while they slept. 

The 17-year-old organiser told Anti-Capitalist Resistance: 

“Very few of us are neurotypical; there are a lot of autistic people here.” 

The children wrote a letter saying they were advocating for their “very existence”.

The children’s protest was supported by several of their parents, as well as the Good Law Project, Trans Solidarity Alliance, Gendered Intelligence, Nancy Kelley (former CEO of Stonewall) and Susie Green (former CEO of Mermaids). 

This reckless activism by vulnerable teenagers is likely to continue in schools in the new term. The group says: 

“We’re planning on a big push to visit every school youth group in London and, as much as we can, every queer youth group in England or the UK.”

As well as the support of activist organisations, some of these children have parents who want them to live “in stealth” as the opposite sex; others want to be treated as the opposite sex at school without their parents knowing. 

Safeguarding lessons must be put into practice

Janice Turner wrote in The Times on Friday about how safeguarding can fail when a group is not subject to scrutiny. LGBT Youth Scotland supports the same campaigning messages promoting childhood transition as Stonewall, Mermaids and the children outside the DfE. It has strongly influenced the Scottish Government, and it continues to run a schools programme in primary schools as well as secondary schools in Scotland. 

The organisation received funding from BBC Children in Need for 14 years, even after its first chief executive, James Rennie, was convicted of sexually abusing a three-month-old baby. It finally lost funding only after it emerged that a co-author of its 2010 guidance for schools had been convicted of sharing indecent images of children as young as newborns and attempting to groom someone he thought was a 13-year-old boy online.

Safeguarding systems have been built up over years of lessons learned from the harrowing cases of child abuse, abuse of vulnerable adults and failures of care in schools, hospitals and residential homes. A key lesson is not to create a caste of people to whom ordinary rules and scrutiny do not apply. 

Lessons from previous inquiries into cases of abuse (such as the White Inquiry on children’s homes in Islington and the Warner Report on abuse in children’s homes in Leicestershire) have highlighted how a politicised and simplistic approach to equal opportunities led children’s services to employ people who were not safe to work with children, and to look away when those people practised outlandish and unevidenced “therapies” that enabled abuse.

Safeguarding systems are founded on risk assessment, transparency, candour, professional curiosity and reflective practice. None of this is possible when you pretend some boys are girls and some girls are boys, or that adult men (including those with a sexual paraphilia for cross-dressing) are women. The biggest risk factor for sexual offending is being male. 

Safeguarding is also impossible when those who speak up about it are attacked as “bigots”, and made to fear for their livelihoods. Turner said she spoke to a gay man who had worked at Stonewall in the early 2000s producing materials for schools. The guide for primary schools said little more than that gay families exist; the one for secondary kids was about emerging teenage sexuality. But there was a mix-up and some secondary guides went to primaries. Aghast, this man offered to resign; the materials were retrieved with apologies. A gay charity dreaded being accused of sexualising children. Now, he thinks, it wouldn’t care, because no one would dare point a finger.

Read more about our model policy for schools

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Sex Matters has been calling for the Department for Education to produce a simple, straightforward model policy that schools can adopt, to be confident of giving safe and lawful answers which protect the wellbeing of all children.

Today we are publishing our model policy, which is aligned to safeguarding legislation, the Cass Review, the Equality Act 2010 and the DfE draft guidance.

Our policy is a whole-school model policy that concerns how a school records, communicates and uses data and language on the sex of all pupils, and how it can make sure that where it has policies that treat girls and boys differently it does so fairly and lawfully.

The model policy provides answers to questions from pupils and parents who want the school to bend those rules and routines for a child who is experiencing gender-related distress or who identifies as transgender. 

It is designed to help school and college leaders be confident that their approach supports robust safeguarding and does not subject any child to unlawful discrimination or harassment under the Equality Act 2010. The basic approach is to:

• treat all pupils with compassion and respect

• communicate sex-based rules and policies that protect the wellbeing of all pupils

• be clear that these rules apply to all pupils for the whole time they are at school.

It includes specific policies for areas such as changing rooms, sports and uniforms and emphasises that schools use clear sex-based language in order to be clear about rules that apply to girls and boys.

We hope the model policy will be useful to school leaders who are facing demands from activist groups, and will encourage the DfE to produce its own clear, straightforward model policy for schools.

Read more about our model policy for schools

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We agree that the DfE guidance is helpful and that it should be strengthened with a clear explanation of the law. We recommend that the DfE publish a model policy for schools backed by legal analysis. 

But the EHRC in its response gets the law wrong. As it is the nation’s equality watchdog, this is very concerning. We have published a detailed analysis:

Safeguarding comes first

The EHRC goes wrong by losing sight of the primary responsibility of school leaders, which is to keep children safe and to educate them. It becomes too focused on the legal possibility of indirect discrimination based on the protected characteristic of “gender reassignment” and forgets about the direct discrimination that would be involved in exempting children from the rules and policies designed to safeguard them.

The basic principles in relation to the protected characteristics of sex and gender reassignment and schools are:

• Mixed schools have sex-based rules and policies (that is, where girls and boys are treated differently) only where the rules are justified, most often for reasons of safeguarding, safety, dignity or fairness. Exempting a child from safeguards because they declare themselves to be transgender would be direct discrimination.
• Single-sex schools are expressly allowed by the Equality Act. There is no need to further justify why an individual child of the opposite sex will not be admitted. 
• A boy who may have the protected characteristic of gender reassignment should not be excluded from provisions or facilities for boys. 
• A girl who may have the protected characteristic of gender reassignment should not be excluded from provisions or facilities for girls.
• A child who may have the protected characteristic of gender reassignment should not be treated differently with regard to safeguarding and risk. This requires that nobody is made confused about their sex.

Our analysis covers each of the areas where these principles apply (including sports, toilets and changing rooms, uniform) but here we focus on pronouns, which is where confusion often sets in.

Pronouns 

Personal pronouns (he/ she) are words that relate to a person’s sex. There are no laws about pronouns, but as part of their job of keeping children safe, and enforcing clear behaviour policies schools need to know and refer to children’s sex routinely and accurately. Using the wrong sex pronoun for a child – calling a girl “he” or a boy “she” – is likely to confuse people about that child’s sex and the rules that apply to them. There is no human right that requires a school to keep a child’s sex private in school. 

In 2019 the EHRC published draft guidelines for schools that said: 

“If a pupil has legally changed their name, then the school must use the pupil’s new name and relevant pronoun.”

This guidance was never completed; many organisations raised objections to it and the draft was withdrawn. 

In 2023 the EHRC reviewed its general guidance for schools on the Equality Act published in 2014. This included a section that said of a female pupil wishing to “live as a boy”:

“Not referring to this pupil as a boy would also result in direct gender reassignment discrimination.”

It is not “direct gender reassignment discrimination” not to refer to a girl as a boy, and EHRC removed that section. Baroness Kishwer Falkner, chair of the EHRC, said: “We have now revised some areas to ensure the guidance is legally correct.”

However, in its response to the DfE consultation published last week, the EHRC again suggests that a school might agree to refer to a boy with language that relates to girls, and vice versa (indeed it suggests that it should be as routine as a change of name):

“Once a decision has been taken to recognise a change of name or pronouns it should be implemented consistently within the school… our recommended approach regarding requests to change a child’s pronouns is similar to that in respect of name changes.”

Any child can change their name. But a boy cannot change into a girl or a girl into a boy. “Changing a child’s pronouns” is a euphemism for using language that suggests the child is no longer a boy or a girl, and should be treated as being the opposite sex, or neither. This is not compatible with referring to a child’s sex accurately. 

The policy of referring accurately to each child’s sex is justified by the need for everyone in school to understand the rules that apply to them in order to keep all the children safe and treat them fairly. These are rules that both DfE and the EHRC agree are lawful and justified.

For a policy to be indirect discrimination there must be a detriment. Children often have to be refused things that they want, in their own best interests. This is why schools have rules and behaviour policies. Refusing to indulge a child’s wish for something that would undermine their safety is not a detriment.

The EHRC should recall this response to the guidance and reconsider it. 

As Sex Matters wrote to the EHRC in November 2023, there is a critical gap in the EHRC’s governance manual: it does not mention safeguarding or include a process for due diligence on safeguarding in its recommendations and guidance. If the EHRC had a safeguarding due-diligence policy it would have assessed this recommendation against it and recognised that they were not compatible. 

The EHRC should have a published safeguarding policy, and a process for assessing the safeguarding implications of the guidance and recommendations it produces.

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