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Our submissions

As part of our advocacy work, we will submit consultation responses wherever possible, using the lived experience and testimony of our service users. Here you will find links to our responses so you can see exactly what we are asking government and public bodies to do to advance the rights of trans young people in this country.

  • Ban Conversion Therapy Consultation: Mermaids’ Response

    Key points from our response: 

    1.We urged the Government to ban “conversion therapy” in all forms, in all settings and protect people of all ages, to ensure the harms against LGBTQIA+ people through conversion practices do not continue.

    2. We further encouraged the Government to invest in wider social awareness raising and education around the nature of “conversion therapy” and the harm it causes.

    3. We support the Government’s proposal to address physical acts of “conversion therapy”, but have raised concerns around whether the criminal law will be effective tackling conversion practices. To address these concerns, we recommended a civil-criminal hybrid system alongside encouraging the Government implements a wider social education initiative to help deter perpetrators of conversion practices through awareness raising.

    4. We welcomed the Government’s proposals to also address non-physical forms of ‘conversion therapy’, but have identified specific areas of concern that the Government must address

    • The Government must remove the “consent loophole” for those victims/survivors aged 18 or over to ensure this ban does not exclude anyone from accessing support and justice – you cannot consent to abuse.
    • The Government must include conversion practices which take the form of casual conversion, private prayer and other non-physical acts within the ban for it to be fully effective.
    • The ban must include within its definition of “conversion therapy” acts which attempt to “cure”, change and/or suppress someone’s sexual orientation and/or gender identity.
    • The ban must protect all those within the LGBTQIA+ community.
    • The ban must explicitly state that safe and supportive therapies are not considered conversion practices.
    • Lastly, the Government must clarify how this ban will apply in religious settings.

    5. There is currently a large gap in the provision for survivors of conversion practices, which the Government must urgently address by closing the gap. We recommended ways in which the Government can do so:

    •  Introduce statutory provision of publicly funded support for current and historical survivors of conversion practices.
    • Community outreach and education which includes wide-ranging education around LGBTQIA+ inclusivity to tackle homophobia, biphobia and transphobia which underlies conversion practices.
    • Specialist safeguarding training for professionals to support them in better recognising conversion practices so that they are able to better support survivors of conversion practices.

    6. While we welcome the Government’s proposal to introduce ‘Conversion Therapy Protection Orders’ we encourage the Government to introduce further forms of support outside of criminal sanctions and protection orders.

    7. We strongly believe current statutory bodies, such as the police, CPS and others are providing both inadequate action against perpetrators of conversion practices and inadequate support for victims and survivors of conversion practices. We recommend that statutory guidance and training is desperately needed for these services to address their current inadequacy.

    8. While these statutory bodies can do so much more to support victims and survivors of conversion practices, we believe the Government should also focus on other avenues and other bodies to provide support for survivors. For example, by providing financial support, housing support, medical and psychological care and support and education to wider society. We have encouraged the Government to introduce a truly holistic package of support, both to upskill statutory bodies such as the police, but also to fund other areas of equally important support for victims and survivors of conversion practices.

    Read our full response, which was submitted on Monday 17 January 2022, here.

  • The Elections Bill 2021 (Voter ID) inquiry

    What’s the inquiry about?

    The UK Government’s plans to introduce a mandatory requirement for voters to provide photo identification documents (ID)

    The key points from Mermaids’ response:

    • We are really concerned that the introduction of a voter ID may indirectly disenfranchise many marginalised communities, including the trans community.

    • This concern arises from that fact that although many trans people don’t have a form of ID they are comfortable with using and therefore many not apply to register as a voter.

    • Ultimately many trans people will be faced with a question: do I ‘out’ myself in order to vote, or not vote at all? This question, either way, infringes on an individual’s rights, namely, an individual’s right to privacy, as well as the right to vote. We are also worried about the increased risk of discrimination and harassment this may introduce.

    •We also flagged that the UK does not legally recognise non-binary people, and therefore non-binary people are unable to access official ID which aligns with their gender identity, which will deter some from voting.

    Statistics show that electoral fraud in the UK is almost non-existent and therefore does not outweigh the adverse impact the voter ID process will have on marginalised voters, such as trans people, people of colour and others who will be disproportionately impacted.

    You can access a copy of our full response, which we submitted on the 31st August 2021, below:

    The Elections Bill Inquiry – Mermaids Response – 31Aug21

  • The ‘Women’s Health Strategy’ Inquiry

    What’s the inquiry about?

    The UK Government sought the publics views to help inform the development of the government’s strategy around women’s health.

    The key points from Mermaids’ response:

    •  We called for this Strategy to be fully trans inclusive.

    •  We called for this Strategy to be inclusive of the experiences of those who do not identify as a woman, but whose experiences will resonate with the topics listed within the call for evidence.

    •  We recommended the Government introduce appropriate and comprehensive trans (including non-binary) awareness training for generalised medical professionals.

    •  We called for more funding for gender-specialist healthcare services and decentralisation of gender-affirmative care and treatment.

    •  We stressed the importance of more accessible and gender-affirming mental health support for trans young people.

    •  We highlighted the huge gap in research undertaken and data collected around trans young people’s experiences of health care and accessing healthcare in the UK. Especially, trans young people who belong in other marginalised groups, for example, Black, Asian and other racialized trans young people, disabled trans young people and those from poorer communities and areas.

    •  We urged the Government to support LGBTQ+ charities and organisations, many of which are under-funded and under-supported.

    You can access a copy of our full response, which we submitted on the 30th May 2021, below:

    Women’s Health Strategy – Mermaids Response – 250521

  • The Home Office’s ‘Violence Against Women and Girls (VAWG) Call for Evidence’ Inquiry

    (Content Warning – this submission contains reference to violence and abuse against women)

    What’s the inquiry about?

    The UK Government sought the public’s views to help inform the development of the government’s next strategy around ‘Tackling Violence Against Women and Girls’

    The key points from Mermaids’ response:

    •  Our submission discusses the wider societal transphobia and misogyny which leads to high rates of violence against trans women and girls.

    •  We looked to the US context where the Human Rights Commission has called violence against trans people, especially trans women of colour an ‘epidemic’.

    •  We looked to the UK context in which Safe Lives 2018 states that not only are trans people the most at risk of sexual abuse of the LGBTQ+ community, trans survivors of domestic abuse are one of the most hidden groups of domestic abuse survivors.

    •  We discuss how the toxic discourse around trans lives in mainstream media currently in the UK has created within the domestic and sexual violence sector, a ‘hostile landscape to navigate for trans survivors of sexual violence…’ (Gal-Dem, 2021).

    You can access a copy of our full response, which we submitted on the 25th March 2021, below, which includes our recommendations to the Government:

    Violence Against Women and Girls Strategy Inquiry – Mermaids Response – 240321

  • The Health and Social Care Select Committee’s ‘Children and young people’s mental health’ inquiry

    What’s the inquiry about?

    The UK Government asked the public’s thoughts on the government’s ‘progress’ in improving provision for children and young people’s mental health support.

    The key points from Mermaids’ response:

    •  Many schools do not offer trans young people affirmative support. We recommended that the Government produce national trans inclusion and wellbeing guidance for schools to educate and empower teachers to become trans inclusive.

    •  We know that gender-affirmative healthcare for many trans young people is inaccessible and/or severely delayed. We also see that the current inaccessibility of mental health support means that rather than alleviating issues, many young people’s mental ill health is elongated.

    •  We recommended that the Government ensure that generalised mental health and medical professionals are educated and trained to ensure they’re aware of how to best support trans young people and to decentralise gender-affirmative care.

    •  We recommend for there to be specific training and awareness on non-binary identities to combat the binary restrictions when accessing gender-affirming care, and to avoid perpetuating harmful gender stereotypes that act as barriers to young people accessing care.

    •  Lastly, we discussed the open hostility towards trans young people in mainstream media, which acts to influence wider society, and the detrimental impact this has on young people’s mental health.

    You can access a copy of our full response, which we submitted on the 26th February 2021, below:

    Children and Young People’s Mental Health Inquiry – Mermaids response – 260221

  • Toilet Provision For Men and Women: Call for Evidence

    Here are the key points we made in our submission to the Government’s inquiry:

    •  Trans young people are not made to feel welcome, or even safe when using toilet facilities. It is unacceptable that any child should be made to feel this way.

    •  All children, including those who are Trans, should be able to access the toilet that makes them feel respected and affirmed. We want a future whereby every young person can choose a toilet with freedom and autonomy; for some this would be a gender-neutral toilet and for others it would be a gender-specific toilet.

    •  In order to ensure ‘everyone is served fairly’, and that everyone can feel comfortable using public toilet facilities, not only are gender-specific facilities in which trans people can feel safe in using vital, but gender-neutral facilities are also greatly necessary to ensure non-binary people’s experiences with toilet facilities are one of comfort.

    •  We strongly advocate for toilet facilities where everyone can feel comfortable, and safe, and this means: fully private cubicles with ‘full’ doors, a larger proportion of cubicles over urinals, single-accessible toilets, if the premises allow it and sanitary bins in all toilet facilities.

    •   We urge the government, in their effort to ‘ensure that everyone is fairly served’ and that ‘different voices are heard’, to speak with trans, non-binary and gender-diverse young people directly.

    You can access a copy of our full response, which we submitted on the 29th January 2021, below:

    Toilet Provision Inquiry Submission – Mermaids – 2902021

  • The Women and Equalities Select Committees’ ‘Reform of the Gender Recognition Act (GRA)’ public inquiry

    What’s the inquiry about?

    The WESC is reviewing the Government’s work around the GRA and trans equality generally

    The key points from Mermaids’ response:

    •The Government’s response to the GRA consultation for England and Wales didn’t go far enough.

    • We strongly believe that the legal process for gender recognition should be based on self-determination, and therefore the following current requirements should be removed:

    • Mandatory age of 18 years old;

    • A ‘binary-only’ system i.e. it needs to be non-binary inclusive;

    • A diagnosis of gender dysphoria, which stigmatises trans lives;

    • For individuals to have lived in their ‘acquired’ gender for at least two years’, as this creates an unnecessary and arbitrary barrier;

    • The ‘spousal veto’, or spousal consent provision which violates trans people’s right to a private life, and may leave trans people at risk of abuse and coercive control.

    You can access a copy of our full response, which we submitted on the 27th November 2020, below:

    WESC GRA Inquiry – Mermaids Response – 261120

  • Submission to the Universal Periodic Review (UN Human Rights Council) 4th Cycle

    What’s the inquiry about?

    • During the III Universal Periodic Review (UPR) Cycle, the United Kingdom received 3 recommendations regarding SOGIESC issues. (134.125, 134.124 and 134.84). It has accepted only one recommendation:(134.84) addressing fighting negative stereotypes in the media against minorities, including LGBTI persons. It can be concluded that there was a lack of attention given to SOGIESC issues in the UK during the last review and a failure to implement 2 of the 3 recommendations this Council made.
    • The human rights situation for LGBTQI people in the United Kingdom has deteriorated significantly since the last cycle (2017-2022), especially in relation to the rights of trans persons.
    • As we make this submission in 2022, we draw the urgent attention of the Council to the daily evidence we receive that trans young people face a litany of abuses and discrimination. They are denied the right to access timely healthcare, are casually harassed within our schools and by the media without consistent challenge, their right to privacy is violated when they are outed without consent to ‘protect others’, their right to access facilities without discrimination is violated as they are ostracised and made to feel unsafe for using a toilet, and, they are told they are a risk to others if they want to play a sport.

     

    Submission to the Universal Periodic Review (UN Human Rights Council) 4th Cycle

What do we mean by public consultations or inquiries?

The Government and public bodies will often publish a “consultation”, “inquiry’ or call for evidence on a specific topic, to hear directly from the public to ensure that any policy that is developed is informed by those who either have lived experience, support those who do (like Mermaids!) or who are knowledgeable about that topic. The insight they gather from people’s responses then goes on to hopefully shape that government or public policy.  

If you’d like to speak to a member of the Policy team regarding our submissions, you can email us at [email protected].