Complaint to the Charity Commission regarding Action for Children's content regarding cross-sex identification, and actions of Paul Carberry, CEO.
Dear Charity Commission,
I would like to make a follow-up complaint regarding Action for Children (1097940), given that I have since been in touch with one of Action for Children's trustees, who has asked for my complaint (CRM:0049441) to be further considered by Action for Children's CEO, Paul Carberry.
I would like to make the complaint that Action for Children continue to fail in their charitable objects:
"the charity works for the public benefit having as its objects the promotion of the upbringing and care of children and young people in need from all backgrounds, cultures, and faiths or none in particular by: 1. promoting their better care and safeguarding them; 2. providing assistance to them and their families and carers; 3. promoting their health; 4. promoting their education and establishment in life."
I consider that when it comes to the matter of cross-sex identification, Action for Children are actively working against these charitable objects.
I would consider a successful outcome of my two complaints regarding Action for Children to be the following:
1) Action for Children to remove their content that promotes a misleading and harmful narrative of matters of cross-sex identification to parents and children. This could be accompanied by a simple message for parents and children to contact the NHS instead.
2) Action for Children to spend some of its £149,787,000 income (2023) in a follow-up task to ensure the welfare of the parents and children who attended Action for Children's group "Trancakes".1
"Trancakes" and social transition
With regards to Action for Children's group "Trancakes", the Cass Review notes that in an NHS setting, such social transition would be seen as "an active intervention because it may have significant effects on the child or young person in terms of their psychological functioning and longer-term outcomes".2 Action for Children in this respect have been acting as NHS professionals, despite evidently not having the expertise to do so.
The Cass Review, furthermore, notes that there is no strong evidence either way for whether social transition is beneficial or causes harm. It notes that "a child who might have desisted at puberty is more likely to have an altered trajectory, culminating in medical interventions which will have life-long implications".3
Given this is one potential outcome, I think Action for Children should be liable for any ongoing care for any children who attended "Trancakes", who found that they later wanted to desist from identifying as the opposite sex.
Response from Paul Carberry, CEO
I would also like to make the complaint that Paul Carberry has not considered the points I have raised in my complaint, and sought to avoid the scrutiny of Action for Children's trustees regarding this matter.
I see that it is inevitable that the matters I raise will eventually bring Action for Children, and many other charities, into disrepute.
Accordingly, in this case, it is inappropriate for Paul Carberry to advise members of the public, such as myself, to not contact trustees, (paragraph 62 of this complaint) given that this interferes in the role of trustees to hold their charity to account. I think, in fact, that the normal behaviour would have been for Paul Carberry to have invited trustees to discuss my complaint, for their insight and expertise.
It is of further concern that Paul Carberry believes that requesting a response to a complaint be made in writing is of any relevance at all (paragraph 39 of this complaint), given the serious nature of my complaint, namely that Action for Children's actions and content around the subject of transsexualism is harming children, primarily girls.
I see that Paul Carberry's statement shows confusion regarding Action for Children's role in this matter: "Please be assured that Action for Children is awaiting updated Government guidance on the matter, which we know to be complex, and once it is published, we will update our material accordingly" (paragraph 61 of this complaint).
There are no requirements for Action for Children to target any content regarding transsexualism at children and parents. Action for Children are choosing freely to enter this "complex area", and are presenting itself as an authority on transsexualism. Accordingly, it should be able to justify its content against criticism. If it cannot, it should remove this content, and leave this matter to the NHS, as I request at the start of this complaint.
Furthermore, if Action for Children wants to use the UK Government as an authority, my original complaint highlights existing government advice that Action for Children is not following. Paragraphs 50-55 of my prior Charity Commission complaint CRM:0049441 show where Action for Children's content would not be permitted to be taught in schools under the interim Department of Education guidelines.
Paragraph 34 of the same complaint CRM:0049441 highlights where Action for Children are signposting parents and children to Stonewall, who continue to promote puberty blockers, despite the Cass Review finding puberty blockers have "unclear" rationale and "weak evidence" for their use,4 for children who are distressed regarding their sex, and the the subsequent ban from this use by the UK Government.
At no point have I received a response to any of the points I raised in my complaint from Action for Children. Even at CEO-level, there is an inability to justify any of Action for Children's content against the points I raise in my complaint.
I very much encourage every member of staff at Action for Children and the trustees to read my complaints, as I think that they convey the actual primary research regarding cross-sex identification in an easy-to-understand way, and the way in which Action for Children's misleading content is contributing to harm children, primarily girls. Additionally, I again share the following links for members of staff and trustees who want to look into this matter themselves:
https://www.healthsense-uk.org/publications/newsletter/newsletter-127/420-127-orlando.html
Yours,
Orlando
5th September 2024
Dear Orlando,
I hope this finds you well.
[...] kindly passed on your details. I am aware you had complained previously and your complaint was dealt with by an Operational Director who advised the information you complained about had been correctly removed from our Parent Talk platform and the matter was closed. With hindsight the colleague in question should have offered you a telephone conversation.
I would be pleased to speak with you Orlando if you were so minded. Katherine my EA can arrange a Teams call for us.
Kind Regards,
Paul
Paul Carberry
Chief Executive
5th September 2024
Dear Paul Carberry,
Please could you confirm that you had read my attached complaint. Please could you also respond to the points I have raised in my complaint in writing.
Additionally, could I please ask you to read two short articles, which I also sent in my initial email to [...]. The articles provide context to my complaint.
The first article is written by Ray Blanchard, who served on the DSM-4 gender identity disorder subcommittee, and Prof. Michael J. Bailey. Both are pre-eminent researchers in this field. The article is written to convey the research behind this matter in a way that is accessible to the public, including parents who are affected by their child's cross-sex identification:
https://4thwavenow.com/2017/12/07/gender-dysphoria-is-not-one-thing/
The second article is my short, referenced, memo, which I have written to illustrate the research mentioned in the article above:
NB. The links in my attached complaint are not clickable, therefore, for convenience, I have included some of the links below:
Action for Children:
Deconstructing the feminine essence narrative:
https://www.researchgate.net/publication/5420507_Deconstructing_the_Feminine_Essence_Narrative
HealthSense article:
https://www.healthsense-uk.org/publications/newsletter/newsletter-127/420-127-orlando.html
Draft Department of Education Guidelines:
Yours,
Orlando
5th September 2024
Dear Orlando,
I have read your complaint and confirm that I will respond in writing. I am not long back from leave and as you can imagine i am catching up. I will respond to you in writing next week.
Best wishes,
Paul
5th September 2024
Dear Paul,
Thank you for your reply, I appreciate that some time may need allocating to my complaint, in order to consider it fully.
Yours,
Orlando
19th September 2024
Dear Orlando,
Further to our initial exchange of emails, I have now had the opportunity to review your complaint and would like to thank you for your patience following my return from annual leave.
Our usual complaints process and procedure gives complainants the opportunity to discuss matters before an outcome is given, but I note that you have declined the opportunity for such a call.
Having reviewed your correspondence and Action for Children's guidance on gender-identification, which was updated following your initial complaint, I am content that it follows the latest Government guidance in this very complex area and I am confident that we are legally compliant.
Action for Children aims to support children, young persons and parents in their daily challenges and whilst there is an on-going debate on the best way to address cross-sex identification, I do not believe that Action for Children's material presents a misleading narrative.
We anticipate that there will be fresh guidance from the new Government on this matter and I can confirm that the charity will follow this, once it has been published.
Finally, may I take this opportunity to thank you for raising this matter and ask that you direct any further correspondence to me.
Yours sincerely,
Paul Carberry
CEO
19th September 2024
Dear Paul Carberry CEO,
I don't consider your response has addressed the issues I have raised in my complaint.
It is my view, that Action for Children now are fully informed regarding the content of the DSM-5 and the actual research regarding gender identity and gender dysphoria, and are now consciously choosing to misrepresent this matter to children and parents.
I have what the DSM-5 calls autogynephilia, and late-onset gender dysphoria (covered in paragraphs 11 and 12 of my complaint, attached again as PDF). Furthermore, I can see from reading the DSM-5, that early-onset gender dysphoria is something that will usually resolve at the onset of puberty, with a high likelihood of same-sex attraction, which I cover in paragraph 9 of my complaint. The DSM-5 sees cross-sex identification as connected to atypical sexuality/sexual orientation. However Action for Children does not mention any of this to parents, nor children, but rather construes cross-sex identification in terms of a somehow "mismatched" "essence" or "gender identity", which I cover is misleading in paragraph 6 of my complaint.
I highlight in my Trans memo, [1] the motivation of activists for promoting this "mismatched" "essence" or "gender identity" narrative. [2] I see that at some point, Action for Children has become to be used as a vehicle for this activism, to the detriment of children. Furthermore, the fact that Action for Children's content suggests the opposite to what is in the DSM-5, "Gender identity is different from a person's sex or sexuality", [3] indicates that Action for Children's material has been written by activists, to further the "gender identity" "essence" narrative, which is a fiction.
I see that this is causing children, primarily girls, who are a cohort known historically to suffer from mental health social contagions, to falsely diagnose themselves with a "mismatched" "gender identity", despite never being likely in the past to have been affected by this issue, which I cover in paragraph 20 of my complaint.
This has happened, for example, to the following parent's daughter:
"But it [gender identity] was allowed to be taught in the first place and now my daughter is stuck in the belief that she should be a boy after being exposed to this". [4]
Finally, I note that this is not the sole occurrence of Action for Children being used as an apparent vehicle for the activism of adults. In the article "How to support children and young people with their gender identity", [5] Action for Children suggests that it is possible for a child to be neither male nor female:
"A non-binary young person may prefer a pronoun that doesn't relate to male or female gender, such as 'they' or 'zir'."
The idea that someone can be neither male nor female, and can call themselves "zir" is not something that is coming from children. I see that this material is being targeted at children by adults who have an interest in embedding certain identities in society for their own motivations, [6] and have evidently found that children's charities, such as Action for Children, are a fertile ground in which to do this.
[1]
[2] "They wanted the whole business of Blanchard's taxonomic division shot down. Transsexuality should appear only as the public could stomach it, as one simple story of gender, a tale of "true" females tragically born into male bodies, rescued by medical and surgical reassignment. And there should be absolutely no mention of autogynephilia or any other sexual desires that might make trans women look to the sexually sheltered like the perverts they were historically assumed to be."
Alice Dreger, bioethicist quoted in
[4] https://x.com/h_m_b6/status/1791118478113472763
https://web.archive.org/web/20240528180222/https://x.com/h_m_b6/status/1791118478113472763
[6] I see the creation of "non-binary" category, again, to be likely cover for male paraphilia, as "gender identity" does for autogynephilia. It does not surprise me that WPATH, the trans activist organisation, tried to advocate for "eunuch" as a "non-binary" "gender identity" https://www.dailymail.co.uk/health/article-11227887/Eunuch-gender-says-prominent-pro-trans-advocacy-group.html
2nd October 2024
Dear Orlando,
Thank you for your email of 19 September 2024. I am sorry you feel that Action for Children has not addressed your complaint, but in previous correspondence, I have set out the steps we have taken, including revising our guidance.
Please be assured that Action for Children is awaiting updated Government guidance on the matter, which we know to be complex, and once it is published, we will update our material accordingly.
I would politely ask again that you refrain from contacting Action for Children's Trustees directly as I do not consider this appropriate. This is a matter for the charity's Executive Team. [...] has forwarded to me your email to him of 26 September. Please accept this email from me by way of reply.
We now consider the matter closed and I can confirm that we will not be taking your complaint further or entering into any more correspondence with you.
Yours sincerely,
Paul Carberry
Separate to this complaint, is the following document, included for interest. Action for Children’s “Gender Identity Guide”.
Cass Review, p. 158. https://cass.independent-review.uk/home/publications/final-report/
Cass Review, p. 158.