City of London Gender Identity Survey

On July 7th 2018, a link to a survey monkey questionnaire was tweeted out by Edward Lord OBE , an officer of the City of London Corporation. The survey is being carried out by the Corporation in relation to proposals to make all its services and facilities ‘gender neutral’.

The City of London Corporation has responsibility for a huge number of sites around London which will be used by millions of people entirely unaware of who manages them. These include the Tower of London, Hampstead Heath, the London Museum, the Barbican and various libraries, markets and parks. Click on the links below to see the scope of the Corporation’s reach:

City of London Things to Do

City of London Services

City of London Business

We are very concerned that this survey is not being carried out in good faith and that it is being done in such a way as to privilege the interests of some people over others. We believe the City of London Corporation may be in breach of its obligations under the Equality Act (2010) and the Public Sector Equality Duty.

We are therefore calling on the City of London Corporation to halt the consultation and review its implementation to ensure it is in line with good practice and with the law.

What can you do?

If you share our concerns, please:

• Write to the City of London Corporation explaining why you are concerned about the proposals
• See below for the contents of our letter and feel free to adapt: personalised letters  produce better responses.
• Refer to any sites and facilities run by the City (see above) that you use and explain how a change in this policy would impact on you and others.
• Submit your letter here
• Let us know that you have contacted them and share any response you get

Contents of WPUK letter for adaptation

We are aware of a survey being circulated which is consulting on proposals to make City of London Corporation services and facilities gender neutral.

Concerns we raised:

• That a proposal of this magnitude is being carried out via Survey Monkey and that it was initially only available on Twitter. Survey Monkey is not an appropriate platform to use to collect responses for a survey of this kind as it is open to multiple completion by single individuals. Neither is it a reliable, secure or inclusive way to undertake a survey which will potentially affect millions of London citizens and visitors to the City
• The way the questions have been framed which is confusing and obstructive
• The terminology used which repeatedly conflates the terms ‘gender’ and ‘sex’. This  is both confusing and alarming given that ‘sex’ is a protected characteristic under the Equality Act
• The comments made by one of the Officers of the City on Twitter which imply any oppositional responses to the proposals will be disregarded
• That this consultation is being carried out over the summer holidays with a closure date of 14^th September.

All of this calls into question the propriety of the consultation.

Questions we asked:

• Who authored the survey and what experience do they have in creating surveys of this kind?
• What advice and guidance did the authors have on drafting questions in line with best practice and equality law?
• What guarantees can you give that all responses will be fairly considered?
• Why has Survey Monkey been chosen as a platform and what steps have been taken to ensure that results are reliable and democratic?
• What work was done to ensure that the rights of all those with protected characteristics were considered in the framing of the questions?
• How will the City ensure that all potential users of these services are aware of this survey and are able to respond?
• Has the survey been translated into community languages?
• Has it been made accessible for visually impaired people?
• How will the City consult with representational groups to fully consider the implications of possible changes, in particular, their impact on those with protected characteristics?
• What other methods is the City using to elicit responses to the proposals?
• Does the City intend to carry out a full impact assessment and how will this be executed?

We  also noted that only 20% of the City’s council members are women when women make up over 50% of the general population.

We asked:

1. What strategies the City has adopted to increase the proportion of female council members and officers?
2. What steps were taken to ensure women were involved with the process which drafted and approved this survey and any wider consultation?

We are calling for a halt to this consultation and a relaunch that enables the largest number of people to be aware of its existence and to be able to participate fully.

Campaigners question validity of survey on transgender rights May 2019