Why can’t Avon and Somerset Police tell the truth?

When the public ask for information at a Police and Crime Panel, we should be told the truth, the whole truth, and nothing but the truth.

By Claire Loneragan

On 23 February 2025, Joy Davies submitted a Freedom of Information Request to Avon and Somerset police. You can find it here, along with the response from Avon & Somerset who were happy to provide the information requested.

This is what Joy requested:

Please provide a copy of the most recent of the following documents, please also indicate if there are any further iterations awaiting approval.

1. Most recent Transgender in the workplace policy.

2. Most recent EIA for the Transgender in the workplace policy, specifically any considerations regarding use of changing rooms and toilet facilities.

3. What groups, both internal and external, were consulted with in the preparation of the policy.

4. Most recent custody protocol incorporating strip searching process.

5. Most recent custody EIA for custody protocol.6. What groups, both internal and external, were consulted with in the preparation of the protocol.

It’s hard to know where to start with the documents provided.

They reveal one of the worst Equality Impact Assessments (EIA) I’ve seen – in what is a very crowded field – and that Clare Moody and Sarah Crew deliberately mislead the public when they answered questions at the Police and Crime Panel (PCP) in Taunton on 4 February 2025.

Or if they did not, then activists have so thoroughly captured A&S Police that it is no longer possible for senior officers and the PCC to trust the information they are given by their staff.

Avon and Somerset Police Transgender and Non-Binary inclusion in the workplace guidance

Dated March 2025, this document is bang up to date and kicks off with some very positive updates. On 5 March the Stonewall review was removed (which hopefully means that Stonewall no longer has oversight of Avon & Somerset Police HR policy).

Excellent news.

That same update removed Mermaids and Stonewall as support groups. Also excellent news. And Appendix D was corrected to show “Warrant card” rather than “Warrant card(s)” which probably relates to withdrawal of the previous guidance allowing “genderfluid” officers to have more than one warrant card.

This is where the good news ends.

This document was obviously written by activists. Every tenet of genderism is accepted without caveat, from sex being “assigned at birth”, to non-binary people identifying as neither male nor female (or, confusingly, identifying as both). We learn that warrant cards will be issued to reflect an individual’s “authentic gender identity” and misgendering and deadnaming may be treated as harassment.

Even the need for extreme secrecy about someone’s “gender identity” whilst at the same time treating a “transgender colleague” as the gender with which they identify – regardless of whether they have had any cosmetic surgery or hormone treatment – is earnestly demanded without any consideration as to how this could possibly be achieved. For those who transition whilst in service, fellow officers are somehow required to simultaneously know and not know their colleague’s sex.

It will come as no surprise that, along with names, uniforms and pronouns, police officers who claim to be “transitioning” can choose the toilets and changing rooms they would like to use. Indeed, Clare Moody quoted from section 10 of this document at the PCP in Taunton on 4 February:

“10.3 If a person is transitioning in a workplace, then they may wish to talk to their employer or manager about the facilities they wish to use at which point during their transition.”

She also said:

“in compliance with the law, single-sex facilities and shower areas are available for staff….the design and provision of toilets, showers, and changing rooms are intended to prevent any situation where a woman would be forced to undress or shower with trans-identifying men.”

But these things cannot both be true. Even if the design intends to prevent women being forced to undress or shower with a “trans-identifying man”, the policy permits – even requires – precisely that.

It implements self-ID in the workplace and wraps it up in the approved language of activists.

The glossary, which is littered with typos and grammatical errors, lists the terminology officers should use, whilst noting that not everyone uses the terms as defined. Unaccountably, “misogyny” and “autogynephilia” are omitted.

Transition is to be supported by all, with time off for medical treatment and surgery (if requested) and all traces of a previous identity expunged on request. Nothing is too much trouble, and colleagues are instructed to “respect and support individual’s (sic) choices and wishes”. Avon & Somerset have implemented the Family Guy trans policy

The Equality Impact Assessment

When you’re in need of a good laugh, it’s hard to beat an Avon & Somerset Police Equality Impact Assessment. And the EIA that accompanies the Transgender and Non-Binary inclusion in the workplace guidance is a gem.

The purpose of an EIA is to give the tyres a good kicking on any new policy and surface any consequences for people who are not the intended targets of the policy. But, as with all EIAs that relate to matters transgender, the author appears to believe that his or her task is to examine how the life of a transgender person will be affected by this policy.

Who approves these things?

This summary couldn’t miss the point more thoroughly. We are led to believe that the people who are permitted to choose which toilets and changing rooms they use are the only ones affected by this choice. No impact on women, then, of men identifying their way into women’s facilities?

And what is meant by “intersectionality” here?

Come to that, what is meant by “evidence”? If evidence gathered for criminal investigations looks anything like this, it’s a miracle anyone is ever convicted of any crimes at all.

We shouldn’t be surprised that no impact was identified for any other group; only the LGBT+ Network and Outreach team were consulted. Of course they didn’t ask women. Or disabled people. Or consider the public impact of a male police officer wearing a female uniform and calling himself Gladys. Only a bigot would have a problem with that.

And the impact identified on those claiming the protected characteristic of gender reassignment?

Adverse impact identified- due to the withdrawal of national guidance- since our guidance was based on the NPCC guidance, we are urgently reviewing our position, including seeking legal advice.

In the interim, all searches are being carried out in line with the officer or staff member’s training and legal authority, taking into account our responsibilities under Police and Criminal Evidence Act 1984, and, where a person has been detained, as authorised by the Custody Sergeant.

This authorisation must take into consideration the response of the detainee and officers concerned to ensure any conflict is reduced or avoided, and searches are conducted safely and with dignity.

Only a cynic would interpret this to mean “having been forced to withdraw our unlawful policy, we will revert to searching the public in line with the rules laid out by PACE”. But why would this be an “adverse” impact? Male officers who would like to search female suspects do not suffer a detriment from being told they cannot.

On 4 February at the Taunton Police and Crime Panel I asked whether officers had been trained in the new policy following the withdrawal of the NPCC transgender search policy, and whether an EIA had been done.

Clare Moody replied that there was no new policy, and “Therefore, there was no requirement to undertake an Equality Analysis or Data Protection Impact Assessment.”

And yet, here is the Equality Impact Assessment which specifically acknowledges a change in policy.

For what it’s worth.