Public Policy Researcher Carys Moseley investigates whether the Charity Commission is guilty of ‘whitewashing’ the transgender charity Mermaids’ provision of harmful chest binders for children. Christian Concern.
The Charity Commission has recently published a report in which it has strongly criticised Mermaids, the transgender charity working with children, for peddling disinformation about the effects of puberty blockers being reversible. Mermaids was also warned to let parents know whether Mermaids is to provide so-called chest binders to teenage girls from now on.
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Below I shall go through the Charity Commission’s report to assess how rigorous it is morally.
Complaint about ‘chest-binding’ and online support
What led to this report was a complaint made two years ago about ‘chest-binding’ and online support to teenagers provided by Mermaids. There were various other administrative complaints, such as the high turnover of charity trustees, but the aforementioned two were by far the most important.
Charity Commission report accused of being a whitewash
Miriam Cates told GB News that the report is in reality a whitewash as it merely focuses on maladministration of the charity.
The real problem is that Mermaids is permitted to hand out chest binders at all. Mermaids is a political activist campaign. Its influence on schools has been a disaster.
The Charity Commission’s report
The report reveals that Mermaids supports over 10,000 people annually. This is already a large number of children and teenagers, and shows the level of importance of the report. Many complaints were made to the Charity Commission about Mermaids between September 2022 and July 2023. Sixty-two of these were from fifty-four members of the public. Seventeen of these people were already getting help from Mermaids, with the other forty-five people being members of the public responding to news reports. Only eleven of the complaints stated that they had already complained first to Mermaids. The Charity Commission concluded thus:
“the complainants had little confidence that concerns would be considered and/or appropriately dealt with by the charity.”
It’s doubtful whether the rest of the complainants had any more confidence given that they contacted the Charity Commission whilst bypassing Mermaids altogether.
Provision of ‘chest binders’
Here are the Commission’s exact words regarding the complaint about Mermaids providing so-called ‘chest binders’ to flatten teenage girls’ breasts.
“Between 2017 and 26 September 2022, the charity provided a service to its beneficiaries in which it could issue suitable individuals with a chest binder (‘a binder’). Although binders are commonly available and can be purchased without age restriction, the supply of binders by a charity brings with it the authority of the charity’s approval, which may be of influence on children and their families. They are commonly used to flatten an individual’s breasts with constrictive materials to make them more male-presenting.”
The Charity Commission refers to ‘an individual’ not ‘a girl’ and uses they/them pronouns. This shows that the Charity Commission itself is accepting transgender ideology and falls short in terms of prioritising truth and reality.
Lack of questioning of parents’ motives for ordering ‘chest binders’
Reading on, we find that a number of these ‘chest binders’ were provided to children without parental support, and that not only Mermaids but also the Charity Commission did not enquire as to why some parents were also ordering ‘chest binders’ for their daughters.
“The charity provided the inquiry with information relating to the number of occasions on which binders were issued. In total, between January 2021 and September 2022, the charity issued 125 binders – of these, 101 were issued to parents and carers and 24 to unsupported young persons. Unsupported young person is the term used by the charity to refer to a beneficiary under the age of 19 where the charity believes the primary carers are not in support of the young person’s gender identity or expression. Of the 24 binders issued to unsupported young people between January 2021 and September 2022, 15 binders were supplied to young people between ages of 13 to 16 years old, and 9 binders were supplied to those aged over 16 to 19 years…
…Complaints received from the public by the Commission included the provision of binders to young persons under the age of 18 without parental knowledge and/or consent. The inquiry has therefore considered this issue further. It has not considered the provision of binders to parents and carers who requested them on behalf of their children or those in their care. In a statement dated 27 September 2022, the Metropolitan Police confirmed that supplying a binder to a young person was not a criminal offence.”
The Charity Commission didn’t consider whether these parents or carers were abusing these teenage girls by ordering ‘chest binders’ for them. It just asked the Metropolitan Police to give its view on the legality of this action.
Mermaids’ actions here can be explained by the fact that Mermaids’ founder and former CEO Susie Green raised her own son to become a ‘trans girl’.
Neglect of psychological problems
The Charity Commission criticised Mermaids for not considering that there might be psychological problems arising from wearing ‘chest binders’. Here is what it said:
“No advice was given on the possible psychological effects of wearing binders. The inquiry’s own research of publicly available information about the use of binders identified the same potential health implications as those identified and referenced by the charity in its advice to beneficiaries.
The inquiry sought to understand whether there has been any study or research on the impact, including psychological impact, of binding – particularly on those under the age of 18 – and found that there is, to date, limited publicly available information on this social transitioning issue.
The charity confirmed to the inquiry that it took a harm reduction approach when providing binders, as the charity’s position was that young people will purchase and wear binders regardless of whether the charity provides them or not – although this does not take into account the possible persuasive effect on young people being supplied with such products by a registered charity.”
Indeed. However, it’s not enough to lament Mermaids’ lack of interest in psychological consequences. After all it is enthusiastic about teenagers ‘changing sex’. The problem here is the insufficient concern on the part of the Charity Commission. The Charity Commission could have consulted clinical experts on this matter of teenage girls being suggestible by binders being offered to them. It should also have been more critical of the fact that chest binders were being provided free of charge and by post, thus lowering the barriers for children especially obtaining them. Priority given to those agreeing with ‘chest binding’
Mermaids’ lack of interest in the psychological consequences turns out to be linked to its prioritisation of the views of teenagers agreeing with ‘chest binding’.
“In a small number of cases binders were provided to unsupported young people but only in very specific circumstances. They were supplied with associated guidance about its safe use by a trained charity staff member, as this was preferable to the likely alternative of unsafe practices and/or continued or increasing dysphoria. The charity highlighted to the inquiry some of the alternative steps taken by a beneficiary if they could not obtain a binder. The charity’s position was based on the experiences of its service users, many of whom reported on the positive benefits of using a binder.”
It’s very concerning that the Charity Commission does not challenge this. One would think that ‘chest binding’ would be deemed a safeguarding matter.
Mermaids not sufficiently interested in parents’ motives
The Charity Commission managed to get hold of Mermaids’ policy on handing out ‘chest binders’, and had this to say:
“The inquiry obtained and reviewed the charity’s Binder Service Policy (used while the service was in operation). This policy includes a number of conditions that had to be met in order for a binder to be issued, this included
the charity’s member of staff must assess the young person as being competent to understand the risks of using a binder and record this
if the charity’s member of staff is in contact with the parent/carer only, they should explore where the request for a binder has come from and be satisfied that the request has come from the child and make a record of this.”
This won’t do. It’s not nearly good enough safeguarding of teenage girls. The fact that a teenager asks for something in no way means that the request is suitable. What’s more, Mermaids take parents’ say-so as sufficient evidence of what their children are thinking. They don’t ask the children themselves for their views. This means that the parents can conceal their own abuse of their daughters, their indoctrination of their own children into believing they would be better off living as ‘trans men’.
The Charity Commission has clearly not investigated Mermaids robustly enough. It has soft-pedalled the problems and made an unproven assumption of choice and ‘consent by service users’ the bottom line for assessing Mermaids’ actions. This is woefully inadequate.
The charity’s relationship with the Gender Identity Development Service (GIDS) at the Tavistock and Portman NHS Foundation Trust
Moving onto the bigger picture, the Charity Commission looked at Mermaids’ relationship with the GIDS. It concluded thus:
“The inquiry saw no evidence to suggest that the former CEO or the charity had inappropriate influence or ties to GIDS or that referrals were made without the support and knowledge of a parent or carer.”
Clearly this is responding to a complaint that Susie Green, Mermaids’ former CEO, or indeed Mermaids itself, had influenced the GIDS. The Charity Commission’s conclusion is mistaken here. The historical evidence is clear: Mermaids was very close to the GIDS from when it started as an unregistered charity in the mid-1990s. Dr Domenico Di Ceglie supported its application to be a registered charity later on. After the Gender Recognition Act was passed, Mermaids started to surface more and more as a campaign organisation pushing for physical procedures for ‘sex-change’ for children. As these were increasingly approved after 2009, it would have become very difficult, nearly impossible, to detect any inappropriate influence by Mermaids on the GIDS, as Mermaids’ beliefs and those of increasing numbers of the clinicians had been so close. Is the Charity Commission splitting hairs over the difference between influence and convergence of interests? We can’t tell easily.
Provision of medical advice
Complaints were made about Mermaids dispensing medical advice inappropriately. The Charity Commission had this to say:
“The charity provides information, via its website, on the available NHS clinical pathways (and, historically, to alternative private medical healthcare providers) and it supports and advocates for young people on the issue of gender affirming care. However, the inquiry has not found, based on the documents and records it has reviewed as part of its sampling exercise, any evidence that staff or volunteers at the charity have provided medical advice.”
This again begs questions. This BBC Newsnight clip of Susie Green, the former CEO of Mermaids, saying puberty is ‘torture’ shows what Mermaids’ real view of human development is. It makes puberty out to be abnormal and harmful rather than accepting it as a normal stage in human development. This would have fundamentally corrupted its understanding of medicine and healthcare, and thus the way in which it would have handled telling its service users about NHS clinical pathways. Thus, even if Mermaids were found – this time at least – not to be providing medical advice in the strict sense, it could not be trusted to point to reliable clinicians who would give sound medical advice.
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The Charity Commission’s report did thankfully find that Mermaids had reversed the prior claim on its website that the effects of puberty blockers are reversible. This was only done after the publication of the Cass Review and was a requirement under charity law. Mermaids’ FAQ now reads thus:
“Until Spring 2024, gonadotrophin-releasing hormone analogues (puberty blockers) were prescribed to some trans children and young people by NHS clinicians in England, with varying arrangements in place elsewhere in the UK. They are currently prescribed as a treatment for precocious (early) puberty, some hormone-dependent cancers, and for endometriosis.”
Mermaids offered no apology for having previously endorsed puberty blockers, and the Charity Commission has nothing to say about its lack of an apology or self-correction.
Mermaids whitewashed and let off lightly
Having gone through the Charity Commission’s report, it seems that Miriam Cates MP was right. The report was indeed a whitewash. Not only did Mermaids show insufficient concern about the issues, but also the Charity Commission failed to do so. Mermaids was let off lightly. The Charity Commission never investigated how Mermaids indoctrinated children and teenagers, and also parents, into transgender ideology. It’s not surprising then that both Miriam Cates and psychotherapist James Esses have called for Mermaids to be shut down. We wholeheartedly agree.
Christian Concern has challenged Mermaids more than the Charity Commission has done
Over several years now Christian Concern has challenged Mermaids and its credibility on numerous occasions. Several of our legal cases involve parents, governors and teachers challenging Mermaids’ influence on vulnerable children in schools. We’ve asked for the Church of England to stop using Mermaids as a schools’ mental health resource. We’ve warned before that Mermaids’ backtracking on ‘born in the wrong body’ was disingenuous. We’ve said that Mermaids should be banned from all schools and lose its charitable status. Until and unless this happens, the problems will continue.
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