WILTSHIRE POLICE POLICY AND PROCEDURE

TRANSGENDER POLICY AND PROCEDURE Author Department Date of Publication Review Date Technical Author

L Khandker Human Resources June 2010 June 2013

CONTENTS CONTENTS .............................................................................................. 1 POLICY – TRANSGENDER AND THE WORK PLACE ......................................2 AIMS AND OBJECTIVES ....................................................................................4 PROCEDURE FOR DEALING WITH TRANSGENDER ISSUES .......................5 UNDERSTANDING TRANSGENDER .................................................................6 RECRUITMENT ...................................................................................................7 ISSUES ARISING WITH GENDER TRANSITION DURING EMPLOYMENT ...10 OPERATIONAL ISSUES REGARDING TRANSGENDER STAFF ...................16

Quick Guide – Transgender and Gender Reassignment Procedures ..... 18 INDEX ................................................................................................................19

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POLICY – TRANSGENDER AND THE WORK PLACE Overview Fairness at work and good job performance go hand in hand. Tackling discrimination helps to attract, motivate and retain staff and enhances an organisation's reputation as an employer. Eliminating discrimination helps everyone to have an equal opportunity to work in an environment of mutual respect and dignity. The Equality Act 2010, Equality Act 2006, the Gender Recognition Act 2004 and the Gender Re-assignment Regulations 1999 gives protection to people on the grounds of their gender identity in terms of services, goods and public facilities. This policy sets out how the Force will meet the needs of its staff in terms of their gender identity, whilst ensuring effective service delivery. Glossary of Terms Term Transgender

Meaning A transgender person is someone who has a deep conviction that their gender - whether they are a man or a women - does not conform to the sex they were assigned at birth. – this is known as gender dysphoria,

Gender Recognition Act

The Gender Recognition Act 2004 has enabled people in the UK, since April 2005, to apply for full legal recognition for their acquired gender. It also includes important measures to protect people’s privacy

Equality Act

The Gender Duty within the Equality Act 2006, which came into force in April 2007, places additional duty on public employers to take positive steps to combat unlawful discrimination and harassment of transgender workers or potential workers.

Outing

When against their wishes a person is revealed as Transgender to another person.

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European Convention on Human Rights (ECHR) Compliance The table below lists the ECHR Compliance Guide paragraphs that specifically relate to this Procedure. ECHR Compliance Guide paragraphs relating to this document 12. Article 8 - Right to Respect for Private and Family Life 17. Article 14 - Prohibition of Discrimination

Public Access This policy is suitable for public access. Data Protection Any information relating to an identified or identifiable living individual recorded as a consequence of this policy will be processed in accordance with the Data Protection Act 2018, General Data Protection Regulations and the Force Data Protection Policy. Legal Basis and Driving Force • • • • • • •

Sex Discrimination Act 1975 Gender Re-assignment Regulations 1999 Gender Recognition Act 2004 Civil Partnership Act 2004 Equality Act 2006 Equality Act 2010 Data Protection Act 2018 / General Data Protection Regulations

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AIMS AND OBJECTIVES Aim of Policy and Procedure Wiltshire Police is committed to equality of opportunity, both in the provision of services and in our role as an employer. All staff, volunteers and applicants have the right to be treated with fairness, dignity and respect and to ensure that the working environment is fair and supportive to individual needs. This policy aims to ensure that our dealings with individuals who are undergoing or have undergone gender-reassignment receive the same respect and fairness in treatment in all aspects of their employment or potential employment with the Force. The accompanying Procedure therefore aims to: a) Provide guidance to managers and colleagues on the status of transgender in the UK and the issues faced by someone going through the gender reassignment process or who has been through the gender reassignment process, to increase their understanding and awareness. b) Detail the appropriate steps and issues to be considered when a transgender person applies to the Force following gender reassignment or states that they are about to undergo the gender reassignment process whilst in employment with the Force. c) Provide guidance to staff in dealing with transgender people during the course of their work with the Force by increasing their understanding of gender re-assignment.

Policy Objectives To eliminate discrimination against transgender applicants or employees or ex-employees because of their gender identity. • To raise awareness and understanding of this subject amongst management and employees. • To ensure that all employees are treated fairly, equally and according to their needs. •

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Summary of Our Legal Obligations The Gender Recognition Act 2004 and the Gender Re-assignment Regulations 1999 apply to all employment matters and vocational training and include recruitment, terms and conditions, promotions, transfers, dismissals and training. They make it unlawful on the grounds gender reassignment to: • •







Discriminate directly against someone because of gender reassignment – that is, to treat them less favourably than others; Discriminate indirectly against someone by applying a criterion, provision or practice which disadvantages trans people unless it can be objectively justified. Subject someone to harassment. Harassment is unwanted conduct that violates a person’s dignity or creates an intimidating, hostile, degrading, humilating or offensive environment for them having regard to all the circumstances including the perception of the victim. Victimise someone because they have made or intend to make a complaint or allegation or have given or intend to give evidence in relation to a complaint of discrimination on grounds of gender reassignment . To discriminate against someone because of gender reassignment, after their working relationship has ended.

PROCEDURE FOR DEALING WITH TRANSGENDER ISSUES Gender Recognition Act (GRA) 2004 The GRA gives legal recognition in their acquired gender to transgender people who satisfy the Gender Recognition Panel that they: • • •

have or have had gender dysphoria, and have lived in the acquired gender for two years prior to the application, and intend to live permanently in the acquired gender.

The gender recognition process ensures that transgender people are afforded all the rights and responsibilities appropriate to that gender. If a transgender person is successful in applying for gender recognition and they are unmarried, they will get a full gender recognition certificate 5

(GRC). If their birth was registered in the UK, they will automatically be entered on the Gender Recognition Register held by the Registrar General. Their original birth register entry will be marked, confidentially, to indicate that they have become recognised in their acquired gender. They will then be able to marry a person of the opposite gender and be eligible for the state retirement pension and other benefits in their new gender. If their birth has been registered in the UK they will receive a new birth certificate in their acquired name and gender. Individuals who are married cannot receive a full GRC because marriage is not permitted between two members of the same sex. They may, however, apply to a Gender Recognition Panel for an interim GRC. This enables them to obtain a full GRC after their marriage is annulled, and provides a new ground for annulment to ease the process. They will then be able to either enter into a civil partnership under the Civil Partnership Act 2004 or remarry if they so wish,

UNDERSTANDING TRANSGENDER Who are transgender people? A transgender person is someone who has changed their gender or has indicated their desire to do so. Being transgender means to identify with the gender of the opposite sex. This is not to be confused with transvestism, where a person wears clothing appropriate to the opposite gender. Transgender is not a ‘lifestyle choice’, nor a facet of sexual orientation, nor a disease. It is in fact a recognised medical condition know as “gender dysphoria”, and must be treated as such. Gender dysphoria is a drive to live in the opposite gender to that in which the person has been registered at birth. Many transgender people wish to change their name and personal details and live as a member of the gender with which they identify. This may involve hormone therapy and surgery. The process is referred to as ‘gender reassignment’ or ‘transitioning’. How is gender transition achieved? It is achieved by the person undergoing gender reassignment. This term 6

is used to describe the process whereby a person changes their gender. Not all trans people complete their transition with medical assistance. However, the process usually consist of counselling, followed by medication to alter the body and physical characteristics Typically, after about six months of hormone therapy, the physical appearance of the individual will begin to change. If an individual had not yet changed social gender (started a period of ‘living’ in the desired gender role), they will begin to do so at this stage, although the former gender may be maintained at work for a further period. During the early part of the medical process, it is possible that the individual may display characteristics of both genders. The final stage for some individuals is to undergo surgery, which as long as there are no extraneous delays (for example funding problems or waiting lists), will usually be undertaken within one or two years of the commencement of hormone therapy. However NOT ALL transgender people who go through gender reassignment undergo surgery. The decision should be considered as one of personal choice and not as criterion in the process of definition of gender change. Also not all transgender people wish to or can go through this legal process. Therefore all transgender people should be treated as the gender in which they live, whether or not they have applied for such legal recognition.

RECRUITMENT Recruitment considerations for the employment of transgender people In most cases the gender of an employee is of no relevance to their ability to do their job. Wiltshire Police is committed to the employment, development and promotion of all, regardless of sex, marital status, colour, race, nationality, ethnic/racial/national origins, religious beliefs, disability, age, sexual orientation or gender identity. As such, Wiltshire Police is committed to ensuring potential employees are not discriminated against in the recruitment process.

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Selection Procedure The normal recruitment and selection procedure will be followed in relation to transgender applicants. However, considerations must be given throughout the process to ensure that the wishes of the applicant are taken into account and they are informed of the practical difficulties that may arise. Interviewing It should not be expected that applicants and interviewees for employment would necessarily wish to disclose their transgender status. Many may have experienced prejudice and harassment as a result of disclosure. It is not a question that should be asked at interview, as it is not a relevant criterion in selection. There is no obligation for a transgender person to disclose their status as a condition of employment. If they choose to disclose it, this is not in itself a reason for not offering employment. Moreover, non-disclosure, or subsequent disclosure, is not grounds for dismissal. Therefore any forms and documents that are provided during the interview and resulting procedures that contain personal information relating to former names etc must be kept separate from application forms and if successful at selection must be placed in a sealed envelope and passed under confidential cover to the Recruitment Department. Once the necessary checks etc. have been completed this information, along with copies of birth certificates or any other paperwork that indicates the individuals transgender status, will be stored separately from the main Personnel File and will not be accessible to other personnel. Pre Employment Discussions In roles where there is a potential conflict in relation to searching, the Human Resources Department will discuss the implications with the individual and determine an appropriate and agreed approach to the issue. This will include discussing the practical difficulties around the maintenance of confidentiality and the responsibility placed on the individual to ensure they do not undertake inappropriate searching.

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The HR Department will play a key role in supporting the individual in the commencement of their employment. What about when ‘asked for references and certificates If the Force is asked for a reference for a transgender person who is an employed or an ex-employee, who went through gender reassignment while working for the Force, the reference must be provided without any reference to the fact that the person has had a change of gender. References must be given in the person’s acquired gender. If the Force has to keep evidence of professional status or qualifications, it should be discuss with the individual concerned how to retain such evidence on file – if, for example, certificates are in the individual’s original name – so as not to compromise or breach disclosure of protected information. To do otherwise is a breach of the data protection legislation Security Checks, Occupational Health and Pensions The respective forms used for security checks, medical screening and pensions may seek information that will lead to identification of transgender status. This information will remain ‘confidential’ and the disclosure of this information will however be restricted to those personnel involved in the two procedures who will be required to honour that confidentiality. Any subsequent paperwork that indicates the individual’s transgender status will not be accessible to other personnel. Genuine Occupational Requirements (GORs) under the Eq Act 2010 A GOR exists when the essential nature of the job, or particular duties attached to the job, may be a genuine and determining reason for a member of one sex. It is lawful to discriminate in recruitment, training, promotion and transfer in a job for which the sex of a worker is a GOR must be applied in a proportionate way – so for example, if there are already people of the required sex in employment who could undertake the role or duties required, a GOR cannot be claimed When recruiting to a post to which a GOQ applies, managers should be aware that failure to recruit an individual to whom gender reassignment grounds apply on the basis of their transgender status may be considered unreasonable and lead to claims of discrimination.

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ISSUES ARISING WITH GENDER TRANSITION DURING EMPLOYMENT Time required off work Transgender people undergoing medical and surgical procedures related to gender reassignment may require time off from work. The first stage of reassignment, under the supervision of a qualified medical practitioner, may take several months or years. Appointments may be required during normal working time. Following this stage there is typically a period of one or more years before the individual is accepted for reconstructive surgery and the time taken for this will vary greatly from two to around 12 weeks, depending on the nature of the surgery undertaken, There is no specific minimum or maximum time employers should grant to a person undergoing medical and/or surgical treatment related to gender reassignment. The Force should show the same flexibility as for someone undergoing any other serious procedure. Long term sickness Complications may arise as a result of medical treatment for gender reassignment resulting in prolonged incapacity for work. As with any other long-term illness, the individual will be supported and monitored by Occupational Health and HR in line with the Forces Attendance Management Policy. If incapacity continues beyond normal expectations for the process undergone, a transgender employee may be retired on medical grounds, moved to a different role or dismissed in the same way as any other person who becomes unfit for employment. Agreeing a process to support the indiviual concern In order to support and successfully manage a person’s transition from one gender to the other when they are in the Force’s employment, it is essential that discussions take place with the individual at an early stage. All parties should endeavour to seek agreement on how the process is to be managed, with the issues that are likely to arise being explored. The Head of Human Resources will be informed as a matter of process to identify any legal implications eg pensions, payroll

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Additional support will also be available via Federation, UNISION, Superintendents Association and HR Officers if required by the individual through the transition period Considered, sensitive and well-documented discussions should identify and resolve potential areas of conflict before they arise. Nothing should be done without the consent/knowledge of the individual. Managers should not make assumptions and decisions based on their perception of what is best for the individual. Formal change in gender At some point the individual will start to live full time as a member of the new sex and name and other records will need to be changed formally. As part of this process the individual will decide the appropriate point when a form of dress and the use of single sex facilities will be adopted that accord with the new social gender. It should be understood however, that this change in social gender, whilst usually taking place during or after hormone therapy, will sometimes occur years before any surgical procedure. For some individuals, the final surgical procedure may never take place. These issues must be discussed fully with the individual. Use of single sex facilities Part of the discussion process with the individual undergoing gender reassignment will be to agree the point at which the use of facilities such as changing rooms and toilets should change from one sex to the other. An appropriate stage for using the facilities of the employee’s new sex is likely to be the change of social gender. Following discussions with the individual, a transgender person should then be granted access to the relevant facilities. It is not acceptable, in the long term, to expect a transgender employee to use separate facilities, such as a disabled person’s toilet. However, this may be a practical and acceptable short-term option whilst the individual is going through the earlier stages of reassignment. Should colleagues be informed? It is good practice for employers to take responsibility for informing whoever needs to know, unless the individual going through the process would prefer to do this. If so, the employer will just need to know when the disclosure is to take place and in what detail, so that they can agree and provide appropriate support. Employers should not inform 11

colleagues, clients and the public that an employee is intending to undergo, or is undergoing, gender reassignment, without the individual’s explicit agreement. It is never appropriate to inform colleagues, clients and the public that an employee has in the past undergone gender reassignment. This should be a private matter since gender reassignment will have no bearing on that person’s ability to do their job. Employers should bear in mind that if such an employee is in possession of a gender recognition certificate, it is unlawful to disclose their transgender status without their consent. Education should take place on two levels. General information about transgenderism, and specific information to enable people to understand the needs of the person involved. At the point of change of gender, it is common for transgender people to take a short time off work and return in their new name and gender role. This is often used as an opportunity to brief others. If someone has ‘transitioned’ prior to joining an employer, the employer should not mention their transgender history. Indeed, this could constitute a criminal offence in the case of someone who has obtained a gender recognition certificate. What happens at the point of changing gender at work? At the point when a transgender person decides to change their gender at work, a date should be agreed date from when the person intends to change their gender role. All personnel records must be updated for the transition. The Force will create new records rather than amend old ones, to ensure confidentiality. All data protection principles will be adhered to. What can other employees do to make the transition easier? All employees should refer to the transgender person by their new name and use pronouns appropriate to their new gender role. In the early days, it is only natural that people may occasionally get mixed up and the transgender person should be aware that this could happen and be prepared to make allowances. Employers must also be aware of the genuine concerns that employees may have, and resolve any issues quickly. Unfortunately, no matter how much preparation is made and support given, there may still be people who do not understand the situation or are unsympathetic. It is advisable to discuss this in advance with the 12

transgender person and agree informally how they would prefer this to be managed. Any incidents of misconduct, harassment, bullying or victimisation should be dealt with quickly and in accordance with the Force’s disciplinary procedures. What time off should be allowed for medical treatment? As far as possible, employers should discuss how much time the individual would need to undergo gender reassignment surgery. When the individual is absent for treatment or surgery, then sick pay entitlements should apply. They should also follow their normal policy for medical appointments. As a matter of good practice, employers should offer flexibility to individuals who may need to take holiday or rearrange working hours in order to attend additional appointments, for example, electrolysis. Employers should remember that it would constitute unlawful discrimination if they treat an individual undergoing gender reassignment less favourably then someone who is absent for some other medical reason but there is no requirement to provide them with additional time off for this purpose ie: normal procedures should be followed, in the normal way. How should employers handle media interest? Instances of gender reassignment can attract the attention of the local and national press. If an employee is being harassed by the media, the Force should protect them, and consider strategies which minimise personal exposure and the need for the person to defend their decision. The press office should prepare a statement which can be issued as and when necessary. What about keeping records? The Force should ensure that all documents, public references, such as telephone directories, intranet contacts etc, and employment details reflect the acquired gender of the person. This will prevent any breach of confidentiality. Where documents have been sent and copies taken at the point of starting employment (such as birth certificate, exam certificates etc), then every effort should be made to replace those with equivalent 13

documents in the new name and gender. In some instances, however, it may be necessary to retain records relating to an individual’s identity at birth, for example, pension or insurance purposes prior to obtaining gender recognition. However, once a person has obtained a Gender Recognition Certificate, these MUST be replaced with new details. Who should have access to the records? Access to records showing the change of name and any other details associated with the individual’s transsexual status, (such as records of absence for medical treatment) must be restricted to employees who need the information to do their work. They could include people directly involved in the administration of a process, for example, people involved in the pension schemes. They do not include colleagues, clients or line managers. Once a person has obtained a Gender Recognition Certificate, there must be no disclosure of this information. Not least because it may be a criminal act subject to a maximum £5000 fine. Breaches of confidentiality should be treated in the same serious manner as disclosure of personal details of any other employee. Transgender people in employment may choose voluntarily to disclose information at a secondary level, for example, answering an equal opportunities monitoring questionnaire, or asking support from their line manager. Again, strict confidentiality should be observed, as further disclosure must not be made without the express permission of the transgender person. The Data Protection Act limits the purposes for which information may be kept, and when that information is no longer useful it must be destroyed. When can the employer make a disclosure? The Gender Recognition Act defines a person’s application for gender recognition and a person’s gender history as ‘protected information’. This means that if an employer or employee acquires the information in the course of official duties, it is a criminal offence to disclose it. It is not an offence, however, to disclose ‘protected information’ if the person cannot be identified or if the individual gives consent. However it should be recognised that to even publicly acknowledge that there is a 14

transgender employee could result in ‘outing’ them. Insurance Employers registering employees for corporate insurance and benefits policies should ask their underwriters if they need to be informed of a transgender employee’s status, since some insurers automatically invalidate a policy if gender reassignment is not disclosed. The employer should get the employee’s prior written consent before disclosing the information. If an employer is unaware that an employee has reassigned gender, the obligation to disclose falls upon the employee, who could also be held liable in the event of an incident for which no valid insurance cover existed. An employer should inform insurers if they require the information, in confidence, in the following cases of group insurance policies: a) b) c) d) e)

Group life assurance Group permanent health or income protection Group private medical insurance Group personal accident insurance Group motor vehicle insurance in the case of company cars

This requirement does not apply if the person has a gender recognition certificate. Occupational and personal pensions A transgender person who receives a full gender recognition certificate will be treated according to their acquired gender for state pension purposes. Transgender people who do not obtain a full gender recognition certificate retain their state pension rights in accordance with the sex that is recorded on their birth certificate. In terms of pension provision, it is good practice for people to be treated as having their birth gender up to the point of transition (i.e. when they start to live fully in the acquired gender) and their acquired gender from the point of transition. This would apply for example in calculating funds transfers between pension plans. In some cases, however, it is considered administratively convenient, with the agreement of the transgender person, to treat them as having the acquired gender for the entire duration of the pension contribution history. 15

Survivors benefit In terms of survivor’s benefits, this depends in large part upon the marriage relationship or civil partnership status of the individual. Regardless of legal gender, married partners and civil partners have legal rights to certain degrees of provision. Any other provision for survivors is normally at the discretion of the trustees of the pension scheme if not specifically covered in the pension scheme.

OPERATIONAL ISSUES REGARDING TRANSGENDER STAFF The Legal position of Searching The position of a transgender person, who does not have a Gender Recognition Certificate, gives rise to some specific issues in the police service, particularly in relation to searching. This is because PACE Stop Searches that go further than the outer clothing searches conducted in public view, have to be conducted by a person of the same sex. Where a transgender individual has a GRC, they are legally their acquired gender and should be treated as such for all purposes. Therefore they are ‘legally’ able to search persons of that same gender. A v Chief Constable of West Yorkshire Police and another [2004] IRLR 573 HL Where an individual does not have a GRC, this means that a transman cannot carry out searches or observe searches on men, as they are legally still the opposite sex. However, they cannot carry out searches on women as this would be morally and socially inappropriate as they would have the appearance of a male. The reverse situation would apply to transwomen without a GRC. Practical implications A transgender person, who does NOT have a Gender Recognition Certificate but who is employed as a Police Officer, Special constable or Detention Officers will not be involved in the conduct or assistance/observation of searches that go beyond removal of outer garments. The frequency of this requirement, however, does not bar

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them from undertaking the general role, as these duties, when required, could be assigned to other staff. The transgender individual will receive personal and appropriate instruction concerning the levels of searches they are permitted to undertake at the time of engagement or when they inform the organisation that they intend to undertake the gender reassignment process. Where managers and colleagues are aware of the individual’s transgender status, they will assist them in ensuring that they are not placed in situations where they could be required to undertake inappropriate searches. Where the individual’s transgender status remains confidential, the individual themselves will be responsible for informing the supervisory officer if directed to carry out any search that would be inappropriate for them to conduct. The individual must clearly understand that this situation is likely to raise questions from supervisors or peers who are not aware they are transgender. These issues will be discussed with the Head of HR at the point of recruitment or commencement of the gender reassignment process. Where a trangender person does have a Gender Recognition Certificate, the Force will support that individual to carry out all their duties as a Police Officer, Special constable or Detention Officer. However the Force will need to consider operational factors when dealing with volatile, violent or confrontational issues/situation arising within Custody. However any action taken to defuse a volatile, violent or confrontational issue/situation will need to be reasonable and proportionate to the situation.

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Quick Guide – Transgender and Gender Reassignment Procedures Issues to be considered if someone informs you they are about to undergo the gender reassignment process Contact the Human Resources Department Advice should be immediately sought from the Head of Human Resources or your local HR Partner. If necessary, arrange a meeting with the individual and HR support. Issues which may need to be considered include; • Does the individual wish to stay at their current workplace or be redeployed? • When and how should others be told (if at all)? • Whether the employee wishes to inform line management, colleagues and external organisational contacts personally, or would prefer this to be done for them? • What is the expected time off for medical and surgical procedures? • What support does the individual think they will require? • What amendments will be required to records and systems? • Do unisex facilities need to be made available? • How to handle hostile reactions, harassment and unwanted media interest? • What training needs to be provided by the Force to assist colleagues to understand and provide appropriate support to the individual?

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INDEX CONTENTS .............................................................................................. 1 POLICY – TRANSGENDER AND THE WORK PLACE ......................................2 Overview ..............................................................................................................2 Glossary of Terms................................................................................................2 Strategic Aims ..................................................... Error! Bookmark not defined. European Convention on Human Rights (ECHR) Compliance ...........................3 Public Access.......................................................................................................3 Legal Basis and Driving Force .............................................................................3 AIMS AND OBJECTIVES ....................................................................................4 Aim of Policy and Procedure ...............................................................................4 Policy Objectives..................................................................................................4 Summary of Our Legal Obligations ......................................................................5 PROCEDURE FOR DEALING WITH TRANSGENDER ISSUES .......................5 Gender Recognition Act (GRA) 2004 ..................................................................5 UNDERSTANDING TRANSGENDER .................................................................6 Who are transgender people? .............................................................................6 How is gender transition achieved? .....................................................................6 RECRUITMENT ...................................................................................................7 Recruitment considerations for the employment of transgender people .............7 Selection Procedure ............................................................................................8 Interviewing ..........................................................................................................8 Pre Employment Discussions ..............................................................................8 What about when ‘asked for references and certificates .....................................9 Security Checks, Occupational Health and Pensions..........................................9 Genuine Occupational Qualifications (GOQ) .......................................................9 ISSUES ARISING WITH GENDER TRANSITION DURING EMPLOYMENT .. 10 Time required off work .......................................................................................10 Long term sickness ............................................................................................10 Agreeing a process to support the indiviual concern .........................................10

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Formal change in social gender .........................................................................11 Use of single sex facilities ..................................................................................11 Should colleagues be informed? .......................................................................11 What happens at the point of changing gender at work? ..................................12 What can other employees do to make the transition easier? ...........................12 What time off should be allowed for medical treatment? ...................................13 How should employers handle media interest? .................................................13 What about keeping records? ............................................................................13 Who should have access to the records? ..........................................................14 When can the employer make a disclosure? .....................................................14 Insurance ...........................................................................................................15 Occupational and personal pensions – ..............................................................15 Survivors benefit – check with payroll................................................................16 OPERATIONAL ISSUES REGARDING TRANSGENDER STAFF .................. 16 The Legal position of Searching ........................................................................16 Practical implications .........................................................................................16

Quick Guide – Transgender and Gender Reassignment Procedures ..... 18 Issues to be considered if someone informs you they are about to undergo the gender reassignment process .................................................................... 18 INDEX .............................................................................................................. 16

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