๐Ÿ•Š๏ธ Urgent EHRC Consultation Closes Tonight โ€“ Submit Now

Published: 30 June 2025
Today we were notified that the Equality and Human Rights Commission (EHRC) consultation on the draft Code of Practice for Services, Public Functions and Associations closes at 11:59pm tonight.

If you wish to have your voice heard on matters of identity, legal sex, safeguarding, and discrimination, you must act quickly.
๐Ÿ‘‰ Submit your response here:
https://www.smartsurvey.co.uk/s/ehrc-code-of-practice-consultation-2025/


๐Ÿ“ Our Submission โ€“ Response to Question 76: Final General Feedback

Yes. The Equality and Human Rights Commission must confront a foundational failure in this Code of Practice: it presumes that sex, family status, and identity data held by the state is accurate, lawful, and neutral. In reality, as documented in our published case studies, local authorities, courts, and registration bodies are frequently falsifying, reassigning, or misclassifying identity records โ€” including sex at birth, parentage, and BMD (Birth, Marriage, and Death) entries.

These actions are not clerical anomalies โ€” they are systemic. They result in unlawful removals, denial of contact, misclassification for safeguarding purposes, and complete erasure of parental rights. In our case, the state altered birth records, misassigned one daughter to the wrong family, and used falsified data to justify cross-border movements of our child. These changes were then accepted by services and agencies relying on what this Code wrongly treats as authoritative data.

We urge the EHRC to implement the following changes:

  • A clear requirement that service providers and public bodies verify the legal integrity and origin of personal data used in safeguarding or discrimination assessments.
  • Acknowledgement that protected characteristics may be masked, falsified, or misrepresented by state error or fraud.
  • Stronger obligations on transparency, audit trails, and data subject participation in any identity-based determination.
  • A statutory warning that inaccurate identity data can perpetuate discrimination, especially in cases involving children, women, migrants, and cross-jurisdictional care.

International failures must also be acknowledged:

Rule 26 provisions โ€” both under international frameworks and the European Court of Human Rights โ€” require investigation and accountability where false or misleading information is used by public authorities to justify interventions or remove rights. These frameworks exist to prevent state abuse, yet in practice, they are being ignored, even in cases involving forged records, unlawful detentions, and loss of legal personhood.

Final Warning

The EHRC must explicitly recognise this enforcement vacuum and help build domestic mechanisms to respond when international oversight fails. Without this, the Code cannot provide genuine protection โ€” it merely reinforces state-defined identities without independent verification or remedy.

This failure undermines the entire foundation of anti-discrimination law. It allows the state to define who a person is โ€” legally and socially โ€” without accountability, and with no path to correction. In doing so, the Code risks becoming complicit in the very injustices it claims to prevent.


๐Ÿ“ข Please share the EHRC consultation link today:
https://www.smartsurvey.co.uk/s/ehrc-code-of-practice-consultation-2025/

๐Ÿ”Ž For evidence and context:

Epsteinโ€™s Logs Are Public. Emilyโ€™s Flight Is Missing.

Resolving Birth Certificate Discrepancies in East Sussex

Follow-Up on Birth Certificate Issues โ€“ A Case Study

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