I’ve just spent 2 hours responding to the KCSIE 2026 consultation and as a trans person who works on researching and promoting climate change as a safeguarding issue, the process has utterly exhausted me. I feel I need to voice what I think where it’s strong, where it risks harm, and what I’m asking you to support.
The DfE’s consultation on Keeping Children Safe in Education (KCSIE) 2026 is live until 22 April 2026. If safeguarding is part of your role (DSLs, governors, MAT leaders, AP commissioners, classroom staff), please submit a response—these revisions will shape day‑to‑day practice. Consultation link.
👍 What I think is moving in the right direction
- Mental health: The redraft keeps KCSIE at the right altitude—early identification, whole‑school approaches, clear escalation pathways—so staff can notice → support → escalate without duplicating clinical guidance.
- Information sharing & records: The continuity emphasis (transfer of CP files, “data protection does not prevent sharing”) remains a practical strength.
- Alternative Provision (AP): Signposting to national AP standards inside KCSIE would strengthen commissioning and oversight—schools still hold safeguarding responsibility for placed pupils.
- AI: Referencing the DfE’s generative AI policy and the CLT/Chartered College training is a helpful start for safe, proportionate adoption.
⚠️ Where the draft, ironically, risks harm
1) “Gender‑questioning” pupils
This part took the wind out of my sails a bit, and has me exceptionally concerned.
- The draft risks reframing routine inclusion (names/pronouns, privacy in facilities) as a high‑risk “intervention” and leans toward a parent‑first posture. The social‑science evidence shows supportive adjustments are protective, and that forced outing can increase risk. In short, this approach to safeguarding is, itself, a safeguarding red-flag.
- Reliance on the Cass Review is unsound for statutory school policy: peer‑reviewed analyses document methodological flaws, selective citation, and double standards of evidence, and highlight cisnormative bias in process and framing.
My ask: Insert a short, child‑centred decision protocol: (a) need‑to‑know information‑sharing with pupil consent where safe; (b) case‑by‑case risk assessments for names/pronouns, toilets/changing and sport; (c) privacy‑enhancing options (single‑user facilities) before categorical restrictions; (d) an explicit note that Cass should not be the sole evidential basis for school decisions.
2) Verbal abuse
- Make identity‑based verbal abuse explicit (homophobic/biphobic/transphobic slurs, deliberate misgendering/deadnaming, threats to “out” a pupil) and require recording as prejudice‑related incidents with DSL oversight. This includes citing teachers and staff who verbalise harmful transphobic dog-whistles and rhetoric for safeguardng referal. Evidence links supportive language (e.g., chosen names) to lower depression/suicidality.
3) Climate literacy
- The consultation documents and current KCSIE have no explicit references to climate/ecological concerns as contextual risks. A single sentence directing schools to include foreseeable contextual stressors (e.g., climate‑related worry/distress) in mental‑health signposting and policy reviews would prevent omissions and keep practice proportionate.
4) Medical conditions → safeguarding thresholds
- Keep the useful clarification that a medical condition isn’t, by itself, a safeguarding issue; tighten the link to Individual Healthcare Plans (IHPs) and when to escalate after incidents, and cross‑reference RCPCH guidance on Perplexing Presentations/Fabricated or Induced Illness (PP/FII). IHPs should flag any medical conditions which could be exaccerabated by the impacts of climate change, thus potenitally setting a ‘threshold’ for when safeguarding is triggered.
What I’ll be submitting (and invite you to echo)
- Gender: child‑centred protocol; proportionate, privacy‑first adjustments; do not rely solely on Cass.
- Verbal abuse: explicit identity‑based examples; recording/response requirements; staff conduct expectations.
- Climate: a one‑line, climate‑literate prompt to include foreseeable contextual stressors in resource lists and reviews. Climate change and its impacts must be named and included in Annex B as an example of a contextual safeguarding risk, and an amplifier of risk factors. Having robust Climate Action Plans linked to safeguarding is one method of promoting protective factors.
- Medical conditions: integrate IHPs with safeguarding processes; signpost PP/FII pathways. Highlight medical conditions that can be exaccerabated by the impacts of climate change.
The full text of my submissions to some of the questions are below.
Please add your voice
This is a genuine chance to improve clarity and reduce harm. Submit your response by 22 April 2026 and share this with colleagues, governors and safeguarding partners.
#KCSIE2026 #Safeguarding #Education #LGBTQ+ #ClimateLiteracy #ChildProtection #DSL #AlternativeProvision
Full text Responses submitted FOR QUESTIONS RELEVANT TO CLIMATE-LITERACY AND SAFEGUARDING TRANSGENDER YOUTH
Q31. To what extent do you agree with the following statement: “The revised section on ‘children requiring mental health support’ clearly explains the role of schools and colleges in identifying and responding to mental health needs.”?
Response: Strongly agree. 🌡️
Submision: The revised section gives a clear, high‑level account of what schools/colleges should do: notice early signs, recognise when mental‑health issues become safeguarding, and act proportionately. It then signposts appropriately—to whole‑school approaches (mental‑health lead), MHSTs, and national resources (e.g., NHS 111 / Every Mind Matters)—so staff know where to find detailed guidance without KCSIE duplicating it. In combination with Part one’s immediate‑risk expectations and the wider DSL/multi‑agency framework, this creates a coherent “notice →support →escalate”spine that is both usable and within KCSIE’s remit. This balance closely matches my published framework for reasonable responsibility and standard recognise →respond →refer pathways, supporting confident, compassionate practice. A brief vignette (e.g., climate‑related worry) could further model language and referral triggers while keeping the section high level.
Rationale:
- Clarity on staff roles & early identification. The redrafted Part two section (paras 218–220) states plainly that all staff have a part to play in noticing early signs, and explains how concerns about mental health can intersect with safeguarding (e.g., self‑harm, eating disorders, suicidal ideation), which is reinforced by Part one (paras 44–47) on recognising warning signs and acting promptly. This is a clear, high‑level articulation of responsibilities that settings can operationalise.
- Whole‑school approach is appropriately emphasised. The section highlights the role of a mental health lead and the importance of a whole‑school/college approach to wellbeing (para 221–222), and it signposts to Mental Health Support Teams (MHSTs) as part of an integrated system (para 223). This aligns with how safeguarding culture operates—shared responsibility, coherent messaging, and planned provision.
- Referral pathways and targeted support are made explicit. The text directs schools to identify pupils who may need extra support (para 224) and provides clear signposting to routes such as NHS 111 / Every Mind Matters (para 225), with Part one also setting out immediate actions when a child is at risk (para 47). This combination gives staff confidence about when and how to escalate.
- Consistent with evidence‑informed safeguarding practice. I argue, based on evidence, that literacy and pastoral care must be joined up so staff can acknowledge concerns, use careful language, be institutionally honest about limits, provide supportive structures, and share responsibility across roles—five principles I set out as “reasonable professional responsibility.” The redraft’s focus on early identification, whole‑school systems and clear pathways maps closely onto those principles and will help staff feel confident and compassionate in their response.
- Applicable to context‑linked presentations (e.g., climate‑related distress). Many pupils already have strong emotional connections to nature and that climate‑related worry can present in pastoral conversations; staff need to validate, avoid guilt‑based framings, and follow routine recognise → respond → refer pathways. The redraft’s high‑level framing and signposting support exactly this proportionate, non‑alarmist approach
Q32. To what extent do you agree with the following statement: “The revised section on ‘children requiring mental health support’ provides a clear and useful high-level summary and appropriately signposts to more detailed guidance.”?
Response: Agree. 🌡️
Submision: Recommend one clarifying line so the section is explicitly climate‑literate. Where KCSIE asks schools to list issues/resources for mental‑health‑related safeguarding, it should state that foreseeable contextual stressors (including climate/ecological concerns) must be included—and if omitted, this should be flagged and addressed at policy review. This remains high‑level, aligns with Part one and Part two expectations on early identification, whole‑school approaches and referral (DSL/MHST), and avoids clinical overreach. It also supports proportionate practice evidenced in my work (acknowledgement; careful language; institutional honesty; support structures; shared responsibility) and standard recognise→respond→refer pathways. A brief vignette (e.g., persistent climate‑related worry) could model validation language and referral triggers while keeping the guidance concise.
Rationale:
- Why it fits Part two: The redrafted Mental Health section already sets a high‑level expectation that staff identify early signs, understand when mental‑health needs become safeguarding, and act proportionately (Part one 44–47; Part two 218–225). Adding an explicit climate‑literate prompt here is consistent with KCSIE’s duty‑of‑care framing—no new workload, just clearer contextual risk awareness.
- What to ask for: Insert a line in Part two stating that resource/signposting lists and policy annexes should include foreseeable contextual stressors that may present as, or contribute to, mental‑health concerns—including climate and ecological concerns (e.g., climate‑related worry/distress)—and that omissions should be treated as a policy gap to address at review. This preserves the section’s high‑level nature while guiding consistent practice.
- Evidence from reports: Shows pupils’ strong emotional connection to nature, unequal access to protective outdoor experiences, and the risk of misplaced guilt if institutions overlook structural factors—making climate‑literate signposting a safeguarding (not activist) necessity. Your five “reasonable responsibilities” (acknowledgement; careful language; institutional honesty; support structures; shared responsibility) give staff practical guardrails for proportionate response.
- Practicality: A single sentence plus one short vignette (e.g., “pupil with persistent climate‑related worry”) would model validation language and recognise → respond → refer pathways (DSL/MHST), keeping KCSIE at the right altitude while preventing silent gaps in policies and resource lists.
Suggested KCSIE insertion (model text): “When listing issues, resources and further guidance for mental‑health‑related safeguarding, settings should include foreseeable contextual stressors, such as climate and ecological concerns, and ensure staff know how to validate, signpost and, where appropriate, refer via the DSL/MHST. Where such topics are absent from resource lists, this should be highlighted and addressed at policy review.”
Suggested school‑level policy line: “Our safeguarding and mental‑health policy recognises that some pupils experience climate‑related worry/distress. Staff will acknowledge concerns, use careful language that avoids misplaced guilt, and follow recognise → respond → refer pathways, including DSL and MHST signposting.”
Q34. Do paragraphs 104-115 provide clarity for schools and colleges about their legal obligations relating to toilets, changing rooms, and boarding and residential accommodation?
Response: No. 🏳️⚧️
Submision: The draft frames social transition as an “active intervention” and adopts a parent‑first posture, misapplying safeguarding and risking forced outing; scholarship shows this reverses child‑centred principles and can elevate harm for some pupils. Its heavy reliance on the Cass Review is unsound: peer‑reviewed appraisals document protocol deviations, misreported/weakly analysed findings, and asymmetric thresholds that downplay benefits, so it is not a reliable basis for statutory school guidance. On single‑sex spaces, a blanket “no exceptions” line undermines proportionate risk assessment; evidence links restrictive bathroom/changing policies to higher sexual‑assault risk for trans pupils, while chosen‑name use across contexts reduces depression/suicidality—i.e., supportive adjustments are protective. KCSIE should instead require case‑by‑case, child‑centred decisions (privacy‑enhancing single‑user facilities, supervised timings, and need‑to‑know information‑sharing). Single‑sex sport guidance should mandate documented risk assessments by sport, age and contact level to balance safety, fairness and participation. Further info: Bower-Brown et al. (2024) and D.M. Grijseels (2024).
Q35. Do paragraphs 94-97 provide clarity for schools and colleges about the circumstances in which the school is justified in having a policy of single-sex sports?
Response: No. 🏳️⚧️
Submision: Paragraphs 94–97 restate generic “safety/fairness” aims but offer no operational criteria (e.g., age, sport/contact level, curricular vs competitive), no requirement for a documented risk assessment, and no duty to consider participation‑preserving alternatives (adapted rules, tiered groups, supervised timings). That is insufficient for proportionate, defensible decisions. Safeguarding scholarship shows blanket, restrictive approaches increase harm and disengagement for gender‑diverse pupils, whereas supportive, proportionate adjustments are protective—KCSIE should embed that principle explicitly. Given serious methodological concerns about relying on the Cass Review to justify categorical positions, the section should avoid importing its assumptions and mandate an evidence‑led, case‑by‑case ramework. Existing school guidance already emphasises harm‑minimisation and individual planning; KCSIE should mirror this in sports policy. Further info: Bower-Brown et al. (2024) and D.M. Grijseels (2024).
Q42. Do you agree that referencing the voluntary national standards for non-school alternative provision in KCSIE helps reinforce the responsibility of schools to carry out safeguarding checks and ensure the suitability of commissioned provision?
Response: Yes. 🌡️
Submision: Referencing the voluntary national standards for non‑school AP in KCSIE strengthens commissioning practice and reinforces that schools retain safeguarding responsibility for placed pupils, including due diligence, clear checks and frequent reviews. It gives DSLs/governors an authoritative benchmark for contracts and assurance, reducing practice variability. To keep policies climate‑literate, QA should also note contextual risks linked to AP placements (e.g., travel patterns, site heat/flood exposure, access to supportive outdoor space), aligning with evidence that transport and environment are material factors for pupils and settings.
Rationale:
- Reinforces commissioning responsibilities. Adding the voluntary national standards for non‑school AP to KCSIE clarifies that schools remain responsible for safeguarding pupils they place, and should assure suitability and ongoing oversight of commissioned providers. This is consistent with the KCSIE draft’s AP section (e.g., due diligence, written assurance of checks, frequent reviews, knowing where a child is at all times) and the consultation’s stated intent.
- Quality assurance made practical. Explicit reference to the standards gives governors/DSLs a shared benchmark for contracts, visit reports and review cycles, reducing ambiguity and variance in practice across LAs and MATs.
- Climate‑literate safeguarding. My work shows school travel and site context can carry structural risks (e.g., transport burdens; environmental exposure), with transport a major systems factor for schools. Embedding the standards in KCSIE encourages QA to consider contextual factors (travel to site, heat/flood risk, nature access as a protective factor) to prevent silent gaps in safeguarding for AP cohorts
Q43. Does this inclusion support schools and local authorities in maintaining high standards of care for children educated outside mainstream settings?
Response: Yes. 🌡️
Submision: Embedding the voluntary national standards within KCSIE gives schools/LAs a common yardstick for selecting and monitoring AP, supporting consistently high standards of care outside mainstream. It complements existing KCSIE expectations for AP (clear records of where a child is, written assurance of checks, regular reviews, decisive action on concerns), making oversight more practical and auditable. To ensure safeguarding is climate‑literate, AP placement reviews should also consider contextual environment factors (travel to/from site, exposure to heat/flood risks, and access to supportive outdoor space), reflecting evidence of structural differences that can affect pupils’ wellbeing.
Rationale:
- Supports high standards beyond mainstream. By signposting the national standards inside KCSIE, schools/LAs have clearer expectations for selection, monitoring and review of AP, helping maintain consistent safeguarding and welfare across diverse settings.
- Operational fit with KCSIE duties. The KCSIE draft already specifies AP safeguards (keep location records; obtain written assurance of checks; review at least half‑termly; terminate where concerns persist). The new reference makes these expectations easier to implement and evidence.
- Climate‑literate implementation. Evidence highlights structural differences (e.g., rural travel burdens; variable access to protective nature), so using the standards can prompt AP contracts/reviews to include contextual environment checks (travel risk, extreme weather readiness, suitable outdoor access), preventing overlooked vulnerabilities.
Q44. Do you agree with the addition of guidance on safeguarding children with medical conditions, and does it help clarify when a medical condition may become a safeguarding issue?
Response: Yes. 🌡️
Submision: The new text is helpful and proportionate: it confirms that a medical condition is not inherently a safeguarding issue, while stating that, after any clinical incident, the responsible healthcare professional should consider with the DSL whether safeguarding duties are triggered. This gives staff a clear threshold and respects the boundary between healthcare management and safeguarding escalation (¶243). In implementation, settings should link Individual Healthcare Plans and risk assessments to safeguarding processes and consider foreseeable contextual stressors that may exacerbate conditions (e.g., environmental factors), consistent with a climate‑literate, proportionate approach I advocate for context‑aware safeguarding practice.
Rationale:
- Useful addition. The new paragraph on safeguarding children with medical conditions clarifies that having a condition is not, in itself, a safeguarding indicator, while also recognising that serious incidents can occur in schools. It sets a proportionate test: after a clinical incident, the responsible healthcare professional should consider with the DSL whether any safeguarding duty is triggered. This is clear, high‑level and operationally sound (¶243).
- Clarity on when it becomes safeguarding. By anchoring decisions in post‑incident review with DSL involvement, the draft draws an appropriate line between healthcare management and safeguarding escalation, reducing ambiguity for staff teams (¶243).
- Implementation and contextual risks. In policy and practice, schools should integrate Individual Healthcare Plans and risk assessments with safeguarding processes and consider foreseeable contextual stressors (e.g., environment, travel to sites) that could exacerbate conditions—an approach consistent with my climate‑literate safeguarding framework on proportionate, context‑aware practice. [The role o…KM RACKLEY | Word]
- Coherence with wider KCSIE. The clarification complements Part two’s emphasis on whole‑school systems, swift escalation when risk is identified, and coordinated multi‑agency working—keeping KCSIE at the right, high‑level altitude.
Q59. What aspects of KCSIE do you find most helpful in supporting safeguarding practice? 🌡️🏳️⚧️
Submision: Most helpful are the clear pathway from frontline action (Part one) to overnance/multi‑agency working (Part two), the unequivocal information‑sharing statements and CP‑file transfer requirements, and practical online safety expectations (4Cs + annual filtering/monitoring review with records). Annex B works well as a live reference by linking to specialist guidance (e.g., CEOP/IWF for AI‑generated CSAM; CEOP for FMSE), keeping KCSIE high‑level but actionable. Important caveat flagged in Q60–61: despite KCSIE’s contextual safeguarding frame, the draft contains no references to “climate”/“climate change.” With regards to protecting trans “gender questioning” children: KCSIE’s clear DSL leadership, information‑sharing expectations and “what to do” structure (Part 1/Annexes) give a usable, child‑centred framework for case‑by‑case decisions, which is essential when supporting gender‑questioning pupils. When applied proportionately, this framework aligns with the social‑science evidence that supportive school climate and chosen‑name/pronoun use are protective (lower depression/suicidality).
Rationale:
- Coherent spine. Part one gives clear frontline actions (reassure, act, escalate), while Part two embeds whole‑school systems (DSL, mental‑health lead, MHST signposting, multi‑agency working), which aids consistent practice.
- Records & information sharing. The explicit “data protection does not prevent sharing” message and transfer expectations for CP files reduce hesitation and protect continuity.
- Online safety assurance. The 4Cs, at‑least annual filtering/monitoring review and record‑keeping make assurance practical and auditable.
- Annex B as a live reference. Curated links (e.g., CEOP/IWF AI‑generated CSAM; CEOP FMSE) keep the core text high‑level while directing DSLs to specialist practice.
- Important caveat flagged in Q60–61: despite KCSIE’s contextual safeguarding frame, the draft contains no references to “climate”/“climate change.”
- Critiques of the Cass Review – TransActual; Bower-Brown et al. (2024)
Q60. What aspects of KCSIE do you find least helpful or most challenging? 🌡️🏳️⚧️
Submision: Climate Change: The main challenge is an omission: the 2026 draft mentions “climate” / “climate change” zero times, so climate is not recognised as a contextual safeguarding risk anywhere in KCSIE’s text. This risks schools overlooking climate‑related worry/distress and environmental context factors in policy, training and resource lists. Evidence from my work shows pupils’ nature connection and institutional structures (e.g., transport) can shape wellbeing and agency; without an explicit KCSIE cue, those needs can be missed. Even the Government’s own analysis shows increasing impacts of climate change to both learning and mental health of children, and yet none of that is considered. Climate change is a safeguarding issue. Gender: Draft text risks reframing social transition as a high‑risk “intervention” and tilting to a parent‑first posture, which can lead to forced outing—a recognised harm factor. The section’s reliance on the Cass Review is deeply problematic: peer‑reviewed analyses document misreported/weakly analysed findings and double standards of evidence, so it is an unsafe basis for categorical positions in schools.
Rationale:
- Critical omission. The draft contains zero references to “climate”/“climate change,” so climate is not treated as a safeguarding risk anywhere in KCSIE 2026 text. This creates a policy blind‑spot for settings already encountering climate‑related worry/distress and environmental context risks.
- Practice impact. My evidence shows many pupils have strong emotional connections to nature; climate‑related concerns can surface pastorally; institutional factors (e.g., transport) shape risk/agency. Without an explicit pointer in KCSIE, schools may omit climate from “issues/resources” lists, leaving silent gaps in policy and training.
- Navigation. Beyond the omission, some topics are split across Parts/Annex; short vignettes would aid rapid, role‑specific action.
- Critiques of the Cass Review – TransActual; Bower-Brown et al. (2024)
Q61. Is there anything missing from KCSIE that would help you safeguard children more effectively? 🌡️🏳️⚧️
Submision: Climate Change: Add an explicit, climate‑literate expectation. Insert a concise line in Part two (and/or Annex B preface) that when listing issues/resources for mental‑health, preventative education and online safety, schools must include foreseeable contextual stressors, including climate/ecological concerns; if absent, this must be flagged and addressed at policy review. This closes the identified gap. Included role‑based vignettes – one‑paragraph scenarios (e.g., persistent climate‑related worry; children isolated at home due to flooding’ behavior deregulation and health issues due to excessive heat etc). Gender: A short, child‑centred decision protocol: (1) need‑to‑know information‑sharing with pupil consent where safe; (2) documented, case‑by‑case risk assessments for names/pronouns, facilities and sport; (3) default use of chosen names/pronouns unless a specific safeguarding risk is evidenced; (4) privacy‑enhancing facilities (single‑user options) rather than categorical bans.
Rationale:
- Add an explicit, climate‑literate expectation. Insert a concise line in Part two (and/or Annex B preface) that when listing issues/resources for mental‑health, preventative education and online safety, schools must include foreseeable contextual stressors, including climate/ecological concerns; if absent, this must be flagged and addressed at policy review. This closes the identified gap.
- Role‑based vignettes. One‑paragraph scenarios (e.g., persistent climate‑related worry; AI‑manipulated image) showing validation language and recognise→respond→refer pathways (DSL/MHST/police).
- Cross‑linking & versioning. Mirror Annex B links (CEOP/IWF; FMSE) from Part five/Online safety; show version/date so DSLs track updates.
- Critiques of the Cass Review – TransActual; Bower-Brown et al. (2024)
Geogramblings 