Access to facilities

Response

1. Provide a copy of any current policy with regard to officers/staff/witnesses/visitors regarding access to toilets, changing rooms and showers in your force area and whether these are restricted on the basis of sex.

 

Please see attached the following procedural guidance, which contains information relevant to this question:

 

• Disclosure 1 – Avon and Somerset Police Transgender and nonbinary inclusion in the workplace guidance

 

For ease of reference, the section on facilities has been copied below:

 

Section 10 Facilities

10.1 Creating an environment where everybody can use facilities, they feel comfortable in and best meet their needs, which (where practical) should include gender-neutral facilities. Prioritising privacy and safety is vital with lockable gender-neutral private cubicles alongside additional separate-sex facilities to offer choice.

 

10.2 Where possible there should be access to gender neutral facilities (wherever this can be reasonably accommodated at the location), as well as single gendered facilities and accessible/disabled facilities at a location.

 

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.

 

10.4 For advice and guidance please contact HR Advisory or Inclusion and Diversity Lead.

 

Please note that this guidance and the corresponding Equality Analysis is currently under review.

 

2. Specify if you have the following throughout the force area with regard to toilets, changing rooms and showers:
   Single sex provision (strictly on the basis of biological sex only)
   b. Gender neutral provision
   c. Unisex provision

 

Recorded information relevant to this question is held within our standard design guide, which provides a framework for the Estates department’s intent in how it designs and operates police premises in Avon and Somerset. It currently states:

 

Sufficient separate female and male toilets and universal toilets is considered optimal across a site to include everyone. Space is likely to be a constraint to achieving this in smaller premises’ and includes the EHRC guidance with respect to toilets, changing and washing facilities. A distinction is made between locker rooms and changing facilities. Following the Supreme Court judgement, a workplace review by Estates has produced an inventory of facilities across the property portfolio and shows provision by location. Provision varies. There is not a single-sex, gender neutral and unisex offer in terms of toilets, changing rooms and showers at every site. Most toilets, changing rooms and showers, not specifically single sex, are floor to ceiling partitions and doors and are fully lockable.

 

3. Provide any policies that have specific regard to whether you allow persons who identify as ‘trans’ or ‘non binary’ to access the facilities of their choice or not. Include any equality impact assessments and risk assessments relating to these.

 

Please see the facilities section of the guidance provided above in response to question 1.

 

Additionally, please find attached the following Equality Analysis completed in relation to that guidance, which is also under review:

 

• Disclosure 2 – Equality Analysis for Transgender and Non-Binary Inclusion at Work Sept 2024_Redacted

4. If you provide toilets/changing rooms/showers that are not specifically single sex, specify if they are floor to ceiling doors/partition walls and fully lockable.

 

Please see our response to question 2 above.

5. Provide a copy of any changes, proposed or carried out, to the review of existing workplace facilities in your force following the Supreme Court judgment of 16/4/25 by your Estates, Legal, HR, Equalities teams/advisors or by your staff associations/networks. Include any workplace union consultations.

 

Please see our response to question 2 above.

 

In addition, our Estates department have advised that for new police stations in Yeovil and Bath there will be an offer of single sex and universal toilet facilities, in addition to private places to change for all.

6. Provide a copy of any internal communications made to staff following the above judgment regarding access to workplace facilities and any changes thereof, including those to or from staff networks.

 

Please see attached the following documents:

 

• Disclosure 3 – Internal Blog post – Supreme Court Ruling on legal definition of a woman
• Disclosure 4 – Intranet guidance on Transgender and non-binary inclusion at work procedure

 

 

Disclosure 3 is an internal blog post authored by Chief Officer Louise Hutchison.

 

Disclosure 4 is a copy of intranet guidance available to all officers. This intranet page is currently under review.

7. Provide copies of any internal stakeholder engagements or consultations regarding access to workplace facilities. Specify which stakeholder groups and when engaged with.

 

No internal stakeholder engagements or consultations are held in relation to your request.

 

 

Within disclosure documents 1, 2 and 4, names have been redacted under the following exemption:

 

Section 40(2) – Personal Information

 

Section 40 is a class based absolute exemption and there is no requirement to consider the public interest in this case.

 

Any information to which a request relates is exempt if it constitutes personal data and would contravene any of the data protection principles.  Personal data relates to a living individual who can be identified directly from the information, or identifiable indirectly in combination with other available information.

 

To disclose the information would identify individuals, which would breach principle 1 (lawfulness, fairness and transparency) of the Data Protection Act 2018.

This serves as a partial refusal notice under Section 17(1) of the Freedom of Information Act.