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Trans guidance and procedures

Date of request: 1 February 2024
Reference: 180/24


The questions can be see below in bold, with answers following each question.


  1. Within your organisation, what policies exist to support staff members who identify as transgender and are transitioning?

Interpreting ‘policies’ broadly to include guidance, we have identified the following document specifically relevant to your request:

  • Avon and Somerset Police Trans Guidance for an Individual

Our Transgender Non-binary and Gender Reassignment in the Workplace Procedure also contains relevant sections.

  1. With respect to the question above, could you please provide a copy of the policies to support staff who identify as transgender?

Please see attached copies of the above documents.

You will see that a note has been added to Section 18 of the Transgender Non-binary and Gender Reassignment in the Workplace Procedure.  As the note states, this part of the procedure is currently under review, as explained in more detail here.

Additionally, redactions have been made to the document as a whole to remove personal information (names), in line with the following exemption:

  • Section 40(2) – personal information

This is an Absolute exemption so therefore there is no requirement to conduct a harm or public interest test. Any information is exempt from disclosure under the Freedom of Information Act if it relates to or is supplied by another individual and disclosure of that information would contravene any of the data protection principles set out in:

(a) Article 5(1) of the GDPR, and

(b) Section 34(1) of the Data Protection Act 2018

A Freedom of Information Disclosure is a disclosure to the world. Therefore information that is provided can be viewed by any member of the public. Should information be provided from which a living individual could be identified this would constitute personal data. This would then become a breach of rights provided under the Data Protection Act 2018.  Information held on an individual by Avon and Somerset Constabulary is done so lawfully and is used for a policing purpose in line with the principles set out in the GDPR. Our privacy policy can be viewed here.

This serves as a partial refusal notice under section 17(1) of the FOI act.

  1. Do you have any information publications or presentations available to staff regarding LGBTQ+ and Transgender, if so please could you provide details and copies of the information.

We have an intranet page on this subject containing links to the following documents.  The additional documents not previously referred to have been attached.

  • Avon and Somerset Police Trans Guidance for an Individual
  • Avon and Somerset Police Trans Guidance for Managers
  • Avon and Somerset Police Trans Guidance Policing Sector
  • Transgender Non-binary and Gender Reassignment in the Workplace procedure

The page also has the following video embedded:


  1. How many persons who identify as transgender are employed or volunteer with your organisation, and at what grade or position are they employed?

Information recorded by Avon and Somerset Police relating to gender identity of employees is self-defined and voluntary to provide, so may not be accurate or complete.  The recorded number of trans employees currently is 12.

In relation to your request for the grade or position, these details have been deemed exempt as they would identify personal information due to the low number of employees they relate to.  As with redactions for question 2, the exemption applicable is Section 40 (2) relating to third party personal information.

  1. What advice and information do you supply to managers and staff regarding Transgender? Do you provide any specialist training in dealing with colleagues or clients who identify as transgender? If so, please provide copies of the relevant policies and material.
    Please see the Guidance for Managers attached in response to question 1
  2. Does your organisation have any connections with Stonewall or similar organisations to support employees from the LGBTQ+ and Transgender community, and if so, please could you provide further details and copies of any documents or policies?

None at present.

7. Do you have any specific policies to support staff members transitioning/transgender where they are deployed or employed in the organisation and in dealing with members of the public? If so, please could you provide further information?

Please see the Workplace Procedure document provided in response to questions 2 and 3.

  1. Do you have a specific lead or individual(s) who deal with LGBTQ+ issues or liaisons within the organisation? If so, please could you provide details?
    Our LGBT Staff Network Chair and Deputy have this role within the organisation. Once again contact details have been deemed exempt under Section 40(2) – personal information (see our response to question 2 above). In line with national advice, we would not generally disclose names of specific officers below the rank of Superintendent under Freedom of Information.
  2. Do you have specific policies regarding keeping female, LGBTQ+ and transgender staff safe? If so, please provide details and copies of any relevant policies? 

No further information is held beyond the documents already provided.

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