Feb 28, 2013 - In: US Conference on. AIDS. Palm Springs, CA. World Professional Association for Transgender Health (WPAT
National LGBTI Health Alliance
lesbian, gay, bisexual, transgender, intersex and other sexuality, sex and gender diverse people and communities PO Box 51 Newtown NSW 2042 (02) 8568 1120, 0458 039 685 General Manager: Warren Talbot
28 February 2013 Australian Statistician Australian Bureau of Statistics ABS House 45 Benjamin Way BELCONNEN ACT 2617 [email to:
[email protected]]
Dear Statistician REVIEW OF THE ABS “SEX STANDARD” The National LGBTI Health Alliance (the Alliance) is the national peak health organisation for a range of organisations and individuals from across Australia that work together to improve the health and wellbeing of lesbian, gay, bisexual, trans/transgender, intersex and other sexuality, sex and gender diverse (LGBTI) people and communities. We support measures which contribute to improved health and wellbeing for LGBTI Australians. Formed in 2007, the Alliance includes the major providers of services for LGBTI people in Australia, with Members drawn from each State and Territory, in addition to qualified individuals. The Alliance provides a representative national voice to: develop policy and support LGBTI health issues; seek increased commitment to services for LGBTI people; develop the capacities of LGBTI organisations; and support evidence-based decision-making through improved data collection covering sexuality, sex and gender identity. We manage several health projects, particularly in mental health and suicide prevention. The Alliance appreciates the opportunity to comment on the ABS Sex Standard, and commends the Bureau for its community consultation. We know that the Standard is used by the ABS in all their household surveys and becomes an authoritative document for all researchers looking to frame questions and responses regarding sex in a consistent manner. The current Sex Standard provides no recognition of transgender people and limited recognition of intersex people. The National LGBTI Health Alliance believes that an inclusive solution needs to be found to ensure that appropriate statistics on the health and wellbeing needs of people with diverse sexes and genders can be accommodated within the Sex Standard and/or potential new Gender Standard.
www.lgbtihealth.org.au
[email protected] ABN 45 138 151 569 All donations over $2 are tax deductable: make a secure online donation at www.givenow.com.au/lgbtihealthalliance
Accordingly, we propose the following five broad principles to guide decision-making on this matter. In addition to the five principles, we include: (a) a short Attachment which summarises areas for consideration; and (b) a longer Discussion Paper on developing an evidence-informed environment for LGBTI health policy. The principles being proposed by the Alliance are: 1. The Sex Standard should acknowledge more than just biological ‘sex’ That there is a strong need for the ABS to collect data that accurately record sex and gender information relevant to transgender people, intersex people and other people of diverse sexes and genders. The current Sex Standard data collection method does not acknowledge the possible distinction between sex and gender. For example, someone who identifies as female may be classified as male and could not be recorded as a woman. 2. The Sex Standard should include more than just ‘male’ or ‘female’ That there is a strong need for the ABS to collect data that accurately record sex information beyond the current ‘male ‘ or ‘female’ options. The Sex Standard currently contains an ‘intersex or indeterminate’ sex classification as optional, with the instruction that this option should not generally be available or used on forms. The National LGBTI Health Alliance believes that an inclusive solution needs to be found to ensure the accuracy of statistics on the health needs of intersex people. 3. The Sex Standard Review should explore and discuss the complexity of sex and gender There is a need for the ABS to collect sex, gender, and sexuality data in a way which is inclusive and recognises the diverse health needs of people with a range of sex and gender identities and sexualities. This includes people whose gender identities are not ‘woman’ or ‘man’. This also includes people whose sex or gender cannot be determined accurately by others based on cues such as observation, relationship to respondent or first name. To ensure data integrity, the Sex Standard Review should consult people whose data are likely to be misclassified unless the Standard gives sufficient attention to this range of complexity. Consideration of the differences between current sex listed on birth certificate, assigned sex at birth, people’s own classifications of their genders and their genders as perceived by others need to be considered by ABS in their review to ensure the revised standard achieves the highest level of statistical accuracy in data collection. 4. The ABS should look to collect data on sexual orientation Additionally, there is a need for the ABS to consider the best way to collect sexual orientation information to ensure accurate records of lesbian, gay and bisexual people.
5. The Alliance has expertise in this area regarding how to address points 1-4 Organisations such as the National LGBTI Health Alliance (and its Members) have expertise in this area and are able to provided more detailed advice about accurate terminology, definitions, data classification and coding, data collection methods, output, and measurement issues and related classifications. Feel free to contact the Alliance’s Health Policy Officer, Mr Y Gavriel Ansara if you would like to discuss any of the above matters in order to assist the Bureau in this matter. Mr Ansara’s contact details are:
[email protected], or telephone (02) 8568 1110.
Yours sincerely
Warren Talbot GENERAL MANAGER
Appendix Relevant Points for Submission to ABS Sex Standard Review •
Statistical inaccuracies increase when people’s genders are determined by data collectors.
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The Los Angeles County Transgender Population Estimates 2012 Report acknowledged that health providers underreported the numbers of transgender patients and estimated that approximately half of cases had been misclassified (Division of HIV and STD Programs, Los Angeles County Department of Health, 2012). In health research, trans women are often miscounted as men who have sex with men (MSM) (Sausa, Sevelius, Keatley, Iniguez, & Reyes, 2009), and few studies recognise gay and bisexual trans men as MSM (Bauer, Redman, & Bradley, 2012; Sevelius, 2007). The UK Office of National Statistics (ONS) Trans Data Position Paper (ONS, 2009) noted that people are more likely to respond affirmatively to questions that use language with which they are comfortable and less likely to respond accurately to surveys that classify their genders differently from how they classify themselves. For example, many trans people are offended by surveys that expect all trans people to select ‘other’ or ‘trans’ instead of woman or man. Trans and intersex community consultation can identify suitable language.
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Current best practice overseas is to use more than one question about sex and gender.
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A single question approach that groups questions about transgender status with other sex and gender questions can lead to inaccurate data (ONS, 2009; Sausa et al., 2009). Most trans people do not consider themselves to be a third sex (ONS, 2009). Intersex people are not “female” or “male” and can identify as women or men (OII, 2009). Questions that combine sex and gender typically exclude people who have non-binary genders (i.e., they do not identify as women or men).
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Privacy concerns of transgender and intersex respondents can affect data accuracy. Trans community organisations raised widespread concerns that transgender people often do not identify as trans in data collection due to concerns about individually identifying data and lack of confidence in their anonymity; these organisations recommended pilot surveys to determine how to address such concerns (ONS, 2009).
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References in the Sex Standard should be updated with current evidence-based sources.
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Psychoanalyst Robert Stoller’s 1968 book on sex and gender is the sole gender-specific reference in the Sex Standard. In the 45 years since this book was published, numerous evidence-based publications on sex and gender have critiqued Stoller’s approach. Approaches that treat trans people’s genders as disordered or as inherently problematic should be avoided (WPATH, 2010), as should approaches that pathologise intersex people.
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Please be aware when using UK and US sources that they often exclude intersex people.
References Bauer, G., Redman, N., & Bradley, K., for the TransPULSE Project. (February, 2012). Gay, bisexual and MSM trans guys: No assumptions! A report prepared for the Gay Men’s Sexual Health Summit, Toronto. Available at: http://transpulseproject.ca/wp-content/uploads/2012/04/Gay-Bisexual-and-MSM-TransGuys-Report-for-GMSH-Summit-2012-vFINAL.pdf Division of HIV and STD Programs, Los Angeles County Department of Public Health. (2012). Los Angeles County Transgender Population Estimates 2012. Available at: http://publichealth.lacounty.gov/wwwfiles/ph/hae/hiv/Transgender%20Population%20Estimates%20212-13%20pub.pdf Office of National Statistics, UK. (May, 2009).Trans Data Position Paper. Available at: http://www.ons.gov.uk/ons/guide-method/measuring-equality/equality/equality-data-review/transdata-position-paper.pdf Organisation Intersex International Australia. (June, 2009). Federal Department of Health and Ageing’s New National Women’s Health Policy. [Submission]. Available at: http://oii.org.au/1800/submissionfederal-department-health-ageings-national-womens-health-policy/ Sausa, L. A., Sevelius, J., Keatley, J., Iñiguez, J. R., & Reyes, M. (2009). Policy Recommendations for Inclusive Data Collection of Trans People in HIV Prevention, Care & Services. Center of Excellence for Transgender HIV Prevention: University of California, San Francisco. Available at: http://www.transhealth.ucsf.edu/trans?page=lib-data-collection Sevelius, J. (2007). The transgender men’s study: Preliminary findings. In: US Conference on AIDS. Palm Springs, CA. World Professional Association for Transgender Health (WPATH) Board of Directors. (2010). Depsychopathologisation statement released May 26, 2010. Retrieved from http://wpath.org/announcements_detail.cfm?pk_announcement=17.
