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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Gender-Inclusive Care Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} provides inclusive, respectful, and person-centred care for all service users, regardless of their gender identity, gender expression, or sex characteristics. Our commitment to gender-inclusive care ensures that every individual receives dignified, equitable, and high-quality support, free from discrimination.

This policy has regard to and aligns with:

• The Equality Act 2010 (including the protected characteristic of genderreassignment, and the separate protected characteristic of sex) and our duties to eliminate discrimination, harassment and victimisation and to advance equality of opportunity.
• The Human Rights Act 1998 (in particular respect for private and family life, dignity, autonomy and non-discrimination in the delivery of care and support).
• The Social Services and Well-being (Wales) Act 2014 (person-centred care, well-being, voice and control).
• The Regulation and Inspection of Social Care (Wales) Act 2016 and The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 (as amended) (standards of care and support, respect, sensitivity, language and communication, information, safeguarding, complaints and quality monitoring).
• Welsh Government Statutory Guidance for providers of care home and domiciliary support services (last updated 27 March 2024), which service providers and responsible individuals must have regard to.
• The Mental Capacity Act 2005 and Deprivation of Liberty Safeguards (DoLS) (where relevant to decision-making and restrictions in care and support).
• Welsh Language Standards / Active Offer expectations to meet language needs and support people to receive care in Welsh where desired.
• The Gender Recognition Act 2004 (including confidentiality protections relating to a Gender Recognition Certificate where applicable).
• UK GDPR and the Data Protection Act 2018 (lawful, fair and transparent handling of personal data, including enhanced protections for sensitive information and confidentiality).
• Social Care Wales Codes of Professional Practice (standards of conduct, practice and employer expectations for a safe, respectful and appropriately supported workforce).
• Care Inspectorate Wales (CIW) inspection expectations, including the May 2024 Inspection Framework and its rights-based approach.

2. Scope

This policy applies to:

• All employees, including care staff, managers, and administrative personnel.
• Service users receiving care, regardless of their gender identity.
• Family members, advocates, and external healthcare professionals interacting with service users.

It covers:

• Inclusive language and respectful communication.
• Confidentiality and data protection.
• Personalised care planning and gender-sensitive services.
• Staff training and competency.
• Reporting and addressing discrimination or bias.

3. Commitment to Gender-Inclusive Care

{{org_field_name}} is committed to:

• Recognising and respecting all gender identities and expressions.
• Providing a safe and affirming environment for transgender, non-binary, and gender-diverse service users.
• Ensuring equitable access to healthcare, personal care, and support services.
• Training staff to deliver gender-inclusive care with dignity and respect.

4. Inclusive Language and Respectful Communication

4.1 Addressing Service Users Correctly

• Care staff must use a service user’s preferred name and pronouns (e.g., he/him, she/her, they/them).
• If a service user’s gender identity is unclear, staff should politely ask: “How would you like to be addressed?”
• Staff must update records to reflect correct pronouns and preferred names, even if different from legal documentation.

4.2 Avoiding Gender-Based Assumptions

• Care workers should not assume gender based on appearance or voice.
• Avoid gendered language such as “sir” or “madam” unless the service user confirms preference.
• Use gender-neutral terms (e.g., “partner” instead of “husband/wife”).

4.3 Language, communication and the Welsh “Active Offer”

We will take reasonable steps to meet each person’s language and communication needs, including offering information and day-to-day communication in the individual’s language of need and choice. Where required, we will support alternative and accessible communication methods (for example large print, easy read, pictorial tools, BSL or other aids).

We will actively offer services in the Welsh language and will record an individual’s language preference within their care documentation/personal plan. Where a person wishes to receive care through the Welsh language, we will plan staffing and communication to support this as far as reasonably practicable.

5. Confidentiality and Data Protection

Gender identity information, trans status/history, medical transition information and related care details must be handled in line with UK GDPR and the Data Protection Act 2018. We will ensure information is:

• collected only where it is necessary and relevant to safe, person-centred care;
• recorded accurately and respectfully;
• shared only on a strict need-to-know basis; and
• protected through appropriate access controls, secure storage and staff confidentiality obligations.

5.1 Protecting Gender Identity in Records

• A service user’s gender identity must remain confidential unless they consent to sharing it.
• Care records should be updated only with the service user’s approval.
• Deadnaming (using a previous name) is strictly prohibited once a preferred name is recorded.

5.2 Disclosure and sharing of Information

Staff must not disclose a person’s gender history, trans status, previous name, or any gender-related personal data to anyone (including family members) without the individual’s explicit consent, unless there is a clear legal basis to do so (for example safeguarding, serious risk of harm, or another lawful requirement).

Where staff become aware that a person holds a Gender Recognition Certificate (GRC), or otherwise become aware of protected information relating to a person’s gender recognition, this information must be treated as strictly confidential and only shared where lawful and necessary. Any request for disclosure (internal or external) must be escalated to the Registered Manager (and, where needed, the Data Protection Lead) before any information is released.

5.3 Recording preferred name/pronouns and preventing “deadnaming” in practice

We will record a person’s preferred name, title and pronouns prominently within the care documentation/personal plan so staff can use them consistently. If legal/identity documentation differs, we will record the legal name only where necessary for administration (for example invoicing or statutory documentation) and will clearly mark it as “legal name – not for day-to-day use”, to reduce the risk of accidental disclosure or distress.

Any historic name or gender marker will be restricted to the minimum necessary and access-limited. Staff must follow record-keeping and confidentiality controls to prevent inadvertent disclosure (for example in visit notes, rota notes, shared communication logs, or messages to families/professionals).

6. Personalised Care Planning and Gender-Sensitive Services

6.1 Person-Centred Assessments

• Care plans should respect gender identity and lived experience.
• Clothing, grooming, and personal hygiene support should align with the service user’s gender expression.
• Toileting and bathing preferences should be accommodated, including preferences for same-gender care staff where possible.

All gender-related preferences (including name/pronouns, clothing/grooming support, privacy expectations, and intimate care preferences such as who provides support) will be agreed with the individual and recorded in their personal plan, and staff will follow the plan consistently to protect dignity and reduce distress.

6.2 Gender-Affirming Medical Support

• If a service user is undergoing hormone therapy or gender-affirming treatments, staff must:
  • Ensure medications are administered correctly as per prescription.
  • Be aware of side effects or additional health concerns.
  • Support access to LGBTQ+ inclusive healthcare professionals.

6.3 Inclusive Personal Care Practices

• Respect chest binding, prosthetics, wigs, or other gender-affirming items.
• Ensure privacy and dignity when assisting with dressing and personal hygiene.
• Support grooming and self-care routines that align with gender identity.

6.4 Advocacy and support to express views

Where a person would benefit from support to understand information, express their wishes, or raise concerns, we will offer information about advocacy and support access to relevant advocacy/self-advocacy services.

This includes signposting to Llais complaints advocacy where the individual wants independent support to raise a concern or make a complaint about social care.

6.5 Consent, capacity and decision-making

Staff must seek and record consent for sensitive discussions and support related to gender identity, expression and intimate personal care, and must support the individual to make their own decisions wherever possible. Where there is doubt about a person’s capacity for a specific decision, staff will follow Mental Capacity Act principles, involve appropriate professionals where required, and work in the person’s best interests, taking account of the person’s wishes, feelings, beliefs and values and the least restrictive approach.

7. Staff Training and Competency

7.1 Mandatory Gender-Inclusive Training

• All staff must complete gender-awareness training during induction.
• Training includes:
  • Understanding gender identity, gender expression, non-binary identities and respectful practice in personal care.
  • Legal protections and responsibilities (Equality Act 2010 – gender reassignment and sex; Human Rights Act 1998).
  • Confidentiality, information sharing and record-keeping in line with UK GDPR/Data Protection Act 2018.
  • Mental Capacity Act 2005 principles and supporting decision-making, including consent for sensitive personal care discussions where relevant.
  • Communication, accessibility and Welsh language Active Offer expectations.
  • Professional standards aligned to Social Care Wales Codes of Professional Practice.

7.2 Ongoing Education

• Staff will receive annual refresher training on gender inclusion.
• Guest speakers or training from LGBTQ+ organisations will be incorporated.

8. Reporting and Addressing Discrimination or Bias

8.1 Zero-Tolerance for Discrimination

• {{org_field_name}} does not tolerate discrimination, harassment, or exclusion based on gender identity.
• Any staff, service users, or visitors found engaging in discriminatory behaviour will face disciplinary action.

8.2 Reporting Gender-Based Discrimination

• Any concerns must be reported to the Registered Manager immediately.
• Affected service users will be supported and protected from further discrimination.
• Whistleblowing procedures apply to staff who witness or experience discrimination.

8.3 CIW Compliance and Monitoring

• CIW will assess gender inclusivity as part of regulatory inspections.
• Annual equality audits will ensure best practices are maintained.

8.4 Complaints and independent support (Llais)

Individuals (and/or their representatives) will be provided with accessible information on how to make a complaint or raise a concern. Complaints and outcomes will be recorded, analysed for learning, and handled in line with our Complaints Policy and regulatory requirements.

Where an individual wants independent help to raise a concern or make a complaint about social care, we will signpost to Llais complaints advocacy and support the person to access it if they wish.

9. Monitoring and Continuous Improvement

• The Registered Manager is responsible for ensuring compliance with CIW regulations and gender equality laws.
• Service user feedback will be regularly reviewed to improve gender-inclusive practices.
• Quarterly reviews of care plans will ensure that gender identity and personal preferences are respected.

Monitoring will include periodic audits of care documentation/personal plans to confirm that preferred name/pronouns, language needs (including Welsh language preferences), privacy/intimate care preferences, and any reasonable adjustments are recorded clearly and followed in practice, with actions tracked to completion where gaps are identified.

10. Related Policies

This policy should be read in conjunction with:

• Equality, Diversity, and Inclusion Policy (DCW30).
• Confidentiality and Data Protection (GDPR) Policy (DCW34).
• Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13).
• Dignity and Respect in Care Policy (DCW31).
• Staff Conduct and Code of Ethics Policy (DCW28).

11. Policy Review

This policy will be reviewed annually or sooner if required by legislative updates, CIW guidance, or operational needs.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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