Healing Process policy suite

Sex, Gender Reassignment and Gender Identity Policy

1. Purpose

To provide respectful, lawful and clinically safe treatment of information about sex, gender reassignment and gender identity, and to prevent harassment or discrimination while preserving data needed for safe care.

2. Scope and status

This policy applies to product fields, identity and profile design, photography guidance, communication, workforce conduct, research, analytics and provider configuration. Providers must align deployment with current law, clinical standards and their approved single-sex, privacy and records policies.

Core supplier and product policy

3. Policy principles

• Every person must be treated with dignity and addressed respectfully. Deliberate harassment, humiliation, outing or misuse of personal information is prohibited.
• The service will distinguish concepts only when there is a defined purpose. Sex, gender identity, title, pronoun, name, organ inventory, pregnancy possibility and clinically relevant history must not be collapsed into one ambiguous field.
• Clinical accuracy is essential. Respectful communication must not erase information that an authorised professional needs for safe assessment, screening, medication, safeguarding or records reconciliation.
• Collection is minimised. The interface will not ask intimate questions merely to personalise marketing or because a field is customary.

4. Mandatory requirements

• Use a preferred/display name and respectful form of address in ordinary interfaces while retaining verified legal or demographic identifiers only where needed for identity, records or another lawful purpose.
• Allow pronouns to be recorded where the person wishes, without forcing disclosure or presenting pronouns as a substitute for clinical information.
• Where sex is required for a defined clinical, legal, statistical or identity purpose, explain or document that purpose and restrict access appropriately.
• Provide privacy during image capture and review, especially for intimate body areas, and support a chaperone, same-sex practitioner request or other reasonable preference through the provider’s process where practicable and lawful.
• Do not expose a person’s transgender status, previous name or related history to users who do not require it for their role.
• Configure search, matching and record reconciliation so that name changes do not create duplicate records or misidentification.
• Test automated or analytical functions for differential performance and avoid inferring sex or gender identity from an image.
• Marketing and training must not make contested legal or clinical claims. Wording is reviewed when law, codes or provider requirements change.

5. Procedure and escalation

• A user can request correction of display information through the approved process; historical clinical records are amended by correction or annotation rather than deceptive overwriting.
• A concern about privacy, harassment, inappropriate disclosure or discriminatory access is escalated to the equality and data-protection route, with safeguarding or patient-safety escalation where relevant.
• Product changes affecting demographic fields, matching or access undergo clinical, equality, privacy and legal review before release.
• Providers define how staff respond to requests about ward, clinic, chaperone or same-sex care arrangements under current law and local policy; the app does not make that allocation autonomously.

6. Roles and responsibilities

Equality Lead

maintains respectful practice, complaints analysis and legal-policy review.

Clinical Safety Officer

ensures demographic design does not create misidentification or unsafe clinical omission.

Data Protection Officer

controls access, disclosure, correction and minimisation of sensitive information.

Product team

implements distinct, purposeful fields and prevents unauthorised exposure.

Providers and professionals

apply current law and local clinical, chaperone, privacy and single-sex policies.

7. Records, confidentiality and retention

Keep field definitions, data dictionary, purpose mapping, access matrix, equality and privacy reviews, correction records, complaints, incidents and change approvals.

Records created under this policy must be accurate, attributable, access-controlled and linked to the applicable retention schedule. Where a provider is the controller or authoritative record holder, its documented instructions and legal duties apply.

8. Monitoring, assurance and review

Review annually and promptly after material legal guidance, regulatory interpretation, provider policy or identified safety/equality issue. Monitor complaints, misidentification, duplicate records, correction requests and access disparities.

Material non-compliance is reported through the relevant clinical-safety, patient-safety, data, security, safeguarding, HR, contractual or whistleblowing route. Corrective actions receive an owner, target date and effectiveness check.

9. Training and communication

The policy owner identifies which roles require awareness, operational or specialist training. Training is accessible, version-controlled, role-specific and refreshed after material change or evidence that understanding is inadequate. Providers communicate local procedures and contact routes before users are granted access.

10. Related documents

• Equality, Diversity, Inclusion and Human Rights Policy
• Data Protection and Confidentiality Policy
• Consent, Capacity, Carer and Proxy Access Policy

11. Approval record