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Writer's pictureKathryn Watkins

Filthy Lesson Content in schools - Court Appeal

The details of this case are as follows:




After a Mother of a 13-year-old girl in a secondary school in Lewisham, UK noticed some very disturbing content within her daughters RSE lessons requested (on several occasions) to see the work being taught to her daughter, she was stonewalled through-out and was not allowed to view it. This led to a complaint being put in to the ICO (Information Commissioners Office) which was also denied. Therefore the mother had to take a civil case to court to appeal the decision of the ICO. Read about the incident here.


Thankfully, Tribunal Tweets on Twitter transcribed the case as it was happening and the following is how it was transcribed by them - I did take screen shots but they aren't clear unfortunately. Please note that the case hasn't finished yet, the closing statements are to be read on the 10th May 2023.


"Good afternoon. We shall shortly be reporting from the afternoon session Clare Page's appeal against an ICO ruling."

CP: the Appellant, Clare Page ZG: Zoe Gannon, barrister for CP


School: first respondent, the school CP's child attends. The School is not represented at this hearing.


SSE/SoSE: second respondent, the School Of Sexuality Education - a third-party organisation offering RSE/PHSE lessons for schools, including that attended by CP's child. SW: Susan Wright, barrister for SSE

ICO: Information Commissioner's Office, which ruled that School / SSE were not obliged to make SSE materials fully available to parents. This is the decision being appealed today. The ICO is not represented at this hearing.


The case is being heard by:

J: Judge Buckley assisted by two panel members (P)


Witnesses: CP: The appellant (evidence given this morning) DP: Dolly Padalia, CEO of SSE (began evidence this morning, to be continued now).

We expect the hearing to begin with the cross-examination of DP by ZG, and to begin at 13:50.


We begin.

J: invite ZG to question DP. ZG: To begin - bundle for disclosure purposes; solicitor part way through redacting, so it's on it's way. J: those wanting docs should email the court, for forwarding to solicitor.

J: OK Ms Gannon? ZG: Check 1 point with you Ms Padalia, you run RSE for secondary schools? DP: Predominantly, also some universities and primary schools. ZG: Primary? DP: Yes ZG: From age 4? DP: Yes but mostly secondary schools

ZG: What info do you give to parents? DP: Info about deliverer - DBS check etc, training, recruitment processes. Sent to the school. ZG: But is CP as parent not entitled to know who delivering? DP: Provision is standard, person doesn't matter.

ZG: CP has no right to know? Is that SSE policy, that CP should not know name? DP: Yes that's right ZG: Is that just CP, or is that policy for all parents? DP: We tell schools, it's up to schools what they then do. Our facilitators represent SSE - don't see why naming matters.

ZG: Am asking if it's your view that parents should not know who from SSE is giving sex ed to their child? DP: Not that simple. We tell schools, schools do due diligence. Naming the person not important. ZG: Does that apply to all parents? DP: Sure.

ZG: Are you aware that is contrary to DfE guidance? DP: Think that is a mis-reading of guidance. We are entirely open with the *school* and we help them with due diligence, help them share the diligence results.

ZG: if we look at DfE statutory guidance. Says school must do so and so - schools must have up to date policy available to parents, and to others, and must publish on website. Public policy. DP: Yes I see.

ZG: reading on, guidance says must be public what is taught, and by whom. That is what the Sec of State says. DP: Yes and we are public that SSE is delivering. ZG: Says should be public *who* is delivering. DP: DIsagree. Individual not important. Organisation is.

ZG: Agree to differ on that I think DP: Yes

ZG: If it's your policy that parents should not know, why is that not in your contract with school? DP: Not sure I understand. The school knows who facilititator is early on. DP: What matters is knowing the org, SSE, is delivering. Not names.

ZG: Will clarify. You have said you do not want schools to share names with parents. If that's so important, why is not in the contract?

DP: We make sure schools have all relevant information about our org and our facilitators generally, and that's what we share. ZG: You haven't answered; why not in contract. One more time? SW: Ms Gannon has asked twice but DP has not agreed there is a prohibition?

ZG: She has said so. J: My note is that DP said schools were not to share names of individuals. SW: "Prohibition" too strong. J: I think distinction without a difference, can DP clarify?

DP: Will try. It's not in contract because it also depends on the individual facilitators, whether they want to be named, they may have had a parental session same day, so, it's a possibility, so, not in contract. We aim to work closely with schools and with parents.

DP: So expectation not prohibition. A teacher is always in our sessions.

ZG: So sometimes parents do know, you're saying now? But sometimes not, and depends on facilitor's wishes? DP: Not a change of what I'm saying. We are hardly ever asked for name of facilitator, just qualificaitons etc

ZG: Might it be that since it's not in contract, schools would assume it's OK to say? DP: That's not how it works, haven't come across it.

ZG: Should parents be told in advance that when your org comes in, they will not be able to know the names of the people teaching? DP: We'd want to know why parents asking, so that we could supply information re training, DBS etc, because, name not important.

ZG: You would share qualifications, but not names? DP: Yes important that schools make sure to pass on quals etc to parents. Pubish widely. ZG: So you give a "bio" - background etc? DP: Yes and outline of what is to be covered.

ZG: I am trying to work out whether this is an unusual case or whether it's your standard practice. DP: We give max information to schools ZG: I am asking about what *parents* get to know. Background but not name?

DP: Don't know what is shared with parents, only what we *recommend* to schools that they share. ZG: So schools might be sharing names? DP: Have not had this come up - names of presenters. Asked about background, content etc.

ZG: Do you accept that if a child is taught by a person their parent does not know about, there is danger the child could look that person up online without pareent's knowledge? DP: Suppose that might happen.

ZG: Is it *likely* that a child would look up online, if parents not aware? DP: Could happen, also could talk to teachers. ZG: And if they did they'd find your website? DP: Yes, previously, yes

ZG: We are talking about 2021, early 2022. Do you accept that if a child looked at your website then, they would find unsuitable materials? DP: Can completely understand the Q. Yes. Can understand CP's concern - not our context, but links on it.

DP: would like to give context. Website was done without any thought. Links to materials outside our own site was meant to indicate that we are a completely non-embarrassable team - convey that no topics make us uncomfortable, there to support young people, not judgemental

DP: Completely true that we did not consider that if a parent did go and look at our website, they might not see the site as we'd meant it to be, that they'd find things not suitable for young people. Completely accept this is regrettable, understand how CP got impression she did

DP: We rectified that quickly - took feedback, made changes.

ZG: Would like to look at some details. ZG: [missed] is one of your facilitators, interested in sex toys? DP: Yes ZG: Link to her website, AMA? DP: Yes

ZG: If we look at that site? [page refs, all look] [I'm informed the facilitator being discussed is Nadia Deen]


ZG: Images 1-6 in para 24 - screenshot of your website linking to hers, then screenshots of her website, a bio of her, says she is working on a line of sex toys, and that she works as facilitator for you. DP: Yes

ZG: Another shot - founders of her website; one an award winning women's sex site? SW: One founder I think? ZG: Yes you're right - one founder, then contributors. ZG: The contributors - there's then a link to their website. Call themselves Adult entertainers, fetish trainers.

ZG: This is highly inappropriate material for, say, an 11 year old child. And it's two clicks away from that child having had a presentation from you.

DP: Yes, I agree. Those are nothing to do with us, not in our curriculum, they are not related to us. Our site is not for young people. Google analytics says not much traffic from young people.

DP: But I reiterate, we wanted to be clear we are diverse, not judgemental. Show our values, not a cold academic-credentials site.

ZG: for completeness, do you agree it's inappropriate to expose this material to children via an organisation they've been introduced to at school? DP: Children don't really remember name of organisation, I suppose could stumble.

DP: Children already see lots of harmful material online - we aim to give them tools to deal with that. But, our website is not for young people, not aimed at them.

ZG: Moving on, you also linked to a website Squish Squash Squelch by Dr Emma Chan. DP: Yes I see that.

ZG: Here is part of her website - there's a song - talks of stimulating vulva and anus with a sex toy. Is that suitable for 11 year olds? DP: That's not on our curriculum. ZG: Court understands that. This was linked from your website.

DP: Yes but not ours. ZG: Am aiming to get agreement that this is unsuitable for children. DP: Yes, agree, that site is not designed for young people.

SW: I think Qs are being conflated a bit - about whether likely to be accessed by children. J: I assumed Miss Gannon was just not repeating the earlier line of questioning ZG: Yes but happy to re-put.

ZG: Do you accept Miss Padalia that it is possible, likely, that a child would find your site. DP: Yes but mostly they don't, our analytics show, and children will be finding those sites anyway. Lots of research about that. Disingenuous to say our site is the only way.

ZG: Nobody is suggesting your site is the only way young people might find harmful material on the internet. ZG: As you've introduced it, what is your traffic breakdown for young people?

DP: Over last year - mostly adults, mostly from UK but some from US. ZG: So minority that you know are children? DP: The data isn't very clear about that. But access is mostly to home page etc

ZG: When did you implement Google analytics? DP: Can't remember ZG: Was it active in 2021? DP: Cant remember. but assume the same pattern

ZG: One more site to look at. [Missed name]. She says she is facilitator for SSE, is that right? [Problems getting to the right part of the bundle for some participants]


ZG: Ms Aween[?] says she is facilitator for SSE, is that right? DP: For a short time but mostly more a consultant. ZG: Her site linked from yours? DP: Yes

ZG: And her site incudes this material her - soft porn, basically? DP: Erotica. ZG: Starts with two people rubbing drugs on their gums? DP: This is material for adults, made very clear on the site.

ZG: And is this part of what you were apologising for earlier? DP: Yes, it is not part of our curriculum. ZG: Do you still maintain that parents should not know the names of the facilitators we have looked at in detail?

DP: Agree that it's good parent should talk to school if they have concerns, like Miss Page did, and school then to us.

ZG: Not quite my Q. These three people go into schools and deliver sex education to 11 - 18 year olds. Should parents know in advance these people are doing this? DP: Already answered.

ZG: You say on website your staff includes teachers, doctors, social workers - DP: Youth worker not social worker. ZG: Which of those are these three people?

DP: Content designer. Dr Chan is a doctor of course. ZG: So not just the roles you listed? Broader than that? DP: Yes, we try to hire broad range.

ZG: Do you check facilitators' own websites to make sure content is OK for children? DP: The websites are not aimed at children, what we look at is how well they will deliver our material to children.

ZG: I asked if you checked the websites? You said that was their private role? You don't check? DP: We do as part of recruitment etc yes

ZG: And having checked the ones we've looked at, you still felt they were appropriate people to send into schools? DP: We employed them for their RSE expertise, so yes am confident that we did the right checks. The websites are not for children, not our curriculum.

ZG: When I asked re SSE and children going to website you said not very likely. How about these people, once the children know their names? DP: Not likely. ZG: How do you know? DP: Children don't really remember names.

DP: I do again say that the website should have had those links, regrettable. SW: Intervening to ask re timing? J: How long for closing? ZG: An hour, little more SW: 40 minutes about

J: And rest of cross? ZG: I have not made much progress; have been allowing Miss Padalia plenty of time for her replies. J: Time is under pressure then. Can we extend from 4.30 to 5?

[All agree 5] J: Am keen not to end part-head. Miss Gannon can you possibly manage to complete in 30 minutes? ZG: I think that's unlikely I'm afraid. J: We will look again in 45 minutes or so at timing. SW: It was appellant set timetable J: Indeed but am not going to guillotine

ZG: Do you accept Miss Padalia that in 2021 your website *did* give names of facilitors? DP: Yes ZG: So you were not concerned at that time with hiding the name? DP: We still share with schools.

ZG: I am talking about making them public, to parents. In 2021 you were happy to do so. DP: That was before, and, we found that the people were getting harassment eg on Facebook, so we took names down.

ZG: Can you recall if name of facilitators teaching Ms Page's child were on the site then? DP: Can't recall. ZG: Do you know if those who taught Ms Page's daughter have active social media presences? DP: Some do some don't.

DP: Can I clarify - not a drop down day, just one session, only about 30 minutes. ZG: I think we need a closed session, to look at the social media profiles I want to talk about.

J: You mean, the people giving the session? ZG: Yes, and whether they mentioned SSE on them, and did SSE link to them on the website. I would like to go individual by individual, to assist Ms Padalia.

ZG: Meanwhile I want to look at the concept of harm here. Ms Page has never threatened any member of your staff. DP: Not that I know of.

ZG: You talk of abuse you had online. Nothing you needed to report to the police? DP: Lots of it was nasty, we blocked, but no not the police. ZG: Facebook, Twitter? DP: Yes ZG: Any accounts suspended as a result? DP: Not that I know of.

ZG: Nobody came to your office? DP: We had hate mail but no. ZG: Police involved? DP: No.

ZG: No protests at schools? No personal contact at all? DP: No, but we must accept that online abuse can be very harmful. ZG: Of course, but I am just trying to clarify what has happened.

ZG: And you block when this happens? DP: Try to, but there's a lot.

ZG: Moving on. You encourage schools to vet your materials in advance? DP: Yes ZG: But that didn't happen in this case. DP: We have standard practice for engagment with schools - complementing schools own curriculum.

ZG: I am asking because, if we look here, school is saying you did not provide the consent session material you would be teaching *before* the session? DP: We make a difference between sharing - actual copies - which we didn't, and run-throughs, summaries, which we did.

ZG: But school did not have the material. DP: No ZG: You have not mentioned a run-through before, not in either witness statement. DP: Because it's standard practice. Amelia would have done this, it's standard.

ZG: So you did not personally do the run-through, and you didn't record it - SSE didn't record it. DP: Standard not to. ZG: Is it not likely it didn't actually happen at all? DP: Am sure Amelia offered, up to school to take up.

DP: It is standard practice. To run through with schools. Standard practice. ZG: Have you been able to ask AJ if it happened? DP: No. but there's an email mentioning it

ZG: But school has said they did not have the material. And all you know of is a phone call that might have mentioned it. Isn't is possible it didn't happen? DP: Yes possible.

ZG: Your policy is school must not keep materials? DP: Yes ZG: So for example Ofsted cannot inspect what has been taught? DP: Good question. We provide summaries etc for this, for school to keep.

DP: We provide summary materials in advance, and they can keep that. ZG: But not the teaching material actually used, and Ofsted would not be able to check? DP: No but summaries, descriptions, plans.

DP: And Ofsted have observed our sessions in the past - and a teacher always does.

ZG: Do you accept that preventing parents from seeing materials, you are inhibiting their ability to engage with their child on the matters covered? DP: yes, good question, and we do want to engage parents, but we put a lot of work into our slides etc, it's what we sell.

DP: We want parents involved, we offer them workshops, very important for RSE to have multi-approach including parents, but, have to involve parents in way that doesn't harm our organsiation

DP: We don't want schools not to hire us because they might have to share information with parents. ZG: I repeat, refusing to share means parents can't engage with the child about it? DP: disagree, not how all this works.

ZG: What if a parent wanted to discuss it with a partner? Or (though not the case here) a religious leader? DP: Our summaries etc provide enough information.

ZG: You say you don't take inappropriate materials into schools. But how can parents be confident of that, if they can't see what is taught? DP: We have teachers present, we follow DfE guidelines, Ofsted have observed us.

ZG: Can I clarify re Ofsted? Going very fast. DP: Ofsted have observed us in the past.

ZG: More recently you've been advocated a book called [too fast]. Ms Page says in witness statement that the book has an exercise in it - called "good sex, bad sex, depends". Includes discussion of anal sex, group sex, BDSM.

ZG: Says love and affection is sometimes - but not always - part of "good sex". Says that some people like painful sex, or anonymous sex.

ZG: Do you think telling children anonymous sex is good is harm-free? DP: Book not by us, we don't teach the book. ZG: You would not advocate anonymous sex to children? DP: No. ZG: But you recoommned the book on your webiste? DP: Yes, but for adults.

ZG: Turning to this sample lesson plan. ZG: Judge, I am very unlikely to finish in the next 10 miinutes. J: Noted. Please continue.

ZG: This plan is from your website, says for 16+ SW: I don't see "lesson plan"? ZG: Was summarising. Can Miss Padalia clarify? DP: Not plans. Never taught. Not in curriculum. ZG: Your name on them? DP: Yes, worksheets, but not lesson plans.

DP: Can understand why Miss Page might think lesson plans, they are resources for use during pandemic, not in schools. Children were spending a lot of time online, resources for parents and teachers, developed with universities. ZG: That's helpful, thank you.

ZG: You co-created, says age 16+ ZG: Encourages parents, teachers, to get those children to watch a Netflix programme called "Sex Education". Which Netflix rate 18+.

DP: Yes, children are already watching them, so we always work on premise that they have, and then we we look at challenging harmful stuff in them. ZG: But here you are encouraging 16 year olds to watch 18+ films. DfE guidance is clear, must be age appropriate.

DP: Disagreeing that we encourage them to view it. ZG: Must question that. It says here, explicitly, "watch this". Encouraging 16 years old to watch 18+ film. DP: We sort of meant, watch it as a re-cap. For teachers and educators to use.

DP: In our experience teachers and educators want material to help them engage with children on things like this. If we want to engage young people there's no point pretending to them that they haven't seen it.

ZG: You have said you employ best practice. If we look at next page. You are asking 16 year olds to write down phrases associated with sex - "I like this" sort of thing - and you list some possible adjectives.

ZG: You then say "look at yourself in a mirror at the end, or have a video call with a friend to discuss". You're aware video calls can be recorded? DP: Yes but children already do that anyway, they already use that vocabulary.

ZG: Do you not think that encouraging young people to make video calls, talking about sex, which might be recorded and shared, is a safeguarding risk? DP: Yes if that happened, the schools should take it very seriously.

DP: Our approach is always that young people shoujld have agency, should never do anything they are not comfortable with.

ZG: If you are proposing this, you are encouraging it, you are leading children to belief this is safe. ZG: Is this that best practice?

DP: Well it might not be a video call, might not be recorded, in any case it's with a peer, and the teacher or educator might be present. ZG: Can you not see this is not safe? DP: See what you are saying but that is not feedback we have had.

ZG: Moving on. Again this is encourage 16+ pupils - SW: I don't see "pupils"? ZG: DP has said "teachers"; teachers have pupils. May be clearer if I continue.

ZG: This is another recommendation to an episode of the 18+ Netflix programme. Activity to do is to think about whether it encouraged "sex positivity", and to discuss that with friends over Snapchat and Facetime - which again can be recorded.

DP: Young people are already talking about all kinds of sex stuff all over the place anyway. But, this activity is not talking about sex itself - it's to talk about talking about sex. SW: Can we take the rest of the sentence? ZG: Indeed. It talks of making activitist plans?

DP: Yes. That means creating safe places for children to discuss.

ZG: Moving on - DP: Could we have a break, 5 or 10 minutes? J: Indeed. We will break until 3.45. SW: I would like when we resume to have an idea what is going to be requested from the witness; am wondering about relevance. J: We will discuss. [BREAK]

Missed - tech difficulty. DP: explains asexuality. Lot of pressure on young people to be sexual.

[Technical difficulties] ZG: same material teaching. Do you accept if copyright (CR) was breached, you could enforce that? DP: I assume so ZG: and its pretty normal to enforce CR? DP: yes

ZG: do you accept 'all schools are expected to make disclosure of third party providers'? Do you agree you were not at unfair disadvantage, all orgs expected to do that? DP: if shared will have detrimental affect. It's good schools being held accountable. Good that parents are engaged.

DP: Seems to be confusion over letter from gillian keegan which makes distinction between sharing and viewed. And this has detrimental effect. We are happy to arrange viewings of content and separate workshops as well. Happy to do that.

ZG: looking at letter 'all schools required to share info and publish'. Schools required to share curriculum and won't infringe CR. What they're saying is schools are expected to share not show?

DP: Curriculum content not slides and resources. We are transparent with our content. Important to ensure parents know. We're succeful working with parents. I can talk shout forever but I won't, but has to be done in fair way.

ZG: you say in WS it's fatal? Overstating? DP: Don't think i am. If schools have our content that's us as an org over JB: have you read letter? DP: yes

JB: with points in mind, 'schools shouldn't agree with restrictions'. It's Teaching resources not curriculum there. Next paragraph starts 'we know some schools' [reads - CR shouldn't be obstacle] Are you still of the view it says showing rather than sharing? DP: can I just say how we've been supporting schools. [Too fast] We work with parents so make our content properly aware of what's taught. Contracts point, ref to parent coming to schools not convenient. We run it online. We offer to all parents. ZG: turning to 873 of your witness statement. Is it your view sex education can never be partisan or political?

DP: what we do is evidence based and encourages critical thinking. We answer questions in a way I guess they can connect with. I think important relationships and sex isn't politicised

ZG: I'll try again. Do you accept it can be partisan and political? DP: of course. But she can be delivered badly too

ZG: Your CEO describes themselves as activist. Not reasonable to presume it's possible that part of her activist activities manifests in your activities provided by your org DP: we have to operate via gvmnt guidelines and we do

ZG: lots of 'sex positivity'. On your website it says 'stepping away from monogamy assumptions'. Sex positive? DP: yes like asexual and (too fast) on spectrum

ZG: many people would think shouldn't be stepping away from monogamy assumptions. You accept some people may see as political or partisan?

DP: I think your confusing things here. We're not making assumptions we're validating ALL. Are there some families not monogonmous? We're not saying there's a correct way we're saying everyone is valid and have to respect one another. That's not political that's just being nice.

ZG: Sex ed includes non judgemental and acceptable of sexual practices different from the normal? DP: but want to explore interpretations though

ZG: yes advocating that to children, aren't you exposing them to some sexual practices are properly judged and inappropriate? DP: your talking of abuse that's not sex positivity. We look at coercion and pressure and making feeling guilty and bad. All our work is geared to empowering boundaries. ZG: I'll try again. Aren't you exposing them to an idea inherently unsafe? DP: no you're interpreting it wrong. We all have boundaries that have to be respected.

ZG: you said earlier you advocate sex positivity but your saying now you don't say what it actually is? DP: yes we don't give definitions unless asked ZG: if u don't explain it isn't there a risk ppl don't understand what you mean?

DP: anything uncomfortable they should speak to trusted adult ZG: one other term you mentioned was heteronormativity [reads definition]

ZG: do you accept this term is used in your sessions? [ heteronormative (HN)] DP: yes but with context that I provided ZG: do you accept then there is risk that some consider its partisan or political?

DP: no we are not giving instruction or telling YP what to think. We are tying HN into content we are delivering ZG: describing society at HN is not right if people don’t actually assume everyone is HN. Someone could consider partisan

DP: we think people would disagree and important we do say society can sometimes be HN ZG: So if it’s something some people agree / disagree then partisan?

DP: I think its important its discussed in sessions, students bring this up and we respond to it ZG: Turning to policies. Your witness statement only refers to code of conduct, no SG policy and you haven’t given code or SG policy to the tribunal that you now say you have

DP: disagree as we had to submit to Charity commission so not just saying have it now. And its shared with schools ZG: you mentioned Charity Commission. Are you are aware that CC says all SG policies should be available publicly?

DP: I think there is a misunderstanding there. It is available to schools ZG: but not on website? DP: no cos other procedures, there's a form if there’s a complaint

ZG: As SG policy and code of conduct have not been provided to Ms Page or the tribunal there is no way to assess the validity of these DP: but NSPCC have reviewed. Also, I am a designated SG officer. I am well placed to be putting these policies together and enforcing and holding schools accountable ZG: Do you accept ppl can make mistakes and you cld make a mistake in the policy? DP: Yes we review regularly and share with NSPCC ZG: When shared with NSPCC? DP: Feb 2023 ZG: But at relevant time in 2022 it hadn’t been reviewed? DP: It would have been ZG: When?

DP: Can’t remember but I can find the dates ZG: Its our position that as not in bundle tribunal cant assess its validity DP: I would argue the people that review are best placed to do that ZG: Moving on. You describe call with Ms Page as not civil. The school said CP harassing you

DP: Me having conversation with parents is part of my job, this conversation felt different she attacked our work and I tried to end the conversation. I didn’t feel listened to. There’s a diff between constructive feedback and aggression. My suggestion was then misinterpreted.

I was surprised that she described the call as civil as I was really upset and reported it to my LM ZG: Call lasted 16 mins max and was interrupted once. During that call she did raise her voice? DP: I think she did ZG: You are just making it up. That’s not in your witness statement

DP: I’m sorry you feel I’m changing my story. I tried to be straightforward and to the point in my wit state, I wouldn’t describe it as civil. I am now providing you with more detail as you are asking. Even if she hadn’t you can still be unpleasant w/o that

ZG: Swear? Threats of violence? DP: No ZG: Insult you personally? DP: No but the organisation ZG: Didn’t refer to PCs or anything like that? DP: No but she did talk about HN and queerphobia

ZG: You obviously have a different perspective about the conversation. Do you accept her report is supported by the fact that immediately after the call you emailed the school where you don’t make any reference to it being a difficult conversation?

DP: No, I spoke to my LM Amelia Jenkinson. I appreciate Ms Page is saying it was civil. I did not think so and I am valid in feeling that way. I left a voice note explaining how I felt to colleague afterwards ZG: Those are my Qs. Thank you Judge

J: Ok. DP can you remember when the decision was made to take the bio / names of facilitators down from website? DP: following feedback from the Trust CEO. I can find date. J: say that was Nov 2021, how quickly did you act to take down?

DP: V quickly. AJ did it. I can’t give you date. Could check and come back SW: it’s the email of 6th May 2022 . I will see if I can find ref. J: I think it might be helpful for us to know the date the details were removed. ZG: agreed

J: Can this be date be found done before reconvene hearing please. J: You talked about how bios were sometimes provided in brochure given to students. Can you explain what you meant please?

DP: Yes one example. We were with independent school who were running a conference with lots of speakers. School wanted bios as well as normal info we give. We were told that went into a brochure but don’t know details. We checked with individuals in question that they were fine for that to be included J: OK. Panel questions? Mr Sivers: Yes. There was some discussion on the run-through of course material. You said no record of run-through as so routine? DP: I can find out date it happened

Mr Sivers: I would have thought there would be a diary date DP: yes. My predecessor would have done it so I can’t find out quickly. Mr Sivers: No shared calendar? DP: yeah but need to rifle thought it.

J: We need to leave it where we are in relation to evidence apart from the date I have asked for please. Ms Murphy: Impact of disclosure. You said you do consultancy and training as well as school sessions. What % is school sessions? DP: 90% to 95% is school sessions

MM: can you tell us about the market. Do most schools use 3rd party providers. You say you work with 300. Is it common? DP: yes all schools we work with have 3rd party providers for something e.g. health , drugs MM: you mentioned cancellations. What was the extent?

DP: 18/10 cancelled and other schools in Summer Term cancelled, that is confirmed in emails. Since then, our work has been mischaracterised and we have had misunderstandings about our work and then cancellations. I put one example in my evidence. It’s a shame. If we could have run through our slides, parents would have changed their minds. I think schools have felt anxious and that has had impact from Jan onwards. Cancellations may seem common but they are actually very rare. J: Thank you. Re-examination please

SW: taking legal action re copyright is that something you have budgeted for or could budget for? DP: Costings have been done in sense we have rough idea as we have contacts who have

shared fees when investigating claims for rother ppl. But we are small, not feasible for us to do SW: you have not been represented in this matter up until 2 weeks ago? DP: yes. We are very small with very limited resources. All of our time is dedicated to YP in schools

SW: Does the appellant take a position in respect to breach of confidence has been established? ZG: do you mean whether we take issue whether you have been clear enough in your conditions? SW: yes ZG: email chain is clear enough re conditions for attaching the material

SW: Thanks J: Thanks. Ms Wright, DP needs to get that date. Oh I need to ask that in closed! ZG: after closed we need the gist

J: yes. Best way is if we get a date now for coming back. Then I allow everyone to leave then we provide the gist in writing. So please don’t leave DP as we need to ask you some Qs in closed J: is it easy for you to find that date DP? DP: yes, I look in diary and ask colleague

J: so in 7 days? DP: yes ZG: DP has explained she's going to ask a colleague, we would want to know how she knows that’s the date

J: if it can be evidenced by screenshot that would be most useful. O’wise might have to be witness statement. We will get gist in similar period of time ZG.

[discussing dates for reconvening, expect to finish subs in a morning, date decided of 10 May]

J: Please can that date be provided as soon as practicable and no later than 4pm on 9th. ZG: 4pm on 8th please so I can take instruction J: Bank hol ZG: 10am on 9th?

J: yes, and send to tribunal as well as solicitor please. GRC will send out joining instructions for 10th May. Anything else before close ZG? ZG: No but can I get gist asap too.

J: hopefully yes, think will be short. J: Ms Page leave as well as observers please

<Open hearing ended. To be reconvened on 10 May 2023 for closing submissions.>


This hearing is of massive importance considering the huge fight and ongoing campaign by Public Child Protection Wales and their court case. We have been exposing this graphic, hyper sexualised content being delivered to school children for three years. We are currently at appeal stage after losing a Judicial Review against the Welsh Government last November.


To be continued...................









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