UK Report Highlights Risks in Data Recording of Biological Sex and Gender Identity

A recent government-commissioned report in the United Kingdom has uncovered significant concerns over how biological sex and gender identity are recorded in official data systems. The study, led by Professor Alice Sullivan from University College London (UCL), reveals that the conflation and ambiguity between biological sex and gender identity in data collection are leading to confusion and potential risks in critical areas such as healthcare and safeguarding.

The report highlights that the shift in terminology from “sex” to “gender” as a catch-all term, which began in the 1990s, has contributed to a “widespread loss of data on sex.” This lack of clarity in data collection practices has resulted in inconsistent recording across various organizations, with some mixing biological sex and gender identity, complicating efforts to track and analyze outcomes for specific population groups, including individuals with mixed or gender-diverse identities.

The Need for Accurate Data Collection

Professor Sullivan emphasizes the importance of distinguishing between biological sex and gender identity. She advocates for the default recording of biological sex at birth while allowing for the recording of transgender and gender-diverse identities where appropriate. According to Sullivan, these are distinct variables and should be treated as such to maintain data integrity.

One area significantly affected by this ambiguity is healthcare. Crime statistics, for example, have been recorded based on preferred gender rather than biological sex, and individuals have been allowed to change their gender markers on NHS records. This misalignment raises concerns about accurate healthcare provision, as certain medical conditions and screening processes are sex-specific.

The report also reveals that unclear guidance and the absence of standardized practices have led individual organizations to develop their own data recording systems. These variations have been embedded into IT systems, further blurring distinctions and increasing the difficulty in rectifying these inconsistencies.

Risks in Healthcare and Safeguarding

Healthcare services are particularly vulnerable to risks arising from inaccurate data collection. The report indicates that loss of data on biological sex can have severe implications for health services, including incorrect medical screenings, misdiagnoses, and compromised patient safety. For example, cervical cancer screenings are sex-specific and require accurate sex data for eligibility.

Minors are especially at risk, with safeguarding measures compromised by unclear data recording practices. Social care and child protection services rely on accurate sex data to assess risks and make informed decisions. Inadequate data collection can hinder the identification of at-risk individuals, delaying necessary interventions.

Moreover, the report suggests that allowing changes to gender markers on NHS records without creating new NHS numbers may expose individuals to risks, including errors in medical history retrieval and inconsistent care across services.

Recommendations for Improvement

The report outlines several recommendations to address the identified issues:

1. Clear Separation of Biological Sex and Gender Identity: Organizations must clearly distinguish between biological sex and gender identity in all data collection processes. The default target for data collection should be biological sex at birth.

2. Standardization Across Organizations: A unified and standardized approach across all public and healthcare services is crucial. Government bodies and organizations must adopt consistent guidelines to ensure clarity and accuracy in data collection.

3. Review of IT Systems: Existing IT systems should be audited to rectify any conflation of sex and gender identity data. Updates are necessary to ensure systems can accurately record and differentiate between these variables.

4. NHS Policy Changes: The NHS should cease issuing new NHS numbers when gender markers are changed, reducing the risk of data fragmentation and potential errors in healthcare provision.

5. Robust Government Oversight: The report calls for a dispassionate and robust government approach to data collection, avoiding political or ideological biases that may influence data practices. This includes ensuring that the Office for National Statistics (ONS) and other data-gathering bodies maintain impartiality.

6. Improved Guidance and Training: Government departments and organizations must provide clear guidance and training on data collection practices, emphasizing the importance of accurately recording both biological sex and gender identity.

7. Enhanced Safeguarding Measures: Improved data accuracy is essential for safeguarding practices, particularly for minors. Social services and child protection agencies should receive support to access and interpret data correctly.

Government Response and Future Actions

The Conservative government commissioned the report over a year ago, with expectations of publication by August 2024. However, following the general election, the report was delayed and released in March 2025. The health department has acknowledged the report’s serious findings and committed to urgent investigation and action.

Defense Minister Luke Pollard highlighted the government’s commitment to improving data collection practices, recognizing the importance of accurate data in enhancing healthcare services and safeguarding protocols.

The Department for Science, Innovation and Technology expressed its gratitude to Professor Sullivan for her work, emphasizing the need for accurate data to support research and public services. Similarly, the Department of Health and Social Care vowed to address the findings with urgency, reflecting broader efforts to reform gender identity services across the country.

Implications for Healthcare and Policy

Accurate data collection is vital for effective healthcare delivery and public policy. The report’s findings underscore the need for reforms to ensure healthcare providers can offer sex-specific care without compromising individuals’ gender identity rights.

For example, healthcare screening programs such as breast and cervical cancer screenings rely on sex-specific data to determine eligibility and ensure early detection. Misrecorded data can result in eligible individuals missing screenings, leading to delayed diagnoses and poorer health outcomes.

Safeguarding children and vulnerable individuals is another critical area impacted by data inaccuracies. Social care services depend on accurate data to assess risks and implement protective measures. Clear data recording can enhance decision-making processes and improve the safety and well-being of at-risk populations.

Broader Societal and Policy Impact

Beyond healthcare, the report’s findings have broader implications for public policy and societal attitudes toward sex and gender. The conflation of sex and gender identity in official data reflects broader societal trends toward recognizing and accommodating gender diversity. However, this shift must be balanced with the need for precise data to ensure public services are effective and equitable.

The report calls for a balanced approach, advocating for the recording of biological sex by default while respecting individuals’ gender identity where relevant. This nuanced approach can help reconcile the need for accurate data with the rights of gender-diverse individuals.

The government-commissioned report led by Professor Alice Sullivan brings to light critical issues in UK data collection practices, particularly the conflation of biological sex and gender identity. The confusion and inconsistencies in data recording pose significant risks to healthcare services and safeguarding measures, especially for vulnerable populations.

By implementing the report’s recommendations, the UK can enhance the accuracy and reliability of its data systems, improving healthcare outcomes, safeguarding practices, and public policy. The government’s commitment to addressing these findings will be crucial in ensuring that data collection practices support effective and equitable public services.

As the UK moves forward with these reforms, the report serves as a crucial reminder of the importance of accurate data collection and the need to balance societal progress with practical policy considerations.