Trans activism UK’s Response to the BBC’s Executive Complaints Unit

Seven months after our initial open letter to the BBC, we have finally received an official response from the Executive Complaints Committee, the top level of the BBC’s complaints procedure pipeline, regarding our issues with the article “We’re being pressured into sex by some trans women” by Caroline Lowbridge. 

While their response does concede some of our complaints as being valid, it also doubles down on some troubling beliefs that are important to acknowledge.

In our view, while this is progress and a minor victory, it is far from what we were hoping to see and is ultimately not a suitable response. We have made some progress, but this response does not change our feelings about the harm the BBC has caused and risks causing again in future

So, below, we will discuss the points where the BBC has now acknowledged they were in the wrong, what steps they have taken and what steps they have failed to take in addressing the missteps of the article, and the areas where we believe it is appropriate to escalate a complaint to OFCOM, in the hopes of seeing further changes from the BBC.

Areas Where the BBC Acknowledges They Failed / We Were Correct in Our Complaint.

The ECU at the BBC has finally acknowledged the validity of a few of our complaints. 

The Article Headline

In the Head of the ECU’s view the headline gave a somewhat misleading impression of the article itself, and it appeared from many of the complaints that this had contributed to an understanding of the article as more focused on the conduct of trans women than was in fact the case.

Firstly, they acknowledge that the original headline of the article gave the false and not evidence-based impression that trans women pressuring cis lesbians into sex was a widespread issue. The body of the article did not contain enough evidence to back up the headline. While the headline stopped legally shy of alleging all or most trans women were potential rapists, it attempted to allege it was more widespread of an issue than there was evidence to assert.

The principal issue of complaint in relation to accuracy was that the evidential basis for suggesting pressure from trans women posed a significant problem for lesbians was inadequate.  In this connection, the Head of the ECU noted that the headline “We’re being pressured into sex by some trans women”  (which was not written by the author of the article) gave the impression that the focus of the article would be on pressure applied by trans women, whereas its focus was at least as much on internalised pressure experienced by some lesbians as a result of a climate of opinion (as they perceived it) within the LGBTQ+ community, rather than pressure directly applied by trans women.

Part of the reason the ECU acknowledged the headline was inaccurate, they acknowledge in the above quote that many of the accounts in the piece are not about trans women pressuring people into sex as the headline implied, but rather about cisgender women dealing with external factors such as changes in public perception of trans women.

While the article’s headline has been changed, they have not changed metadata relating to the headline, meaning that the original headline still appears in Google searches, and when the article is posted to social media platforms.

Get the L Out’s Survey

The questionnaire was sent to a small number of “women only” and “lesbian only” groups, and only around a third of its 80 respondents were from the UK.  The article included some caveats, for example by acknowledging that “the sample may not be representative of the wider lesbian community” and by describing Get The L Out as an organisation whose members “believe the rights of lesbians are being ignored by much of the current LGBT movement” and which had been accused of “bigotry, ignorance and hate”.

However, in our view these caveats do not go far enough to make it clear to readers that the survey’s lack of statistical validity or the extent to which Get The L Out has an agenda (as an organisation which believes “transactivism erases lesbians, and silences and demonises lesbians who dare to speak out”), as the results of the survey appear to support this.  The article failed to exercise the appropriate degree of scepticism in its treatment of the survey, falling below the BBC’s standards of due accuracy.

The BBC ECU acknowledged that the Get The L Out survey gave a misleading impression of the alleged pressure’s prevalence, as well as being a biassed source that was not properly contextualised, with the survey lacking statistical significance. 

Lack of Anti Trans Bias Context

With these two points in mind, the Head of the ECU went on to consider the argument put by a number of complainants that the article conveyed an impression of the scale and seriousness of the issue it explored which went beyond what could be justified on the basis of its evidence, which was principally anecdotal and, insofar as it emanated from organisations and individuals with an anti-trans agenda, to be viewed with scepticism.  He agreed that the article’s evidence base was not such as to support the impression that “being pressured into sex” was a widespread experience for lesbians in the context of their relations with trans women, and noted the following statements in the article cited by complainants as giving the impression that it was:

Several people got in touch with me to say there was a “huge problem” for lesbians, who were being pressured to “accept the idea that a penis can be a female sex organ”. (Author)

We know a minority, but still a sizeable minority of trans women, do pressure lesbians to go out with them and have sex with them… (Bev Jackson, LGB Alliance)

The ECU did acknowledge the validity of our complaint that the article failed to apply proper scrutiny to the alleged scale and seriousness of the claims made by the article. The response acknowledges that there was not enough evidence in the piece to support the statements in the article that suggested it was a widespread issue, and the complaint that not enough context was given to the clear anti-trans biasses of many of the quoted groups implying the problem was widespread, such as LGB Alliance.

“The author went on to question the contributor on the basis for saying “a sizeable minority”, which drew an admission from the contributor that “We have no figures”.  Taking these qualifications together with the author’s acknowledgement towards the beginning of the article that, in the virtual absence of research, “it has been difficult to determine the true scale of the problem”, the Head of the ECU did not believe the statements cited above would have added significantly to the misleading impression arising from the article’s headline and its treatment of the Get The L Out survey, and he found no further breach of due accuracy in this respect.

However, the BBC, unfortunately, did not agree with our argument that these allegations would contribute to a wider perception by readers that trans women sexually assaulting cis lesbians were a commonplace issue. They argue that the minor caveats they gave in the piece are sufficient to make it clear that the argument lacked numerical evidence, a point with which we strongly disagree.

Lily Cade Should Have Been Contextualised

“They acknowledged, however, that she had admitted to behaviour which she now recognised as sexually abusive in a Zoom conversation in September 2020, which had escaped attention by the time the article was ready for publication over a year later.  In the context of the article, this information would have helped readers to judge her comments in the light of her own actions, and it was regrettable that it was not included.”

The BBC did acknowledge that information about Lily Cade’s history as a sexual abuser would have been useful context to give in the piece, although we will later address that the BBC ECU failed to address most of our other complaints on this matter.

In summary, the below are the main points the BBC ECU is willing to concede in response to our complaints:

The Head of the ECU found that the article, though a legitimate piece of journalism overall, fell below the BBC’s standards of accuracy in two respects: the headline gave the misleading impression that the focus of the article would be on pressure applied by trans women, and the treatment of the survey conducted by Get The L Out did not make sufficiently clear that it lacked statistical validity. 

The Areas Where the BBC Disagrees with Our Complaints

While we did gain some ground in getting the BBC ECU to acknowledge some of our complaints, there are many points where we and the BBC still disagree regarding the article.

Comparisons to Platforming Homophobia

“The Head of the ECU considered these analogies unhelpful because of the extent to which there remains controversy about what constitutes a transphobic view, the controversy itself reflecting the extent to which it is argued that claims by or on behalf of trans people conflict with claims by or on behalf of other groups which have suffered prejudice, disadvantage or victimisation.  He therefore did not accept that the inclusion of the contributions objected to could not be justified in terms of due impartiality.”

One major disagreement we hold with the BBC ECU is their claim that “there remains controversy about what constitutes a transphobic view”. Several complaints sent to the BBC by cis gay and cis lesbian people for example raised the comparison to platforming homophobic hate groups uncritically without examining their biases, and how under Due Impartiality the BBC would not feel it important to give homophobic hate groups a voice to air their feelings on a topic of this nature.

The BBC argues that there is not enough consensus on what does or does not constitute transphobia, and therefore due impartiality doesn’t require them to deplatform transphobic groups in the same manner.


“Other examples included contributors referring to trans women as “biologically male” or having “male” characteristics, but in no instance did this amount to a denial that trans women were women in fact and in law.  While the Head of the ECU appreciated that such references were nevertheless capable of giving offence, he believed their inclusion was warranted by the editorial intention of providing insight into the experience and feelings of the contributors concerned. He found no example of misgendering or bioessentialist language in the author’s own words.”

The BBC claims that it is not misgendering to refer to a trans woman as a “biological male”, or to describe their body as “male”, and that doing so in no way contradicts a trans woman’s status as legally female, which is honestly a ridiculous claim to make.

We not only believe that these are acts of misgendering, but in the context of the article, these acts contribute to the suggestion that lesbian trans women are men, rather than being women, which contributes to a context that suggests that trans women are placing themselves into sexual situations where nobody would consent to their presence.

The ECU also attempts to defend the inclusion of these turns of phrase in the article by pointing out they are quotes, not statements by the author, without examining the fact that the author exclusively interviewed people who used this kind of language to describe trans women, and felt no need to correct that language in the body of the article, showing a clear bias by its author to acts of a discriminatory nature.

Lily Cade Complaints

“A number of complainants argued it was inappropriate for the article (in its original form) to include an interview with the lesbian porn star and director Lily Cade, on the basis of her previous sexual conduct and the transphobic views she posted online after the BBC article was published. Those responsible for the BBC article have said they were unaware of Ms Cade’s transphobic views before the article was published and claim there was no reasonable basis on which the views she subsequently expressed could be foreseen.”

“Also in this connection, some complainants referred to claims that the BBC should have been aware of the issues in connection with Ms Cade because Chelsea Poe had referred to them in her interview with the author. The Head of the ECU listened to a recording of the entire interview and found that Ms Poe referred to Ms Cade in the context of her experience seven years previously when considering an offer of work from a production company for whom Ms Cade was directing films, but did not do so in terms which suggested Ms Cade was transphobic and did not mention her admission of sexual abuse. Accordingly the Head of the ECU found no basis for the claims that Ms Poe had alerted to the BBC to the relevant issued in relation to Ms Cade.”

With regards to the inclusion of Lily Cade in the article, the ECU denies that the BBC or Caroline Lowbridge were aware of Cade’s sexual assault allegations prior to the piece’s publication. However, it does not address that these allegations were public knowledge, that they failed to spot them before publishing the article, and that they were incredibly slow to remove her from the piece. 

This statement from the ECU is also in contradiction with a public statement that Chelsea Poe made in November 2021 on her podcast, regarding her interview with Caroline Lowbridge in January/February 2021. She stated, “I also brought up that Lily Cade is no longer in the [porn] industry due to consent issues.” We expect the BBC to be able to provide evidence that Chelsea Poe did not reference Lily Cade’s offences or reputation, and will be seeking evidence under a Freedom of Information Request. 

“A number of complainants considered the update did not give sufficient detail of the reason why Ms Cade’s contribution had been removed but the BBC has to consider how to describe offensive material without repeating and perpetuating any offence it may cause, and the Head of the ECU believed the absence of detail was justified in this instance.”

The BBC ECU also maintains its belief that simply quietly removing Cade from the piece was sufficient. We argued in our complaint that the piece needed to much more directly acknowledge that it had previously contained an interview with a self-admitted sexual abuser of cis lesbians, who had gone on to post an alarmingly violent anti-trans manifesto. To quietly remove her, and to be so slow in doing so, was not enough to undo the harm caused by platforming her.

“The Head of the ECU judged this to be an appropriate response in the circumstances, and sufficient to resolve the issues of complaint in this respect.  A number of complainants considered the update did not give sufficient detail of the reason why Ms Cade’s contribution had been removed but the BBC has to consider how to describe offensive material without repeating and perpetuating any offence it may cause, and the Head of the ECU believed the absence of detail was justified in this instance.”

In regards to that final comment, we maintain that the original article was more than happy to detail allegations of sexual assault when levied at trans women, but felt that it might be “repeating and perpetuating any offence it may cause” when it came to Cade, a cis woman. We believe that this is a clear double standard, and an example of the BBC having separate standards for cis and trans women in their coverage, that leans toward benefiting cis women and toward criticising trans women, even despite statistical evidence that cis women in the UK overwhelming support their trans sisters.

“They acknowledged, however, that she had admitted to behaviour which she now recognised as sexually abusive in a Zoom conversation in September 2020, which had escaped attention by the time the article was ready for publication over a year later.  In the context of the article, this information would have helped readers to judge her comments in the light of her own actions, and it was regrettable that it was not included.  Once the issues of Ms Cade’s sexual conduct and subsequent online comments came to light, however, her contribution was removed from the article, and the following update was added to it on 4 November 2021.”

They did however acknowledge that it would have been useful and important context to note Cade’s sexual abuses in the context of the piece.

The BBC has also failed to do due diligence even now in regards to Lily Cade’s dangerous behaviours, referencing only a Zoom call that took place a year prior to the publishing of the article. They have not acknowledged that Lily Cade made a fictional public post on the topic of sexual relations with underage people on a website in 2018, nor the genocidal manifesto she posted after the publication of Caroline Lowbridge’s work, emboldened by her inclusion in the article.

Complaints about Lily Cade’s inclusion in the piece, citing the abuse allegations, were ignored and dismissed by the BBC complaints department for almost a week, and were only addressed once she posted her transphobic manifesto. 

Perpetuating Harmful Stereotypes

Speaking more generally, the BBC ECU response seems to take the stance that the article did not contribute to perpetuating or increasing a belief in harmful stereotypes about a minority group. We believe that this is easy to disprove, as the comments on social media where the piece was posted on Twitter and Facebook were overwhelmingly filled with commenters using the piece as “evidence” that they were right to believe most trans women were rapists, and as such should have fewer legal rights.

The piece was celebrated by anti-trans hate groups, using it to legitimise their views due to it having been published by such a renowned broadcasting company, which we believe contributed to harmful stereotypes held against trans women.

While the BBC acknowledged many of our serious complaints about the piece, they have refused to take the story down, they have not made significant changes to alert readers today of the flaws in the piece, and they have not amended the piece to make its flaws and biases clear to readers. They have failed to offer a much deserved, prominent and clear apology, something that is apparently appropriate for them to issue after a message disparaging a football club is briefly shown on screen but not after a marginalised group is wrongly implied to be potential rapists.

The piece as it currently stands still platforms groups like Get The L Out and the LGB Alliance without context, it still cites a statistically insignificant survey, and it still does not contextualise that one of the interviewees, a cis lesbian, admitted to the very crime the article suggested trans women were at risk of committing.

The lack of amendment and correction can still cause harm, as can the failure to truly explain the dangers of the misinformation that remains within the article. 

The response acknowledges some of our complaints about the piece but stops short of apologising or taking steps to undo the damage caused by the article.

Next Steps – Escalating to OFCOM

When the BBC ECU responds to a complaint or complaints, this is the BBC’s final response. As a result, if you are unhappy with the BBC’s ECU response, agree with any of the points we have raised above, or you feel that the BBC ignored any of your own personal complaints about the article and failed to properly address them, you can escalate your complaint to OFCOM.

OFCOM will only accept complaints about the BBC once the BBC has issued a final response, which is now the case.

The following form will allow you to make your complaint to OFCOM. When asked to provide the final response you received, you can link them to the ECU’s response to the article. You will be given space to explain why you are still unhappy and feel that the final response is not sufficient.

While you are welcome to make the same arguments we have made in this post, we suggest using your own wording to explain how you feel, so as to not have any complaints dismissed as being copy and paste complaints trying to inflate numbers unnaturally. Explain what you are unhappy about in your own words.

Categories: LGBT, Uncategorized

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