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SUFW submission for first Women’s Health Strategy

Last month, Manatū Hauora / Ministry of Health called for the public to make submissions on their new Women's Health Strategy.

This will be the first Women’s Health Strategy for Aotearoa New Zealand. It will set the direction and priorities for improving women’s health and wellbeing. Women have rights to the highest attainable standard of health and to be free from discrimination. The Women’s Health Strategy will help to achieve that.

SUFW is concerned that the Women's Health Strategy doesn't seem to be centered on the health of biological women. Below is the submission sent to Manatū Hauora / Ministry of Health.


Speak Up for Women (SUFW) is a women’s rights group. We are run by a diverse leadership team that includes members of the Rainbow and the immigrant communities. Over 290 women participate in our discussion group, from different cultural and socioeconomic backgrounds. We advocate for the protection of women’s rights, spaces and language. We would like to share our views and make a submission on the development of the Women’s Health Strategy. We would also like to request our group to be included as a stakeholder for the Women’s Health Strategy.

We welcome the opportunity to make a submission to the first Women’s Health Strategy of Aotearoa. Our vision for this strategy is that it will have biological women’s health at the centre of it.

While we are supportive of the broad diversity of gender expression, we believe that healthcare needs to be based on science and human biology (see the Appendix), because each sex has different and specific healthcare needs.

We support challenging gender stereotypes and believe that there is no right or wrong way to be a woman or a man. We also support freedom of belief, religion and respect for cultural diversity. It is important to us that the first Women’s Health Strategy focuses on women’s biology while being respectful of cultural differences as well as religious and non-religious belief diversity in our society.

We believe that the Women’s Health Strategy needs to be crystal clear about the distinction between biological sex and gender identity. Biological sex has a direct effect on your physiology and consequent healthcare needs, whereas gender identity does not. Cross-sex hormones and transgender surgeries do have a significant impact on people’s physiology, but they do not change someone’s sex. If patients, doctors, or healthcare administrators misunderstand these facts, then it is almost certain that serious harms will result.

We support and advocate for the inclusion of trans-identified females (i.e. trans men), as well as gender diverse, non-binary and intersex females as part of this strategy. We are, however, concerned that the language used in the strategy is not clear about the need to provide health services based on the biological sex of trans-identified and gender diverse individuals.

We note that this strategy describes itself as being targeted towards “all those who identify as women”. We are concerned that this overly-broad targeting will take focus away from the healthcare of biological women. We would like to see the Women’s Health Strategy being focused on areas such as women’s reproductive health, gynaecological health, and pregnancy that affect only the female sex. We are concerned that targeting the strategy towards biological males will negatively impact the services available to biological women as well as the funding available for programs that are desperately needed, such as better service for endometriosis sufferers. Women are still having to wait for years to receive proper diagnosis and treatment for diseases such as endometriosis.

Under Aotearoa New Zealand’s law (1), it is lawful to provide single-sex services and spaces. To include services for males in the Women’s Health Strategy will very likely result in unintended discrimination against biological women and fail to achieve equity in the healthcare outcomes for this population.

We believe that for many women, access to healthcare is impaired by a multitude of factors, with the language used in the health system being one of them. In our observation, it is very common for women with English as a second language to feel bewildered and alienated by healthcare materials that avoid referring to biological sex. One of our members shares her experience:

I am an immigrant, with a university degree. I studied English for 10 years, since I was 8 years old. I like to think that I am quite fluent in English, although it’s not my first language and my children enjoy correcting me when I make mistakes when I talk to them. A couple of years ago, I saw this article about gynaecological cancer awareness month, it was from a charity I was not familiar with. I remember thinking that I should read the article to see if I needed to enrol in some screening program because the system here is quite different from my home country. I remember reading the full article and, by the end of it, I remember having this feeling of being confused. I couldn’t tell why I was feeling confused so I decided to read the article again, in case I had missed something. By the time I had read the article four times, I realised that I was feeling confused because the article was about gynaecological cancer but it didn’t mention the word ‘woman’ at all. Not once! That’s when I realised that it was a language issue. In the end I didn’t feel the campaign was aimed at women like me, because if it was, it would have said ‘women’ at some point, so I just ignored it.

We advocate for the use of sexed-language in healthcare, especially in services that relate to pregnancy, birth, lactation, breastfeeding and infant care, as well as gynaecological care. We appreciate and respect that not all women may feel comfortable with such language, and this factor also needs to be taken into account in this Women’s Health Strategy. However, language should not be done at the expense of creating confusion that could negatively impact health outcomes (including for gender diverse people).

The Plain Language Bill (2) requires the public service to communicate with the public using language that is appropriate to the intended audience and in a clear, concise, and understandable way.

The Code of Health and Disability Services Consumers’ Rights (3) states in Right 1(3):

Every consumer has the right to be provided with services that take into account the needs, values, and beliefs of different cultural, religious, social, and ethnic groups, including the needs, values, and beliefs of Māori.

Right 5 states:

Every consumer has the right to effective communication in a form, language, and manner that enables the consumer to understand the information provided. Where necessary and reasonably practicable, this includes the right to a competent interpreter.

We want to acknowledge Manatū Hauora Ministry of Health's willingness and interest to listen to women’s voices in the development of this strategy and we look forward to having the opportunity to collaborate further to improve health outcomes for all women.


In this section we include links to articles to provide context and supporting evidence for our position:

1. The article Trans ideology is distorting the training of America’s doctors. Fear and ignorance are infecting medical education published by The Economist last year discuss the influence of gender identity theory in medical training and the negative consequences for transgender patients:

2. The BBC article Why transgender people are ignored by modern medicine explains the need for biological sex to be recorded in the health system in order to provide adequate care for trans-identified individuals. Significant issues have been caused by including people in screening programs based on their registered gender (a term traditionally used as synonym of biological sex that has changed its meaning in recent years to gender identity):

“The gender you’re registered as also dictates which screening tests you are invited to, meaning that thousands of transgender men could be missing out on potentially life-saving cervical (Pap) smears and breast exams, while transgender women could be missing out on abdominal aortic aneurism check-ups (or prostate cancer screenings, if they live in the US).”

3. The article It’s time to expand the definition of ‘women’s health’ ( raises the need for disease in research to study differences between men and women “with the recognition that diagnosis, prognosis and treatment might need to be different between the sexes”


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