SchoolDocs Backs Off “Gender Identity” – But Now Leans On An Activist Human Rights Commission
A WIN for Let Kids Be Kids and New Zealand families, but with a sting in its tail. We bring: The details, advice for parents/board members, and a free template for contacting your school
Let Kids Be Kids recently challenged SchoolDocs, the private company writing template policies for most New Zealand schools (and recently launched ECE Docs), over a key sentence in its Inclusive School Culture policy.
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‘Promoting Inclusion’ policy: Before and after
Before
Prior to being contacted by Let Kids Be Kids, the policy wording said prohibited grounds of discrimination could be based on:
“sex, race, age, colour… sexual orientation or gender identity, a disability, or other personal attributes listed in the Human Rights Act 1993 (s 27).”
This was doubly false:
The prohibited grounds are in section 21, not section 27.
Section 21 lists sex and sexual orientation, but does not list “gender identity” or “gender expression” at all.
We wrote to SchoolDocs pointing this out and asked them to explain the legal basis for the claim that “gender identity is one of the recognised prohibited grounds of discrimination under New Zealand law.” No statutory citation was provided. Instead, we were told the wording reflected “legal principles” and “sector practice,” and that any further research was our responsibility because we are not clients.
After
Today we checked the SchoolDocs policies for a school chosen at random, again. The policy has now changed.
The discrimination list has been brought into line with section 21 – it names sex, marital status, religious and ethical belief, colour, race, ethnic or national origins, disability, age, political opinion, employment status, family status, and sexual orientation, and correctly cites section 21.
“Gender identity” has been removed from that list.
This is a clear win for parents and for sex‑based reality. SchoolDocs has stopped adding into their templated school policy that “gender identity” is itself a listed ground in the Human Rights Act.
But there is now a sting in the tail
The updated policy now states that “prohibition of discrimination on the grounds of sex under the Human Rights Act 1993 is considered to include gender identity” and links directly to the Human Rights Commission’s (HRC) “What is unlawful discrimination?” page. There, the HRC explicitly states that discrimination “because of your gender identity” is unlawful, treating this as covered by the ground of sex.
In other words:
The Act is still sex‑based and does not mention gender identity.
SchoolDocs has stopped mis‑quoting the statute but is now pointing schools to a Human Rights Commission interpretation that folds “gender identity” into sex.
That interpretive position has not been written into section 21, and Law Commission material openly discusses the idea of adding new explicit grounds for gender identity and sex characteristics – which would not be needed if they were already there.
The Human Rights Commission is not a neutral scribe. It is actively campaigning to embed gender‑identity ideology across law and policy:
Its material asserts that you have a legal right to identify as any gender and that discrimination based on gender identity is unlawful, presenting this as a straightforward application of sex protections.
It was a key backer of the Conversion Practices Prohibition Legislation Act 2022, (read the HRC’s Conversion Practices Guidelines) which explicitly elevates “gender identity” and “gender expression” as protected characteristics in that Act, even though those terms still do not appear in s 21 of the Human Rights Act.
So the chain now looks like this
Parliament passes a sex‑based Human Rights Act in 1993.
The Government and the HRC adopt an interpretation that sex “includes” gender identity, without Parliament amending the Act to say so.
Professional bodies (like the NZ Law Society through its Gender Equality Charter) build “gender equality and inclusion” projects on top of that.
SchoolDocs imports the HRC interpretation into school policy and tells boards this is “legally sound” and “commonly accepted.”
At each step, contested ideology is presented as if it were simple, settled law. It isn’t.
The hidden problem: Policy changes with no visible history
There is another, more procedural problem that this episode exposes
SchoolDocs has just pushed a changed template into schools nationwide. The wording that once contained “gender identity” has disappeared and been replaced with something different. As far as we can see:
There is no public version history on the policy portal for parents or staff.
There is no way for a casual user to see what the previous wording was, unless they had taken a screenshot or saved a copy (like we did).
It is unclear whether boards are explicitly notified every time SchoolDocs alters the wording of a policy that their school has adopted.
Also of note: The law firm SchoolDocs thanks for assisting with the policy change
The law firm given acknowledgement at the bottom of the ‘Inclusive School Culture’ policy on SchoolDocs is Anderson Lloyd.
Anderson Lloyd is one of many law firms listed as signatories of the Gender Equality Charter on the Law Commission website.
It keeps going… Anderson Lloyd also promoted and raised money for Pink Shirt Day in 2025. Pink Shirt Day is run by the Mental Health Foundation and funds raised go to InsideOut. Which loops us back around to our initial Substack raising issues found in the ‘Inclusive School Culture’ policy, where the ‘what is bullying’ link promotes InsideOut.
Back to SchoolDocs…
If a private company can silently update the “law” as presented to your school, and there is no easy way to track what has changed, that raises basic governance questions:
How can boards discharge their legal responsibilities if they cannot easily see a change log, or compare old and new wording?
How can parents or staff ever prove that a contentious sentence used to be there if the template is overwritten and no official archive is visible?
Who actually controls the direction of school culture – the elected board, or an external contractor quietly syncing “sector practice” across the system?
This is not a small issue. It is how systems drift. Today it was a quiet removal of “gender identity” from a list (a positive change). Tomorrow it could be the addition of something far more radical, with nobody able to show what the previous version said.
At Let Kids Be Kids, the more we uncover, the more our minds boggle at the strategies in place to usurp parental authority and use sleight-of-hand tactics in ‘law’ that impacts the population, regarding ‘gender’ and not upholding basic sex-based rights. We keep referring back to Penny’s speech at the New Zealand First convention in September 2025, too:
The million dollar question
Who is being protected by these “inclusive” policies? Vulnerable students? Or adults in positions of authority who are introducing gender‑identity ideology into classrooms and counselling spaces, and wish to place their own conduct beyond criticism?
Why this matters for Let Kids Be Kids
We should celebrate what has been achieved:
A national policy provider has stopped asserting that “gender identity” is textually listed in the Human Rights Act.
The discrimination list in the Inclusive School Culture policy now mirrors s 21 much more closely.
But we must also be clear about what remains:
The Human Rights Commission is acting as an activist norm‑setter, redefining “sex” to include “gender identity” and exporting that into schools via official‑looking guidance.
SchoolDocs is the delivery vehicle, baking that interpretation into templates that most schools adopt with minimal scrutiny.
The lack of visible versioning or routine, transparent change‑notification leaves boards and parents in the dark about when, how, and why policies are altered.
For Let Kids Be Kids, the core principles are:
Tell the truth about the law. Section 21 does not list “gender identity.” Any assertion to the contrary is interpretation or advocacy, not statute.
Name activism as activism. When the HRC or anyone else expands “sex” into a gender‑identity framework, that is a political choice which should be openly debated, not smuggled in as “compliance.”
Protect children, not ideology. Anti‑bullying and “inclusion” policies should be grounded in material sex‑based reality and applied fairly to all students, not used as a Trojan horse for gender‑identity doctrine.
Call to action for boards and parents
Check your school’s ‘Inclusive School Culture policy’ (this will relate to the 80-85% of schools in NZ using SchoolDocs).
Confirm that “gender identity” has been removed from the list, and that s 21 is now cited.
Note any statement that sex discrimination is “considered to include” gender identity, and the link to the HRC.
Are they aware that earlier wording incorrectly cited s 27 and treated “gender identity” as if it were listed in the Act?
Do they receive clear, written notifications when SchoolDocs changes template wording?
Is there any way for them to view previous versions and track amendments over time?
Let Kids Be Kids has developed a free template for parents to ask about this policy. Download it here.
If you are a board member or have insight into how SchoolDocs communicates changes:
You can ask at your next board meeting or via email for the information listed above. If you are unsuccessful, you can ask for this information under the Official Information Act.
Please contact Let Kids Be Kids at contact@letkidsbekids.nz and let us know:
Whether your board is notified of each policy update;
What information is provided about the nature of the change;
Whether you have any access to version history or archived copies.
Parents need to know whether elected boards are genuinely in charge of their own policies, or whether “inclusion” and “gender” settings for New Zealand’s school children are being centrally edited, with changes appearing and disappearing down the memory hole.
This small victory over the wording of one sentence has revealed a much larger issue: who writes the rules our children and school employees are expected to adhere to, and how transparently those rules can be changed.
Read our earlier post on this matter:
Are School Policy Providers Quietly Re‑writing New Zealand’s Human Rights Law?
Across New Zealand, school boards are outsourcing policies to a private company called SchoolDocs. They service over 2000 NZ schools. This service promises “up‑to‑date” documents aligned with legislation. In reality, one unaccountable provider is telling most NZ schools what the law supposedly says
Let Kids Be Kids is here to support parents who want schools to return to reality: clear sex‑based protections, serious responses to bullying, and classrooms free from political indoctrination about “gender identity.”
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Thank you so much on your hard work on this. I really thought the tide was turning - it’s devastating to see companies pushing ideology into schools like this. My kid has just started a school that uses school docs and the school asks parents to review and comment on the docs - though I wonder what the point is if they can be centrally reissued like this with no clear version control/tracking. I will have to take a look and see if that particular policy has been updated.
Edit: Can confirm, this has been updated in our school policy too - with the same link to the Human Rights website.
Similarly, but not related to schools, last year the TVNZ programme Queer Aotearoa: We've Always Been Here -series 1-episode 6 stated that "the 1993 Human Rights Act, … outlawed discrimination based on sexual orientation or gender identity.” This is, as you say, untrue. However, in this TV programme, which would be watched by many young lesbians and gay men, they not only added 'gender identity' into the law, supposedly, but they also removed Sex. The law actually says 'sex' and 'sexual orientation' but does not include gender identity.
SEX is the very word left out of the reinterpretation of the law. But of course Sex was being discussed because “Lesbian, Gay, Bisexual”, at least, requires sex to be part of the meaning of these words. Without Sex there is no sense to what Homosexual, lesbian, bisexual or heterosexual means. This was being dodged in a TV programme, supposedly, about the history of Gay Liberation. This is an example of 'transing the gay away'.