The Professional Association for Transgender Health South Africa (PATHSA) is an interdisciplinary health professional organisation working to promote the health, wellbeing and self-actualisation of trans and gender diverse people.

We welcome the process of developing a new Official Identity Management Policy, and would like to make the following points:

• A solution has to be found that is inclusive of transgender, non-binary and intersex persons and that does not discriminate.

• We support the proposal of a random number that does not have certain digits as a gender marker.

• We reject the proposal of an alternate digit or letter “X” be used for non-binary, transgender and intersex persons, as it will be discriminatory and can lead to othering and victimisation, and such individuals to be “outed” by their ID number.

• The Alteration of Sex Description and Sex Status Act 49 of 2003 was revolutionary for its time but is unfortunately often misunderstood by officials and in urgent need of revision. We support the approach taken by Malta and Argentina that allows for the legal gender recognition of persons based on self-determination. We regard the current process of requiring letters from two health professionals as unnecessary and not in line with the medical ethical principle of autonomy. We definitely prefer a process of self-determination without the requirement of letters from health professionals.
• As health professionals, we are painfully aware of the struggle of our patients to change their identity documents to align with their gender identity. Currently they have to apply for a name change and gender marker change, which is very time consuming. We look forward to a more streamlined process.

Yours sincerely

Chris McLachlan

Chairperson: PATHSA