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At an individual level, as civil servants, we are subject to the civil service code, in the same way that ministers are subject to the equivalent ministerial code of conduct.
The sexual orientation and religion questions are voluntary, because that is in effect hard-coded into the primary legislation. It was left to an exercise of subordinate legislation powers to make the trans question voluntary, so the 2019 act paved the way for getting to where we are.
From our perspective, the tools fit nicely with our codes of practice on the values, behaviours, skills and competencies that workers are required to have in delivering care.