Dilemmas of school-based relationships and sexuality education for and about consent

ABSTRACT In 2018, reflecting in this journal on the arrival of the ‘age of consent’ into sexuality education, Jen Gilbert questioned what would happen to a concept drawn in part from legal contexts, but partly also driven by the passion of feminist activists, when it met the demands and logics – the learning outcomes and lesson plans – of the classroom. This article offers one response, drawing on qualitative data from two whole-school sexual health programmes, Positive Choices and Project Respect, piloted in secondary schools in England between 2017 and 2019. It describes how each addressed the issue of consent and focuses on specific ‘moments’ that illuminate some of the challenges of doing so for both staff and students. Our analyses aim to contribute to the practice of relationships and sexuality education in schools by helping educators to anticipate, understand and therefore better address the dilemmas that teaching for and about consent might encounter. We argue that these dilemmas relate both to broader (and gendered) ideas of consent and entitlement, and to issues specific to schools. However, we also argue that a more theorised account of the school enables us to identify the minor achievements that are nonetheless possible.


Introduction: the 'age of consent' arrives in school
In 2018, Jen Gilbert reflected in this journal on the arrival of the 'age of consent' in sexuality education and questioned what would happen to a concept in part drawn from legal contexts, but also driven by the passion of feminist activists and campaigners, when it met the demands and logics, the learning outcomes and lesson plans, of the classroom (Gilbert 2018). Feminism has long worked to expose the normalisation of violence and coercion within heterosexual relations and to imagine women's sexuality as active and desiring rather than passive (Whittington and Thomson 2018;McGeeney and Kehily 2016;Fine 1988). It is well-known that experiences of sexual violence are gender-specific, under-reported, under-prosecuted and more likely within relationships (Walby et al. 2017). Educating for and about consent is tasked both with preventing sexual violence by reducing non-consensual sex (assuming that at least some instances of rape derive from an inability to read or communicate sexual cues), and enabling an 'enthusiastic yes' to sex (Coy et al. 2016) to be sought and heard, particularly from girls by boys.
Reflecting these demands and following consultation with educators and campaigners, the government recently mandated relationships and sex education (RSE) and health education as statutory for all secondary schools in England from September 2020. Its 2019 guidance refers a dozen times to the concept (including the legal age) of consent (DfE 2019). Previous guidance issued under the UK Labour government in 2000 focused little on relationships and omitted sexual consent entirely. Similarly, while much research literature on the importance and effectiveness of RSE still tends to focus on prevention of sexual health outcomes deemed negative, such as unintended teenage pregnancy, 'early' sexual debut and sexually transmitted infections, there is increasing attention to constructs such as 'sexual competence' (encompassing contraceptive use, individual perceptions of consensuality and autonomy) (Palmer et al. 2017), as well as dating and relationships violence, healthy relationships, and sexual communication skills.
A body of research, however, has problematised the concept of consent and its meaning for young people. Beres argues that formal consent was seen by the young people she interviewed as a 'bare minimum', which did not connect to their more nuanced thinking about sexual communication and ethics (2014). Further, she argues that in casual sex both genders had similar levels of 'literacy' around sexual meanings, challenging the 'miscommunication' theory of sexual assault (2010). Research with young people in Australia (Powell 2010) suggests increasing acknowledgement of women's sexual agency and mutuality that is nonetheless uneven and still attached to traditional gendered roles and expectations (for instance, of male initiative-taking). Coy et al raise concerns that young people too readily identify certain situations as legitimating coercion and that the concept of consent does not resonate for them (Coy et al. 2016). Albury and Crawford assert that young people are themselves developing an emergent ethics about consent in relation to sexting that is hindered by potentially criminalising legal definitions (Albury and Crawford 2012). Fischel (2016) observes that contemporary sexual liberalism and pluralism have in many Western contexts made sexual orientation (towards different or same-sex partner, even of single or multiple partners) less morally significant than the issue of sexual autonomy, that is to say, whether those choices can be said to be 'freely' made. He argues that this helps explain new ethical complexities relating to consent and youth, whose autonomy in relation to sexuality is already contested. Fields's research similarly notes the challenges of sexuality education (or, we might add, an 'enthusiastic yes' to sex more generally) in a context where youth sexuality per se is often imagined as 'a problem to solve, delay or mute' (Fields 2008, 169). Indeed, a dominant theme in many school RSE interventions is its role in postponing sex altogether (Kirby 2007). We might therefore question how far RSE can prevent non-consensual sex without addressing the wider patriarchy (Anderson 2009).
If sexual consent is indeed shaping the contemporary landscape of sexuality education, now may be a timely point at which to reflect on the possibilities and limitations of teaching consent in schools. Here, we offer reflections from the 'frontline' of current educational practice by drawing on data from Positive Choices and Project Respect, two multi-component and whole-school pilot interventions in England funded by the UK's National Institute for Health Research (NIHR). This analysis aims to explore the place of consent in the intervention materials, how consent featured in classroom teaching and discussion, and student and staff responses to this.

Methods: the broader context of Project Respect and Positive Choices
Project Respect aimed to reduce dating and relationships violence and was developed with two and piloted in four schools between 2017-19, in partnership with the National Society for the Prevention of Cruelty to Children (NSPCC), a child protection charity. Positive Choices was an RSE intervention aiming to reduce unintended pregnancies. It was developed with one and piloted in four schools during 2017-19, in partnership with the Sex Education Forum, an advocate for and provider of RSE. Both interventions included curricula alongside whole-school elements. Project Respect involved: staff training; six lessons for year 9 students (aged 13-14) and two for year 10 students (aged 14-15); school policy review; 'hotspot mapping' by students and staff of safe and unsafe spaces in the school which could then be patrolled by staff; an app so that students could seek support from trusted individuals should they feel at risk of dating and relationships violence; and parent information (Meiksin et al. 2019). Positive Choices included: developing a report of student needs (focused on sexual knowledge and what they wanted to learn in RSE) based on a survey of students in year 8 (aged 12-13); the provision of staff training; the creation of a School Health Promotion Council (SHPC) for staff and students to plan and oversee the intervention, including some lesson selection; ten 60-minute RSE lessons for Year 9, which included eight 'essential' and two 'add-on' lessons chosen from five; a student-led 'social marketing' campaign on aspects of RSE; a review of locally available sexual health services to improve provision and/or access; and the provision of parent information (Ponsford et al. 2018). Based on research that showed promising outcomes for similar approaches (e.g. Taylor, Mumford, and Stein 2015;Philliber et al. 2002), these elements were intended to work synergistically to promote sexual health by improving knowledge, skills, sexual competence, confidence and ability to communicate about sex and with parents as well creating a school environment supportive of sexual health.
The Project Respect and Positive Choices pilot studies focused on assessing the feasibility and acceptability of delivering whole-school interventions to ascertain the potential for a trial of effectiveness in English secondary schools. Both involved systematic optimisation of the intervention using participative methods, and a pilot cluster RCT across six schools (four intervention, two control) with integral process evaluation. In the pilot RCT phase, schools were recruited by email, purposively sampled to be diverse according to various measures of local deprivation and school-level educational attainment. Following completion of a baseline survey, schools were randomly allocated to control and intervention groups. Control group schools delivered relationships and sex education without any modification from the research team.
The data discussed in this paper are drawn from the qualitative elements of the process evaluations, which involved researcher observations and provider, student and staff interviews. Researchers were present at staff training sessions (of which the Sex Education Forum provided one for each component of the Positive Choices programme and the National Society for the Prevention of Cruelty to Children one overall for Project Respect), at least one meeting per school of Positive Choices' SHPC and student-led social marketing activities, and a minimum of one lesson per school for each intervention. Structured field notes were collected from observations focussing on what topics and activities were covered and how the lesson was delivered. After intervention delivery, interviews were conducted with two NSPCC and three SEF staff and school staff and students. School interviews took place in private on school premises with a minimum of 6-8 students and 4 staff in each intervention school and 4 students and 2 staff in each control school. Interviews were semi-structured, with guides covering topics such as school culture, experiences of delivering and receiving the various programme components and staff and student satisfaction and engagement with these.
In Project Respect, at the pilot stage, we interviewed 21 staff and 40 students in six groups and observed three lessons. In Positive Choices, across optimisation and pilot phases, we conducted interviews with 28 staff and eight student groups totalling 64 students, and observed 15 lessons. Sampling was purposive with regards to staff seniority and role, and student age and gender. Ethical approval for this work was gained from the London School of Hygiene and Tropical Medicine Ethics Committee. For each activity, informed written optin consent was sought from all research participants, including students. Parents were informed about the study and could exclude their children if they wished. Interviews were transcribed in full and were subject to thematic content analysis using in-vivo and axial coding. Teaching and learning about consent proved to be a salient theme on which this paper reports our findings and reflections. We describe how each curriculum addressed consent and identify 'moments' in our data that illuminate some of the challenges of doing so for both staff and students. Our analysis aims to contribute to improving the practice of RSE in schools; it is indebted to significant recent theorising of sexuality education (Allen and Rasmussen 2017;Quinlivan 2018

Teaching 'consent' within a whole-school approach: curriculum materials
Across the thirteen lessons provided by the Sex Education Forum for Positive Choices, only a minority addressed traditional RSE topics of the body, conception, contraception, STIs and pregnancy options. The majority focused on relationship skills, personal and critical reflection (for instance on readiness for intimacy, and on issues such as pornography and sexual response and pleasure). In this, they represent current moves towards comprehensive curricula for sexual competence or skills, embracing pleasure and mutuality as part of sexuality education.
Consent formed one specific lesson topic. Its learning outcomes were: • be aware of some of the ways that people communicate consent and non-consent; • understand what sexual consent means, and why it is so important; • know that sexual consent requires choice, freedom, and capacity; • understand the legal age of consent and that most young people do not have sex until after they have passed the age of consent.
The key messages were: • responsibility lies with the person seeking, not the person giving consent; • it is not always easy to communicate how we feel and what we want -these are skills to practice and develop; • there is a legal definition of sexual consent and the law is designed to protect young people from harm; • all young people have the right to access confidential services even if they have sex under the age of consent.
The lesson therefore aimed to go beyond a 'no means no' message and beyond binary notions of consent as a simple 'yes/no'. It acknowledged that consent needs to be articulated rather than assumed and encouraged students to reflect on what this might look and feel like, providing the legal definition but also emphasising affirmative consent (that responsibility rests with the seeker). It emphasised rights for young people (to protection but also to access services). The resources and activities suggested for conveying this learning, described in more detail below, included: asking students to 'explain consent to an alien' prior to being given the legal definition; a 'consent line' exercise; a two-minute video comparing sexual consent to borrowing someone's mobile phone; a quiz about the age of consent and access to sexual health services under 16; and lists of local and national health service advice and counselling services. These were provided on Powerpoint slides. Pedagogically, the materials attempted to build in different ways of learning (individual, pair and group discussions; participatory, interactive and information-giving approaches). They also recognised the contribution of out-of-school sources for pedagogy, advice and support: the 'consent line' activity came from the Personal, Social, Health and Economic Education Association, a UK charity supporting schools and teachers delivering the subject; the video from Rise Above (https://riseabove.org.uk/article/thebasics-of-sexual-consent/); and additional links were provided to Justin Hancock's Bishuk (https://www.bishuk.com/sex/how-to-sex-talk/). Consent was imagined as involving physically embodied interactions; questions of online or mediated interaction did not figure at this point, although they did in the guidance notes where exchanging explicit images under the age of 18 was noted as illegal. Finally, the question of consent emerged at other points in the materials, for instance in lessons on 'Readiness for intimacy' where students were encouraged to reflect on the role of alcohol in decision-making about sex, and on 'Pornography' via a comedy drama Screwball! (Tyler 2017) The Project Respect materials developed by the NSPCC covered consent alongside 'boundaries' and 'spaces' in one lesson in year 9 (ages 13-14). The 'booster' lesson in year 10 (ages 14-15) also addressed 'communication and consent'. The year 9 lessons were described as teaching about 'the meaning and importance of consent', and as enabling students to 'explain the meaning of consent in different contexts'. In year 10, the learning outcomes were: • describe why effective communication skills are necessary for a relationship to be healthy; • explain the meaning of consent in different contexts; • explain that everyone has the right to change their mind, or not to give, or withdraw their consent.
The teaching centred around a video 'Listen to your selfie' produced by Childline/NSPCC (https://www.childline.org.uk/info-advice/friends-relationships-sex/sex-relationships /healthy-unhealthy-relationships/listentoyourselfie-lara-and-paul-stories/). The video was to be shown in both years, with different activities and discussion questions. We do not intend to suggest that these outlines offer ideal templates for teaching consent. Indeed it could be said that they offer insight into the constraints of RSE provision in many English secondary schools. The materials were supported by training and were not meant to supplant all other RSE provision; teachers could adapt them to suit their context, audience and professional vision. Nonetheless they were also 'manualised', created as 'plug and play' resources that could be used with minimal preparation. Rather than representing what the research team or partners saw as best practice, this design responded to feedback from stakeholders that materials should fit with the reality that RSE (at that point, a nonstatutory subject) was often afforded little priority, time for preparation was limited and non-specialist and often less-experienced teachers would deliver it.

Findings 1: Legal discourse in the classroom and the challenge of relevance
As noted, the Positive Choices lessons included the legal definition of consent as involving 'freedom, choice, capacity', what those terms meant, and that sex below the age of consent is illegal. Asking students to explain consent to an alien (or simply to define it, as some teachers adapted the instructions) tended to give voice to students most comfortable with a formal or elaborated code. During one lesson, a student confidently defined consent as 'written or verbal agreement for someone to carry out an action', while others more tentatively offered 'saying yes or no'. Subsequent discussions suggested students were in principle comfortable with liberal notions of freedom and choice: 'it's your body' as one commented.
Notions of capacity to consent, however, appeared more elusive. In a Positive Choices lesson on 'Readiness for Intimacy', a class debated the statement that 'if you are deciding to have sex, it is a good idea to drink alcohol'. One male student commented that 'if the woman is drunk you might think she wants sex and then you could be sent to prison for a crime you didn't commit'. This emphasis on legal consequences of the capacity clause for (implicitly 'naïve' and 'innocent') men has been echoed in online debate and in highprofile media cases (Royal 2019). Neither the teacher nor other students challenged him, suggesting the learning outcomes for the consent lesson had not been fully absorbed.
Moreover, a focus on the procedural appeared bewildering for some students and difficult for staff to explain: So, one boy said to me . . . 'I don't understand, do we have to stop what we're doing and do we have to say, "Do you give consent?" Do we have to use that word?'. And I'm thinking. 'You don't have to use that word but there has to be some verbal communication'. And he said . . . 'I don't really get it, like I don't get how you . . . '. And so he was really confused. And I answered it as best I could using the information from Project Respect and also my knowledge. But I felt like he was challenging. But at no point in the training had [that been addressed]. You know, some role play of that would have been really good.

(Teacher interview, Project Respect)
An approach that constructs sex as a series of discrete acts for which a 'doer' must elicit verbal consent from another may be implausibly remote from common understandings and experiences of mutual sexual interactions. Such an overly simplistic and legalistic approach that students find baffling and unrelatable might have the unintended consequence of hindering rather than supporting consensual practices.

Findings 2: Embodying consent: how active learning may promote understanding of consent
One exercise in the Positive Choices lesson -'Parallel lines and personal boundaries' -was taken from freely available materials provided by the Personal, Social, Health and Economic Education Association. It involved students lining up opposite each other in pairs. One student was instructed to take small steps towards the other, at each point seeking consent to do so ('may I take another step?'), using verbal and visual cues to stop when the partner felt uncomfortable with their proximity.
In several schools, the exercise proved unworkable; the difficulty of rearranging furniture in small crowded rooms, with up to 30 students, was too big a barrier for such active learning. Consequently, some teachers reported calling a few students to the front of the room to demonstrate it to others and others omitting it altogether. This indicates how far school architecture and class sizes embed notions of students as largely passive and immobile.
A teacher interviewed in one school was dismissive of the exercise: 'They know each other well, they're comfortable with getting close to each other, so it doesn't really help'. However, staff in another school argued that the exercise was particularly enlightening, offering an embodied representation of individuals' different comfort lines and boundaries: '[Students] thought everyone would have the same stopping point, but, when they looked down the line, they could see that they didn't'. As others have proposed, promoting learning through embodied practices may provide a powerful way of knowing (Renold 2018). In this school, the lesson on consent was seen as having had a significant impact. According to all staff interviewed, it changed notions of what was acceptable: girls began to question previously normalised behaviour in the school and several reported sexual harassment to staff.
In another school, we observed a teacher struggling to convey the key point about seeking consent, instead asking students to 'stop when your partner tells you to'. He repeated the task several times with slightly different instructions, including one to the student advancing to 'stop when YOU want to', adding rather anxiously 'but don't touch them!' and finally re-allocating students so they were not in friendship pairs. As a result, amidst much laughter, students ran rapidly towards their partner, except in the final case where one girl was made to remain at the start line by her male partner. We interpret this as showing firstly that the notion that consent is the responsibility of the person giving it is deeply entrenched and hard to dislodge. This was also confirmed by interviews in all schools, where both teachers and students repeatedly used linguistic constructions related to 'giving' rather than receiving consent: even where students claimed that the lessons had helped them understand their rights, these were more often described as rights to 'say no' rather than their right to be asked and heard. Secondly, the final version of the exercise might have provided an opportunity to discuss how failing to gain consent might be a humiliating experience that nonetheless needs to be managed. However, the classroom may not be an easy context in which to share such issues, especially when drawing attention to what might be seen as a stigmatising and personal rejection. A point to which we return below is that lessons in both interventions aimed to stimulate collective discussion and critical reflection in order to shift social norms. Yet many teachers found such open pedagogy difficult to manage and requested more lesson content instead.
In one researcher-observed lesson that strongly delivered the message of seeking consent, the woman teacher supplemented the line exercise with a recommended Bishuk resource on non-verbal and coded communication. Her rationale was that students might not otherwise be clear about how consent might be given or withheld. The images from the resource gave students the opportunity to see how such approaches fit with people's typical communication patterns and are well understood (c.f. Beres 2010). Students commented that the lesson had been informative: 'I had thought one thing just led to another' offered one girl, implying that it may have disrupted a discourse of romance or passion (in which one gets 'carried away' and consent is assumed rather than sought).

Findings 3: Screening consent and the 'missing discourse' of media studies
Most of the Positive Choices schools did use the suggested video from Rise Above, which compares sexual consent to borrowing a mobile phone, to raise issues such as accepting a refusal and seeking ongoing consent for repeated or different uses of a phone. Universally, however, schools showed students the 'cup of tea' video in place of or as well. This video derives from a 2014 post by blogger Rock-Star-Dinosaur-Pirate-Princess https://www.youtube.com/watch?v=pZwvrxVavnQ. Through stick-figure cartoons and a male voiceover, the video reinforces a message that consent is 'as simple as tea', repeating lines like 'don't force someone to drink tea . . . especially if they are unconscious'. Teachers stated that they preferred its simplicity and single voice to the multiple contributors in Rise Above, and that students liked its humour; many students we interviewed agreed, describing it as one of the most memorable aspects of the lessons and on 'their level'.
The cup of tea video has the virtue of focusing entirely on the person offering the tea (inviting sex), conveying that an issue involving less personal investment (offering tea rather than seeking sex) makes it easier to identify ethical boundaries and the inappropriateness of pressure. However, this simplification has also drawn criticism. Brady and Lowe (2020) argue that it does not engage with cultural factors that may make declining tea difficult and that the comparison risks obscuring the different gendered norms to which sex and tea are subject.
In principle, the video might be used to address these points and encourage more nuanced arguments, exploring where it is inappropriate or uncomfortable to refuse tea, or where it is assumed that everyone drinks tea or that everyone likes it a certain way. However, our perception was that the video was commonly simply screened in lessons without much discussion. In one of the Positive Choices control schools, students even claimed to have been shown it twice every year, evoking age-old complaints about school sex education's repetitiveness, overused resources and lack of coordination.
Concern about the use of AV resources was much more acute in relation to the film included as part of the Project Respect intervention. It showed a young girl, Lara, having a tame night in with friends. An older man she knows, Dan, arrives with his friends and alcohol, makes moves on Lara in the kitchen which she resists then tries to lead her upstairs. At this point family photos on the stairs and selfies on her phone come to life and ask Lara if this is what she really wants to do, ending with the line 'Not sure what to do? #ListenToYourSelfie. And if you're still not sure, talk to us [Childline]'.
Generally, students and other young people who were consulted in developing the materials responded positively to the video, which had high production values. Experts in supporting victims of sexual abuse and some teachers, by contrast, were gravely concerned that it could be triggering and too 'hard-hitting'. The former also objected to the focus on Lara's responsibility to react, which was implicit in the video and in the initial classroom discussion guides, rather than on Dan's behaviour. This perpetuated the message that girls must learn how to control men's behaviour and keep themselves safe.
Some teachers stated that they had used contemporary portrayals of issues of consent in popular media to enrich discussions. It has long been argued that popular cultural forms, such as soap operas and magazines, can support RSE in the classroom (Bragg 2006). However, our impression was that, again, teachers treated such texts as transparent: that is, students were invited to 'see through' them to the issues they raised. There might be fruitful dialogue in this respect between RSE and media educators. Media studies practices encourage a close reading of the 'languages' and meanings of texts, asking critical questions about their production (who made this? how did it reach our screens?), audience (who is the target and how do you know?), representation (how is this depicted? where is the camera? how does it position us? what world-views or ideologies might it support? how else could it be interpreted?) (Buckingham 2019). Such approaches might have addressed concerns about the inadequacies of supplied resources, provided important contextual information, and enabled students to develop critical perspectives that could also have informed their own campaign materials.

Findings 4: Disciplinary responses to 'problematic' students
The teacher tells me about the consent lesson, saying he told students that even if you meet a woman in a bar, have drinks together, she comes back to your hotel, takes her clothes off and lies down on the bed next to you . . . you do not have the right to have sex with her without consent. He relates that a male student responded that in such a case 'I'd give her a slap!'. The teacher says there were intakes of breath from other students and that he gave the student an hour's detention -'I had to, it was unacceptable . . . '.

Observation notes, Positive Choices Intervention School 1
Teachers faced with students' challenging, sexist or homophobic statements, as above, often activate disciplinary procedures. However as Quinlivan (2018) argues, these embed problematic assumptions: for instance, that it is only certain individuals whose thoughts, attitudes or actions are unacceptable, and that certain forms of speech in the classroom are 'injurious' (Butler 1997), or damaging even to be voiced. Punitive responses may even make it harder to address how an individual student's response is symptomatic of and embedded within wider norms that deserve critical exploration. Issuing detentions makes the RSE space more like others in school, when it might be RSE's difference that students and staff value about it (Quinlivan 2018). Insofar as reducing rates of non-consensual sexual experiences requires reducing the number of people who are pressuring others, approaches should speak clearly to students who are or might in the future be pressuring their partners (not exclusively but primarily boys); exclusion or detention is unlikely to be effective in terms of this ultimate aim.
With hindsight, it is perhaps easy to identify that incident described above offered a 'teachable moment'. The teacher's objection would likely have received support from others in the class (as indicated by their gasps); expressed by peers rather than by a teacher, this might have been more powerful and potentially more enduring in shifting social norms and supporting forms of mutual accountability identified as key to dating and relationships violence prevention (Wekerle and Wolfe 1999;Stanley et al. 2015). Nonetheless, we can appreciate the dilemmas here, which include the teacher's inexperience; how far a school's approaches to teaching and learning support inter-student dialogue; and when or whether 'zero-tolerance' school policies around gendered and homophobic bullying, however well-intentioned, might legitimately be suspended in RSE classrooms.
A further example of a punitive response involved the school where teaching about consent increased rates of girls' disclosure of harassment. The school reportedly dealt with this in a gender-polarised way. Boys described in resentful terms a boys-only assembly in which they were 'shouted at', as if all were equally responsible for such undesirable/illegal behaviour, and threatened with potential legal consequences. Tensions were re-played in our focus group, with some boys complaining that there had not been a problem before, blaming the disclosures rather than the original harassment and refusing to recognise the problem, with girls responding 'so you want us to keep quiet then?'. It was unclear whether these events had any effect on the wider school, since only year 9 were included in the lessons and the subsequent fall-out and none of the whole-school components were implemented in the school. Again, there seemed little space for critical thinking and collective reflection to generate equitable, solidaristic, and community-focused solutions instead (perhaps by redrafting school policies and procedures that had previously failed to identify and challenge such behaviours, or by exploring how boys too are constrained and harmed by cultures of harassment and homophobia (Pascoe 2011)).

Findings 5: Ambiguities and dilemmas of gendered power dynamics in relation to consent
Much research has argued that a gendered approach is necessary to address power relations in consent. The example above shows the damage that a binary approach to sexual harassment may create, and we have also already noted the difficulty of moving beyond a focus on girls' responsibility to resist sexual pressure (in the Project Respect materials) and tropes of unjustly accused men. In two other observations, we noted that when female students raised men's violence to women, their (male) teachers responded by stating that women too could be perpetrators (both citing a then-recent BBC documentary 'Abused By My Girlfriend'). The most generous reading of this is that discourses of equality (rather than equity) to which many schools subscribe inadvertently legitimate the creation of such false equivalences. Furthermore, teachers may not be trained or even willing to address gendered power dynamics. Finally, the complexities of sexual cultures are not easy to address in classrooms, as we noted in the case of a highly experienced and committed teacher who counselled students on how to avoid having their drinks spiked at the same time as asserting the need for an 'enthusiastic yes' to sex. Both pieces of advice were sound, but in juxtaposition gestured to the existence of those who refuse the culture of consent that her students were invited to inhabit, and downplayed the gender relations involved.

Findings 6: The significance of context to teaching consent
In the schools involved in this research (which we suggest are representative of many others), there was a notable pattern of assigning teachers and in some cases even nonteaching staff to deliver RSE, simply because no one else was available. Some schools did not timetable PSHE as a subject and instead delivered it in shorter tutor group times or one-off 'drop-down' days. Teachers described a lack of confidence, willingness or training to teach; many were newly qualified and already under observation; some women mentioned the challenges of teaching about consent and healthy relationships when they themselves had experienced sexual violence. Some literature on implementing dating and relationships violence interventions (Cascardi and Avery-Leaf 2014) recommends that teacher training includes reflection on teachers' own relationships, communication and emotion-management skills, but this underestimates both the vulnerability to which it exposes teachers and the probable high turnover of staff delivering such work.
To convey the significance of school context and ethos to successful RSE implementation, we will describe a school that stood out as different. It was a school of over 1800 students described by staff as 'happy'. The senior leadership prioritised pastoral aspects of the school's mission, evidenced by an on-site counselling service, a distinct PSHE department and timetabled PSHE lessons for students, with attention also to staff wellbeing and community. The long-standing head of PSHE described being trusted to 'get on with the job' by the principal; she oversaw its spiral curriculum and resources, in dialogue with others (e.g. local services; a trans student on transgender issues). Staff opted to teach PSHE and were generally experienced and committed; they used 'correct' (medical) terminology from year 7 and a common set of ground-rules to make lessons safe; anonymous question boxes enabled awareness of students' concerns. Staff described their PSHE role as a privilege, commenting that 'PSHE here is respected', 'kids realise it's a space to ask questions', that 'it's needs-led'. Students interviewed valued PSHE as 'about life' and less pressured than academic subjects. They stated that they liked hearing 'everyone's' and 'different' opinions, that peer relationships were positive enough for students to feel comfortable discussing and sharing issues in class: 'we all get on well', 'it's not awkward, it's mainly just like a fun, comfortable place to just talk about stuff'. The school had an active LGBTQ society, some of whose members volunteered on the School Health Promotion Council. Whilst one of these complained about the 'heteronormativity' of the Positive Choices lessons, we were nonetheless impressed at her confidence that the school was a sufficiently safe space to discuss LGBTQ issues.
This example may shed light on many factors that contribute not only to successful RSE but also to appropriate teaching for and about consent. These extend from leadership, championing and prestige of the subject and stable, trained staffing, to more intangible questions about consideration of staff and student well-being and convivial relations between and among staff and students (Bragg and Manchester 2017;Markham and Aveyard 2003). More specifically, the school ethos itself modelled consent in its processes and decisions about RSE delivery. Without this broader culture, it is hard to see how individual lessons on consent can have the impact they intend. Nonetheless, we may need to acknowledge the inherent limitations and ironies of teaching consent in a fundamentally non-consensual institution, attendance at which is compulsory.

Discussion: horizons of possibility in teaching consent
This paper has explored the place of consent in classroom materials developed for Positive Choices and Project Respect, how consent featured in classroom teaching and discussion, and student and staff responses to this. We have charted some difficulties and dilemmas, not to criticise the materials or the teachers involved, but to illuminate challenges that might be encountered (Beres 2020).
Our analysis has explored how legal definitions were of limited utility, while being simpler to teach and focus on. We observed that teachers often struggled to convey the key message of seeking consent and, even where they acknowledged the need for 'affirmative' consent, seemed uncomfortable in addressing inequities and the complex or gendered power dynamics of sexual relations. Not all teachers had the skills to facilitate potentially sensitive classroom discussions or to use media texts creatively, and the physical set up of classrooms often inhibited active, embodied learning about consent. Conventional teacher-student relationships and policies sometimes made reaching for disciplinary and punitive responses easier than collective dialogue.
But we also recognise that teaching consent requires a lot from teachers: to engage students in open-ended learning with few 'right answers', that may even evoke their own experiences of non-consensual sex, often where they themselves are under surveillance and insecure about their practice or where consent is not modelled in school processes -and all this without good quality initial teacher education about RSE and continuing educational support. There may indeed be a case for entrusting education about consent to specialist organisations or educators with the skills and commitment to deliver it (Pound et al. 2017).
Nonetheless, given that RSE is about to become statutory in England, another direction might be to rethink and reframe our analyses of the school as an institution, which is often subject to over-generalised demands and claims about its functions. Pykett et al have argued, following Hunter (Pykett et al. 2010;Hunter 1996), that identifying the school as an historically contingent and uneven assemblage -a 'pastoral bureaucracy' -may be more generative analytically. It would sensitise us to the different elements contributing to the diversity of practice we describe here. For instance, what we depicted as the 'consensual' school emerged from specific histories of inclusion, 'progressive' teaching, community-embeddedness, and the relations of key ethical actors (such as the principal and department head). The more problematic processes of imposed and top-down pedagogies we identified also bore traces of (distinctly English, but also global) education policy trajectories. Such a perspective may help us appreciate the marginal gains that are nonetheless possible in some contexts. The lessons can be seen to have started a conversation about consent (including what counts as affirmative consent, the role of non-verbal communication, the significance of seeking consent, how substance use might make consent more complicated, 'disrupting' notions of passionate abandon) that in some circumstances and to some extent provided alternative positionings for young people beyond an activemasculine, passive-feminine binary. This was valued by young people and, in at least one school, girls appear to have seized the invitation that the lessons offered to challenge harassing behaviour and assert their rights. If the conversations were incomplete, the problem lies partly outside the school: in established cultural views of consent as resting with the giver, discourses of male initiative-taking, entitlement or victimisation, etc. Even within the school, what is possible within an RSE lesson exists in complex tension with wider school processes, particularly school policies on pedagogy and behaviour.
Our research suggests the value of experience-near approaches which focus on plausible examples from teenagers' lives rather than implausible scenarios or distant hypotheticals. RSE teaching might best address young people's experiences and interests by focusing on the current and future realities of people's lives. These will include gendered experiences of school cultures and (wanted and unwanted) touching that happens on a daily basis in school, without assuming that this affects only one gender or only students. We have suggested that there could be a dialogue between media and sex educators to develop critical viewing skills. Meanwhile, there exist materials that address consent in subtle and complex ways, such as Justin Hancock and Meg-John Barker's handshake-based analogies https://bishtraining.com/ three-handshakes-an-activity-for-learning-how-consent-feels/or Elsie Whittington's 'continuum' of consent (Whittington and Thomson 2018). We need more such materials that emphasise the gendered aspects of consent and address ambivalence, without promulgating fantasies of perfectly rational agents, or relinquishing teachers' and students' occasional need for clarity and simplicity. Schools may require more support to access and understand how to use such resources. Education on consent needs to engage with the difficulty of the concept or else it will do little to enable young people. However, young people themselves are capable of engaging in these debates; there is already sufficient diversity even among groups of peers to shift norms in more pro-social and accountable directions. Here, it is worth noting that both Positive Choices and Project Respect encouraged student-led campaigns, some of which attempted to raise questions of consent and intimacy ethics. Finally, teaching about consent requires a strong sense of justice, rights and equity; skills, commitment and confidence; a supportive structure in terms of time, space, school culture; and attention to the broader social norms that do not support consent or stop those intent on sexual violence.