Safeguarding and Child protection - Low Level Concerns

Low Level Concerns Policy 

(addendum to Safeguarding and Child Protection Policy)

2024-2025

Introduction

This section is based on concerns that do not meet the harm threshold in part 4 of Keeping Children Safe in Education and the Pan Dorset Safeguarding Children Partnership guidance on allegations against staff, carers and volunteers. 

This applies to all concerns (including allegations) about members of staff, including supply teachers, volunteers and contractors, which do not meet the harm threshold. 

Concerns may arise through, for example: 

• Suspicion 
• Complaint 
• An allegation made by a child, parent or other adult within or outside the school 
• Pre-employment vetting checks 

We recognise the importance of responding to and dealing with any concerns in a timely manner to safeguard the welfare of children. 

Definition of Low-Level Concerns 

The term ‘Low-Level’ concern is any concern – no matter how small – that an adult working in or on behalf of the school may have acted in a way that: 

• Is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, and 
• Does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the designated officer at the local authority 

Examples of such behaviour could include, but are not limited to: 

• Being overly friendly with children 
• Having favourites 
• Engaging with a child on a one-to-one basis in a secluded area or behind a closed door 
• Using inappropriate sexualised, intimidating or offensive language 
• Humiliating children

Such behaviour can exist on a wide spectrum, from inadvertent or thoughtless through to that which is ultimately intended to enable abuse. 

Sharing Low-Level concerns 

We recognise the importance of creating a culture of openness, trust and transparency to encourage all staff to share low-level concerns so that they can be addressed appropriately. 

We will create this culture by: 

• Ensuring staff are clear about what appropriate behaviour is, and are confident in distinguishing expected and appropriate behaviour from concerning, problematic or inappropriate behaviour, in themselves and others 
• Have clear policies and procedures, including a staff code of conduct 
• Empowering staff to share any low-level concerns 
• Empowering staff to self-refer
• Addressing unprofessional behaviour and supporting the individual to correct it at an early stage
• Providing a responsive, sensitive and proportionate handling of such concerns when they are raised
• Helping to identify any weakness in the school’s safeguarding system

Reporting a low level concern 

It is imperative that all low-level concerns are shared responsibly with the right person and recorded and dealt with appropriately. 

Low level concerns about a member of staff should be reported to the Headteacher as per the school’s Child Protection procedures.

If the concern is about the Headteacher this should be reported to the Chair of Governors.

Low level concerns about supply staff, contractors and local authority visiting staff will also be reported to their employers.

Staff should use the school’s Low-Level Concerns Reporting Form (appendix one) 

Responding to low-level concerns 

If the concern is raised via a third party, the Headteacher will collect evidence where necessary by speaking: 

• Directly to the person who raised the concern, unless it has been raised anonymously 
• To the individual involved and any witnesses 

The headteacher will use the information collected to categorise the type of behaviour and determine any further action, in line with the school’s staff Code of Conduct. 

• Allegations that meet the harm threshold will be referred to the LADO for advice
• Low level concerns that the school feel may need further guidance on will be referred to the LADO for advice
• Low level concerns that the school feel they can deal with internally, will be dealt with via the school’s usual child protection investigation process (which is detailed within the safeguarding policy)
• The school will engage with its HR provider where it is necessary to undertake further investigation and/or deal with the concern under relevant processes. 

Record keeping 

All low-level concerns will be recorded in writing (form below). In addition to details of the concern raised, records will include the context in which the concern arose, any action taken and the rationale for decisions and action taken. 

Records will be: 

• Kept confidential, held securely and comply with the Data Protection Act 2018 and UK GDPR 
• Reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified. Where a pattern of such behaviour is identified, we will decide on a course of action, either through our disciplinary procedures or, where a pattern of behaviour moves from a concern to meeting the harms threshold as described in section 1 of this appendix, we will refer it to the designated officer at the local authority 
• Retained at least until the individual leaves employment at the school (on the rare occasions whereby concerns are had regarding an identified pattern of low level behaviour maybe a factor in an individual’s reason and intent on leaving their employment at the school, advice and guidance will be sought from the designated officer at the local authority). 

Where a low-level concern relates to a supply teacher or contractor, we will notify the individual’s employer, so any potential patterns of inappropriate behaviour can be identified. 

Reviewing a low-level concern 

Records will be reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified. 

Where a pattern of such behaviour is identified, the Headteacher will decide on a course of action, which may include;

• Disciplinary investigation and/or proceedings 
• Management Advice, including recommendations for training 
• Referral to the LADO (where a pattern of behaviour moves from a concern to meeting the harm threshold). 

If the concern relates volunteers, or any other concerns arise, the school can contact the LADO for further advice. 

References 

We will not include low-level concerns in references unless: 

• The concern (or group of concerns) has met the threshold for referral to the designated officer at the local authority and is found to be substantiated; and/or 
• The concern (or group of concerns) relates to issues which would ordinarily be included in a reference, such as misconduct or poor performance.

Appendix 1.

Low-Level Concern Form