Low Level Concerns Policy

Introduction

Safeguarding is of paramount importance at Golborne and Maxilla Nursery School. This includes ensuring that our staff who work with children do so in way which is in line with the school’s ethos and culture and matches what is outlined in our staff code of conduct. This policy outlines the systems Golborne and Maxilla has in place for managing low level concerns related to staff in school.

Summary

It may be possible that a member of staff acts in a way that does not cause risk to children, but is however inappropriate and not in accordance with the school’s ethos, culture and code of conduct. A member of staff who has a concern about another member of staff should inform the Designated Safeguarding Lead (DSL) or Deputy-DSL in the DSL’s absence in accordance with the school’s Safeguarding & Children Protection Policy and protocols.

Keeping Children Safe in Education 2022

The following is taken from keeping Children Safe in Education 2022.

424. As part of their whole school approach to safeguarding, Golborne and Maxilla ensures and promotes an open and transparent culture in which all concerns about all adults working in or on behalf of the school (including supply teachers, volunteers and contractors) are dealt with promptly and appropriately.
425. Creating a culture in which all concerns about adults are shared responsibly and with the right person, recorded and dealt with appropriately, is critical. If implemented correctly, this should enable the school to identify inappropriate, problematic or concerning behaviour early, minimise the risk of abuse, and ensure that adults working in or on behalf of the school are clear about professional boundaries and act within these boundaries, and in accordance with the ethos and values of the institution.

What is a low level concern?

426. The term ‘low-level’ concern does not mean that it is insignificant. A low-level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ – that an adult working in or on behalf of the school or college 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 harm threshold or is otherwise not serious enough to consider a referral to the LADO.

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

• being over friendly with children
• having favourites
• taking photographs of children on their mobile phone, contrary to school policy
• engaging with a child on a one-to-one basis in a secluded area or behind a closed door, or
• humiliating children.

427. Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate, but might not be in specific circumstances, through to that which is ultimately intended to enable abuse.
428. Low-level concerns may arise in several ways and from a number of sources. For example: suspicion; complaint; or disclosure made by a child, parent or other adult within or outside of the organisation; or as a result of vetting checks undertaken.
429. It is crucial that all low-level concerns are shared responsibly with the right person and recorded and dealt with appropriately. Ensuring they are dealt with effectively should also protect those working in or on behalf of schools and colleges from becoming the subject of potential false low-level concerns or misunderstandings.

Clarity around allegation vs. low level concerns vs appropriate conduct

Allegation

Behaviour which indicates an adult who works with children has:

• behaved in a way that has harmed a child, or may have harmed a child
• possibly committed a criminal offence against or related to a child
• behaved towards a child or children in a way that indicates they may pose a risk of harm to children

Low level concern

Any concern – no matter how small, even if no more than a ‘nagging doubt’- that an adult may have acted in manner which:

• it is not consistent with our school Code of Conduct, and/or;
• relates to their conduct outside of work which, even if not linked to a particular act or omission, has caused a sense of unease about that adult’s suitability to work with children

Appropriate Conduct

Behaviour which is entirely consistent with Golborne and Maxilla’s Code of Conduct and the law.

Storing and use of low level concerns and follow up

All reporting of low level concerns and follow up information will be stored securely within the school’s safeguarding systems, CPOMs, with access only by DSLs. This will be stored in accordance with the school’s GDPR and data protection policies.

The staff member(s) reporting the concern must keep the information confidential and not share the concern with others apart from the Head Teacher or those aware in the senior leadership team.

Low level concerns will not be referred to in references unless they have been formalised into more significant concerns resulting in disciplinary or misconduct procedures.

Links with other policies

This policy links with our policies on:

• Safeguarding & Child Protection
• E-Safety
• Staff Code of Conduct
• Complaints & Whistleblowing

Approved and adopted by the Governing Body October 2022