Low Level Concerns Policy

This School is committed to safeguarding and promoting the welfare of children and young people and expects all staff and volunteers to share this commitment.

Various relevant documents were taken into consideration during the drafting of this policy including: Keeping Children Safe in Education September (2023).

The Surrey LADO can be contacted on 0300 123 1650 or lado@surreycc.gov.uk

If issues relate to a young person: Refer to Designated Safeguarding Lead or SPA on 0300 470 9100 or cspa@surreycc.gov.uk .

During evenings, weekends and bank holidays, the Emergency Duty Team is available: Phone: 01483 51789 Email: edt.ssd@surreycc.gov.uk

Date CreatedDate 1st Review DueDate ReviewedVersionNext Review Due
March 2023March 2024
September 20232September 2024

Introduction

Egham Park School takes the statutory and moral duty to safeguard and promote the welfare of pupils very seriously and understands that staff play a vital role in meeting these responsibilities. Egham Park School works to ensure that we promote an open and transparent culture in which all concerns about adults working in or on behalf of the school are dealt with promptly and appropriately. This policy applies to all staff, volunteers, and visitors.

This policy aims to:

  • help create a culture in which all concerns about adults are shared responsibly and with the right person and are recorded and dealt with appropriately.
  • enable schools to identify concerning or inappropriate behaviour early.
  • minimise the risk of abuse occurring.
  • 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 school.
  • help create an environment where staff are comfortable to self-refer, where, for example, they have found themselves in a situation which could be misinterpreted, might appear compromising to others, and/or on reflection they believe they have behaved in such a way that they consider falls below the expected professional standards.

Definition

The term ‘low level’ concern does not mean that it is insignificant. It means that the behaviour towards a child does not meet the harm threshold for an allegation. ‘Keeping Children Safe in Education’ defines a low-level concern as “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 allegations threshold or is otherwise not considered serious enough to
    consider a referral to the LADO”

Avoiding Low Level Behaviour

Behaviour defined as a ‘low level concern’ can exist on a spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate but is not in specific circumstances, through to that which is ultimately intended to enable abuse. Staff education and reinforcement on avoiding circumstances which may put them in a difficult situation is key to avoiding the need for dealing with these types of concerns. Our school ensures that staff are clear about what appropriate behaviour is through their induction and regularly reinforcement of documents such as:

  • Staff Code of Conduct and Employee Handbook
  • Child Protection and Safeguarding Policy

Reporting a Low-Level Concern

Low level concerns about a member of staff, volunteer or visitor should be reported to the DSL and/or Principal. If the concern is about the Head of Centre this should be reported to the Principal (or the Advisory Board if the concern is about the Principal).

Low level concerns which are shared about staff, contractors, or staff at outside organisations, should be notified to their employers, so that any potential patterns of inappropriate behaviour can be identified. If the school is in any doubt as to whether the information has been shared about a member of staff as a low level concern in fact meets the harm threshold, they should consult with their LADO (Local Authority Designated Officer).

Dealing with a Low-Level Concern

Where a concern is raised about the practice or behaviour of a member of staff, this information must be recorded and passed to the Head of Centre and Principal. The Head of Centre and/or Principal must then make an assessment to determine if the matter is a ‘low level concern’ or an ‘allegation’ and follow one of the following routes.

Allegations that meet the harm threshold will be referred to the LADO for advice. Low level concerns that the Head of Centre or Principal feels may need further guidance on will be referred to the LADO for advice. Low level concerns that the Head of Centre or Principal feels can be dealt with internally will be dealt with via the school’s usual child protection investigation process.

Egham Park School will engage with its HR advisor where it is necessary to undertake further investigation and/or deal with the concern under relevant processes.

Recording a Low-Level Concern

All low-level concerns should be formally recorded by a member of staff when they are made aware of them. This record should then be passed to the Head of Centre/Principal (or Principal if the concern is about the Head of Centre).

The record should include details of the concern, the context in which the concern arose, details of the investigation and any action taken, and the name of the individual sharing their concerns (if known) (unless the individual wishes to remain anonymous which must be respected as far as possible).

Relevant records will be retained confidentially on the personnel file. A separate record will also be kept of low-level concerns to more easily identify patterns that may involve more than one member of staff. All records must be kept in line with data protection principles.

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 Head of Centre and or Principal 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).

Egham Park School will take advice, where appropriate, from their HR advisor in respect of low-level concerns. The school will also review appropriate policies and training, or other wider cultural issues in the school, to see whether anything needs to be done to minimise the risk of similar behaviour happening again. Relevant records will be retained confidentially on the personnel file. A separate record will also be kept of low-level concerns to more easily identify patterns that may involve more than one member of staff. All records must be kept in line with data protection principles.

Low level concerns will not be included in a reference unless they relate to issues which would normally be included in a reference (e.g. misconduct or poor performance).

A low-level concern (or group or pattern of concerns) which has met the harm threshold and has therefore been referred to the LADO may be included in a reference depending on the circumstances.