Responding to low-level concerns about staff or volunteers

Low-level concerns policies and procedures

Having clear guidance on responding to low-level concerns about an adult’s behaviour is part of creating a culture of openness and trust. It helps ensure that adults consistently model your organisation’s values and helps keep children safe. It also protects adults working with children from potential false allegations or misunderstandings.

Your organisation should include a policy and procedures on responding to low-level concerns as part of either its safeguarding and child protection policies or its code of conduct for staff and volunteers.

Guidance for schools in England ¹states that, as good practice, schools should set out their low-level concerns policy and procedures within their staff code of conduct and safeguarding and child protection policies. 

> Read about writing safeguarding policies and procedures

> Find out more about codes of conduct

The policy and procedures should set out:

• what constitutes appropriate and inappropriate behaviour for your staff and volunteers
• what a low-level concern is
• the importance of sharing low-level concerns
• how to report any concerns
• who to report concerns to
• the process for recording, reviewing and responding to concerns.

All staff and volunteers should be aware of, read and understand your low-level concerns policy and procedures. Reading the policy and procedures should be part of your induction processes and training.

> Get in touch with NSPCC Consultancy for expert advice and guidance on policies and procedures, induction and training

Responding to low-level concerns

Reporting concerns

Organisations should work to create a culture in which everyone feels confident to report low-level concerns about an adult’s behaviour. This should include encouraging staff to self-report situations which could be misinterpreted or behaviour which does not meet the organisation’s code of conduct.¹

The low-level concerns policy and procedures should set out who you report concerns to. All staff and volunteers should know who the nominated person is and how to contact them. If there is a concern about the nominated person it should be reported to their deputy or another senior manager.

Concerns should be reported as soon as possible, within 24 hours of you becoming aware of them.

If your nominated person is in any doubt about whether the concern meets the harm threshold they should seek advice from statutory child protection agencies, such as the police or local child protection services, or contact the NSPCC Helpline.

In England, the nominated person should speak to the local authority’s designated officer (sometimes called the LADO or DOLA) who manages allegations against people who work with children.

Recording concerns

All low-level concerns about an adult’s behaviour should be recorded in writing. The record should include:

• details of the concern
• the context in which the concern arose
• action taken.

The name of the person reporting the concern should also be recorded unless they wish to remain anonymous.

The records should be kept somewhere secure and confidential, and in compliance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).²

Recording concerns helps you to identify any potential patterns of behaviour that may need to be discussed with the local authority’s designated officer. Keeping records can also help to inform future training, induction programmes or policy reviews within your organisation.

It’s good practice to keep a record of concerns at least until the person involved leaves your employment.

> Find out more about child protection records and retention

Reviewing concerns

All low-level concerns about an adult’s behaviour should be reviewed by your designated safeguarding lead, nominated child protection lead or, in the case of schools in England, headteacher.³

The person leading the review should speak to all adults involved in the incident, including any witnesses, unless advised not to by any other statutory agencies involved.

The review should consider the level of concern, taking into account any patterns of inappropriate behaviour.

A decision should then be taken on whether any disciplinary or safeguarding action is required. This should be recorded in writing, along with an explanation of why this decision was made.

> Find out more about managing allegations of abuse

Patterns of low-level concerns should also prompt discussions around the current culture of your organisation, and whether anything needs to change. This might include revising current policies, delivering extra training or reviewing your approach to staff induction.

> Use our safeguarding self-assessment tool to identify areas for development

> Get tailored advice from our consultancy service

Guidance and resources

Guidance on low level concerns

In England, specific national guidance on reporting low level concerns about an adult’s behaviour is included in Keeping children safe in education (KCSIE) guidance for schools.¹

> Read our summary of the Keeping children safe in education guidance

The law firm Farrer and Co have published guidance for all organisations who work with children on developing and implementing a low-level concerns policy (PDF),² based on the principles set out in KCSIE.

Resources to support positive behaviour

NSPCC Learning has a range of resources to help support positive behaviour in your organisation.

Our information on behaviour management includes an example behaviour code for adults working with children.

We’ve set out the safeguarding measures you need to consider when working on your own with children.

Our guidance also sets out best practice on managing allegations against people who work or volunteer with children.

Getting advice

The NSPCC Helpline can help when you're not sure if a situation needs a safeguarding response. Our child protection specialists are here to support you whether you're seeking advice, sharing concerns about a child or looking for reassurance.

Whatever the need, reason or feeling, you can contact the NSPCC Helpline on 0808 800 5000 or by emailing help@nspcc.org.uk.

Our trained professionals will talk through your concerns with you. Depending on what you share, our experts will talk you through which local services can help, advise you on next steps or make referrals to children's services and the police.

> Find out more about how the NSPCC Helpline can support you