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A culture in safeguarding
  • Safeguarding

This blog has been written by The Safeguarding Alliance.

Recently Emily Konstantas, CEO, explained why The Safeguarding Alliance refer to safeguarding as analogous to a tree - The Tree of safeguardingand not an umbrella.

You cannot plant a sapling or a seed of a tree and expect it to grow just because you have planted it. The environment has to be right, for example, an oak tree will not grow in the desert and a palm tree will not grow in a cold, damp forest. The same principle applies to safeguarding. You cannot take a 'UK' seed of safeguarding, plant it internationally, and expect it to grow unaided as the conditions will not support it. Safeguarding must remain not only contextual but culturally contextual.

The average tree takes 20 years to mature and will not grow from a seed to a mighty tree overnight. This same principle applies to safeguarding. Embedding a culture in safeguarding takes time. It is unreasonable to think that tomorrow you will sit in the shade of a tree you planted today, but generations to come, will.

Just like the growth of a tree, safeguarding will not always be a smooth journey. With every storm a tree will embed its roots deeper making it stronger and better prepared for future storms. Safeguarding must do the same.

This article will focus on one branch of the ‘Tree of Safeguarding’ – developing a culture around managing ‘low-level’ concerns in international schools.    

Managing a Concern or Allegation

The reason we have chosen to discuss this branch is that we have found there is often a disparity in the level of awareness between schools on how to manage the ongoing suitability of adults to work with children, post the initial safer recruitment process. We have identified that some international schools may not have a policy or procedure supporting the process of reporting, recording, and managing concerns or allegations, especially when related to ‘low-level’ concerns. 

When managing allegations there are two levels of concerns and allegations to consider:

1.     Concerns / allegations that may meet the harm threshold.

2.     Concerns / allegations that do not meet the harm threshold – referred to as ‘low-level concerns.’

The harm test is set out by the UK Disclosure and Barring Service and states that: “A person satisfies the harm test if they may harm a child or vulnerable adult or put them at risk of harm. It is something a person may do to cause harm or pose a risk of harm to a child or vulnerable adult” and has also been referred to in Section 31(9) of the Children Act 2002.

Keeping Children Safe in Education 2023, states that a person may have met the harm threshold if they have:

•        behaved in a way that has harmed a child, or may have harmed a child and/or

•        possibly committed a criminal offence against or related to a child, and/or

•        behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children, and/or

•        behaved or may have behaved in a way that indicates they may not be suitable to work with children.

This article specifically focuses on the importance of embedding a culture around managing ‘low-level’ concerns.

So, what is a ‘low-level’ concern and why do we need to monitor them? A ‘low-level’ concern relates to a concern or allegation that does not meet the harm threshold as defined above, but this does not make the concern any less significant.

Examples of ‘low-level’ concerns may 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. 

The Safeguarding Alliance argue that the term ‘low-level’ concern is creating confusion and could undermine the importance of reporting them appropriately.

Any concern or allegation against an adult working in the school, whether academic, operational, contractor, support or volunteer must be dealt with promptly and effectively; yet on many occasions there remains a lack of understanding around what action to take when faced with a ‘low-level’ concern or allegation.

For example, The Safeguarding Alliance have identified that a significant number of international schools do not appear to maintain ‘low-level’ concerns log or have a clear managing allegations policy around whose responsibility it is to monitor and action such concerns when and if they arise.

So how do staff report a ‘low-level concern’, who records them and who should maintain the log? Below, The Safeguarding Alliance has provided some key pointers when considering drafting a ‘low-level’ concerns policy:

Reporting or Neutral Notification

It is important that there is clarity around how and who to report a ‘low-level’ concern to. As an international school you should have a ‘low-level’ concerns form staff can use to report or neutrally notify. This is like a child protection concerns form but relates to a ‘low-level’ concern relating to an adult.   

In an international context it is important to consider how contracted school staff such as security guards, cleaners, catering staff, and bus nannies will report their concerns. How will you communicate to staff when English may not be their first language, what a ‘low-level’ concern is and how and to whom to report to?

If a concern does arise relating to an external contractor, consider how you will report this to their employer and what action should be taken.


Some staff may be reluctant to report a genuine low-level concern about a colleague for fear of being judged, looking foolish, being ostracised, or possibly losing their job. Staff may also be anxious about the colleague or other staff members finding out, leading to reprisals. Having an open discussion about this and explaining that anyone who speaks out will be supported and protected, should help to reassure staff and create an open and honest culture.

Safeguarding is everyone’s responsibility, and it is important that all staff are empowered to report any concern they may have. 

When a ‘low-level’ concern is reported it is imperative there is clarity around roles and responsibilities. A concern or allegation could be referred to the Designated Safeguarding Lead, but ultimately, the Headteacher and/or Proprietor of a school will be the decision maker. 

The Safeguarding Alliance are pleased to share with you a Reporting Concerns Flow Chart which you may wish to adapt to your school requirements.


The headteacher should maintain up-to-date written low-level concerns log or record. The concerns could be categorised in relation to the type of:

•        behaviour,

•        concern, or

•        allegation,

and should contain guidance to determine what further action may need to be taken.

The record should include, but should not be limited to:

•        details of the concern.

•        the context in which the concern arose, and action(s) taken.

•        The name of the individual sharing their concerns (if the individual wishes to remain anonymous, then that should be respected as far as reasonably possible).

The Safeguarding Alliance has a range of resources around managing allegations, including a low-level concerns log template in the members area.

As a headteacher or proprietor it is important to review the log regularly so that potential patterns of concerning, problematic or inappropriate behaviour can be identified.

When monitoring the log, if a pattern is identified, consideration should be given as to whether there are broader cultural issues within the school which enabled the behaviour to occur. If this is identified, the headteacher or should consider what can be done to minimise the risk of it happening again.


Keeping Children Safe in Education 2023[1] states: “schools and colleges should only provide substantiated safeguarding concerns/allegations (including a group of low-level concerns about the same individual) that meet the harm threshold in references. Low-level concerns should not be included in references unless they relate to issues which would normally be included in a reference, for example, misconduct or poor performance. It follows that a low-level concern which relates exclusively to safeguarding (and not to misconduct or poor performance) should not be referred to in a reference”.

It is important therefore to continuously monitor the log to ensure that a ‘low-level’ concern has not met the harm threshold which would require the school to take separate action dependent on the circumstances.     


In addition to a policy, school leaders should consider who, within the school, will be trained to manage such allegations and conduct a safeguarding enquiry if required to do so.

Top Tips

To summarise we have provided you with our 5-Top-Tips when embedding a culture around managing ‘low-level’ concerns:   

1.     Implement a low-level concern reporting procedure and include it in the relevant policy.

2.     Create a one-page overview flowchart to summarise the procedure.

3.     Implement a neutral notification/self-refer process for staff.

4.     Deliver training to staff on low-level concerns, concerns which meet the harm threshold and ‘whistleblowing’ (reporting wrongdoing).

5.     Develop a monitoring process of low-level concerns to identify trends over time.

[1] Para 442