Low Level Concern Policy

1. Introduction
At Wild Monkeys Childcare Ltd, we aim to create an open and transparent culture where all concerns about all adults involved with our settings are dealt with promptly and appropriately. We aim to identify any concerning, problematic or inappropriate behaviour early; minimise the risk of abuse; and ensure that adults working in or on behalf of our settings (including supply staff, volunteers and contractors) are clear about professional boundaries and act within these boundaries, and in accordance with our ethos.
This policy should be read alongside our Safeguarding and Child Protection and Staff Code of Conduct Policies.

2. 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. A member of staff who has a concern about another adult or who, on reflection, recognises that their actions could have been viewed as a risk should inform the Manager/DSL about their concern using a Low-Level Record of Concern Form.
If the Manager/DSL cannot be contacted, the Owner and Area Manager should be contacted instead.

3. Keeping Children Safe in Education September 2025
The following is taken from Keeping Children Safe in Education 2025 and identifies what may be considered behaviour relating to low level concern:
What is a low-level concern?
433. 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.

434. 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.

435. 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.
Allegation:

Any adult linked to our settings who has:

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.

436. 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.

4. Clarity around Allegation vs Low-Level Concern vs Appropriate Conduct
Allegation:
Any adult linked to our settings who has:

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.

436. 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 settings, schools and colleges from becoming the subject of potential false low-level concerns or misunderstandings.

4. Clarity around Allegation vs Low-Level Concern vs Appropriate Conduct

Allegation:
Any adult linked to our settings who has:

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.
Low Level Concern:
Any adult linked to our settings who has behaved 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.
Appropriate:

Behaviour which is entirely consistent with our Code of Conduct, and the Law.

5. Storing and use of Low-Level Concerns and follow-up information

LLC forms and follow-up information will be stored securely within Wild Monkeys Childcare Ltd.’s safeguarding systems, with access only by the leadership team. This will be stored in accordance with our 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 Manager/DSL or those aware in the senior leadership team (Owner and Area Manager).

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.

Whenever staff leave our employ, any record of low-level concerns which are stored about them will be reviewed as to whether or not that information needs to be kept.

Consideration will be given to:

(a) whether some or all of the information contained within any record may have any reasonably likely value in terms of any potential historic employment or abuse claim so as to justify keeping it, in line with normal safeguarding records practice; or

(b) if, on balance, any record is not considered to have any reasonably likely value, still less actionable concern, and ought to be deleted accordingly

6. Process to be followed when a low level concern is raised
N.B. Headteacher = manager/area manager/owner

7. Low level Concerns Reporting Form
Please use this form to share any concern– no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ – that an adult may have acted in a way that:
• is inconsistent with staff code of conduct, including inappropriate conduct outside of work, and
• does not meet the allegation threshold or is otherwise not serious enough to consider a referral to the LADO.

You should provide a concise record – including brief context in which the low-level concern arose, and details which are chronological, and as precise and accurate as possible – of any such concern and relevant incident(s). The record should be signed, timed, and dated.

Policy Last Reviewed: September 2025

Policy Review Date: September 2026

​POLICY DOCUMENTS

Low Level Concern Policy

POLICY DOCUMENTS