Low Level Concerns in Schools: What to Record and When to Escalate

A practical guide for headteachers, principals, proprietors, governors, trustees and designated safeguarding leads

Low level concern is one of the most misunderstood phrases in school safeguarding, and the misunderstanding is built into the name.

Low level doesn’t mean unimportant. It means the concern doesn’t meet the harm threshold that would trigger a referral to the local authority designated officer. Some of the most serious cases in recent years began as a series of low level concerns that were noticed by different people, never written down, and never joined up.

It’s understandable that staff hesitate. Writing something down about a colleague feels like an accusation, and in a small setting it may be a friend or somebody more senior. That hesitation is the thing the process has to overcome.

In this guide we’ll cover what counts, how to record it, who reviews it, and the point at which a pattern becomes an allegation. What happens once it does is in our guide to school investigations.

What Is a Low Level Concern in a School?

Any concern, no matter how small, and even if no more than a nagging doubt, that an adult working in or on behalf of the school may have acted in a way inconsistent with the staff code of conduct, including outside of work, and doesn’t meet the harm threshold.

Two parts of that definition do the work. No matter how small, which means the bar for recording is deliberately very low. And inconsistent with the staff code of conduct, which means your code is the reference point. If your code is vague, your staff can’t judge what to report.

Examples that typically fall here include being over friendly with a particular pupil, having favourites, taking photographs on a personal phone, engaging with a pupil on social media, using inappropriate humour, giving a lift home, or meeting a pupil alone without a clear reason.

None of those is necessarily misconduct. All of them are worth writing down.

Why Do Low Level Concerns Matter?

Because harm rarely announces itself.

A single instance of an adult giving a pupil a lift is explainable. The same adult also messaging that pupil, also finding reasons to be alone with them, also giving small gifts, is a pattern. Each individual member of staff may see only one of those things and think nothing of it.

The recording system exists so somebody can see all of them at once. Without it, the pattern stays invisible until something serious happens, at which point everybody remembers their piece of it and nobody had the whole.

That’s the whole argument for a process that otherwise feels disproportionate. It isn’t about the individual entry. It’s about being able to look across a hundred of them.

How Do You Build a Culture Where Staff Report?

This is harder than the process and it matters more.

Staff hesitate for predictable reasons. They don’t want to get a colleague into trouble, they aren’t sure it’s serious enough, they worry about being wrong, and in small settings they may be reporting somebody they’re close to or somebody senior to them.

Address those directly and repeatedly. Say explicitly that reporting a low level concern isn’t an accusation, that being wrong is expected and fine, and that the alternative is nobody seeing the pattern.

Include self reporting. A member of staff who realises they handled something badly should be able to say so, and a school that responds to self reporting punitively will never receive another one.

And name the route for concerns about the headteacher or proprietor, which mustn’t run through them. In small independent schools and alternative provision that frequently has no obvious answer unless somebody has deliberately created one. We cover it in investigations in independent special schools.

How Should Low Level Concerns Be Recorded?

In writing, centrally, and with enough detail to be useful later.

Record the date, the person reporting, what was seen or heard, the context, any action taken, the rationale for decisions, and the outcome. Keep the records securely, and keep them centrally rather than in individual personnel files, so patterns across different people and different times can actually be seen.

Two things schools get wrong.

Filing and forgetting. A recording system nobody reviews is a filing system. Set a rhythm, at least termly, and make it somebody’s named job.

Anonymising. The whole purpose is to be able to see that the same name recurs. An anonymous log tells you nothing.

Data protection applies. These records are personal data about a member of staff, must be held lawfully and securely, and shouldn’t be kept longer than necessary. Where concerns are unfounded, unsubstantiated, malicious or false, they shouldn’t be referred to in employer references. Check your retention policy covers them.

When Does a Low Level Concern Become an Allegation?

At one of two points.

Where a single concern turns out on closer examination to meet the harm threshold. Or where a pattern of low level concerns, taken together, indicates the person may pose a risk of harm to children or may not be suitable to work with them.

That second route is the one schools miss. Three separate concerns, each individually below the threshold, can collectively cross it. The judgement is about the pattern, not about the latest incident.

If you’re unsure, ring the LADO for a consultation. That call isn’t a referral, and it’s what the service is there for. The sequence that follows is set out in the LADO process explained.

Where Do Low Level Concerns Overlap With Conduct?

More often than people expect, and being clear about which you’re in protects everybody.

A recorded concern may lead to a supportive conversation, additional training, closer supervision, or a change of practice. It may also, where the behaviour is serious enough or repeated, become a conduct matter with a formal process attached.

What isn’t fair, and won’t survive scrutiny, is a conversation described as informal support that later appears in a disciplinary case. If you’re moving from one to the other, say so, and follow the process properly from that point. We cover it in HR investigations in schools.

What If Our Low Level Concerns Log Is Empty?

Treat it as a question rather than as reassurance.

An empty log almost always means one of two things. Staff don’t know what to report, which is a training and code of conduct problem. Or they don’t feel able to, which is a culture problem and a more serious one.

Ask a few staff, individually, what they’d do if they saw a colleague behaving in a way that bothered them slightly. The answers tell you which of those you have. A Section 175 and 157 safeguarding audit tests exactly this, and it’s the sort of thing that’s very hard to see honestly from inside.

From Our Experience

Many schools tell us their low level concerns log is empty and offer it as evidence that nothing is wrong. It’s an understandable reading and it’s almost never what an empty log means.

We often see logs that exist and have never been reviewed, which is the worst of both positions. The school holds a record of concerns and can’t demonstrate that anybody looked at them together, which is a harder thing to explain than having no log at all.

The other pattern is the code of conduct written at such a level of generality that nobody could measure anything against it. Staff can’t report a departure from a standard that was never described.

Schools with a healthy culture here usually record more than they need to, review regularly, and treat most entries as nothing. That’s the system working, not the system being overused.

A Common Misconception

“Writing it down is unfair to a member of staff who has done nothing wrong.”

It’s a decent instinct and it gets the effect backwards.

Recording isn’t an accusation and it isn’t a sanction. Most entries lead nowhere and should lead nowhere.

The alternative is worse for staff as well as for children. Without a record, a concern raised informally circulates as rumour, with no process attached and no opportunity for the person to be cleared. A recorded concern that was reviewed and found to be nothing protects the individual in a way that gossip never will.

And for the children, the case is straightforward. The entries that turn out to matter are indistinguishable from the ones that don’t at the moment they’re written. That’s why you write them all down.

Questions for Leaders and Governors

• Is our staff code of conduct specific enough to judge behaviour against?
• Do staff know what a low level concern is, and could they give an example?
• Where are records kept, and can we see patterns across individuals?
• Who reviews the log, and when did they last do it?
• Could a member of staff report a concern about the headteacher or proprietor?
• If our log is empty, do we know why?

Our Perspective

The low level concerns process exists because serious harm is usually preceded by smaller things somebody noticed and nobody recorded.

It asks staff to write down things that are probably nothing, which feels uncomfortable and slightly disloyal. That discomfort is the price of being able to see a pattern before it becomes a case.

Every school’s circumstances are different, and what we’d encourage is to judge the system by whether people use it rather than by how tidy it looks. A busy log reviewed properly is a school where adults are paying attention, and the children in it are safer for that whether or not anything is ever found.