Low Level Concerns Policy

Bright World Guardianships is committed to maintaining a strong safeguarding culture, which enables any concerns within the organisation to be identified and discussed.

Staff at Bright World are recruited in line with Safer Recruitment guidelines, receive safeguarding training and training on our professional code of conduct. All staff at Bright World are aware of the expectation of appropriate behaviour towards children and the need to report any concerning behaviour to senior members of staff, or if appropriate and/or the concerns relate to senior members of staff, concerns must be reported to the Local Authority.

This policy aims to outline what would be considered a “low-level concern” and the policy and procedure for dealing with a report. This policy also aims to empower all staff to report any concerns, no matter how small, in the interests of a robust safeguarding culture.

This policy has been written with reference to Farrer & Co’s Low Level Concern Guidance 2020.

What is a Low Level Concern

A low-level concern as described by Farrer & Co in the above guidance would constitute:

Any concern, no matter how small, even if no more than a “nagging doubt”, that an adult may have acted in a manner which:

• is not consistent with an organisation’s code of conduct and/or

• relates to their conduct outside of work which, even if not linked to a particular act or omission, has caused a sense of unease about that adult’s suitability to work with children.

Low level concerns are different to allegations against an adult who works with children. An allegation would constitute behaviour which has or may have harmed a child, possible crimes committed against or related to a child, behaviour towards a child or children which indicates that they may pose a risk of harm to children. However, it is not the responsibility of the person making the report to decide whether it is a low level concern or an allegation, that will be determined by the Designated Safeguarding Lead (DSL).

Concerns can be reported by any member of staff and should be reported immediately to the DSLs Robbie Piper or Lana Foster, or in their absence, the DDSLs James Foster or Su Warren. Reports can be made verbally or in writing. If the concern relates to Lana Foster, James Foster, Robbie Piper or Su Warren, the report can be made directly to the Local Authority.

If the reporter requests to remain anonymous, this will be respected where possible. However, it is not possible to make guarantees of anonymity.

Process for receiving a report of a low level concern:

• The DSL (or Deputy DSL) will receive the report in writing or verbally.
• If the report is made verbally, the DSL will write an account of the report as it is being given, or immediately afterwards.
• The written copy of the report will be kept securely in a password protected folder on Dropbox, or on our system IBOS on their password protected login, accessible only to Senior Management Team.
• If the report is not made anonymously, the DSL will speak to the person who reported the concern and review whether the concern breaches the Code of Conduct. The DSL will also determine whether it is a low level concern or should be escalated to the LADO and considered an allegation.
• If the DSL is not sure whether the report is a low level concern or an allegation, they should consult with the LADO.
• Once the DSL has determined the report is a low level concern, they should speak to the individual involved, make a record of all conversations, their decision about the incident, any action taken and rationale.
• If the DSL feels that the report does not constitute a low level concern they should still speak to the individual involved to let them know about the report and allow them to respond. The DSL should explain the decision, action and rationale to the person who reported the concern.
• If the DSL decides that the report does constitute a low level concern, they will then need to decide whether the issue is best resolved through a conversation, closer management or further training or a combination of all.
• The DSL should seek to speak to the individual involved in a calm and sensitive manner and avoid being critical or threatening.
• If the DSL considers that the issue also involves misconduct or poor performance, they should consult with HR and decide how best to proceed. Consultation with other external agencies may be necessary.
• If the concern, when taken in the context of a pattern of low-level concerns constitutes an allegation, a referral should be made to the LADO. If in doubt as to whether the pattern of concerns does meet the threshold for an allegation, the LADO should be consulted.

Once the low level concern has been evaluated, all notes will be kept in a secure folder in Dropbox for the duration of employment. When the employee leaves the company, the folder will be assessed again to see whether it is still necessary to retain the information.

Any concerns or allegations which have been proven to be false, unsubstantiated or malicious should not be included in references for future employment and Bright World remains mindful of its duty to provide accurate information.

We are committed to reviewing our policy and good practice annually.

This policy was last reviewed on: August 2023

Signed: Lana Foster, Managing Director, DSL