EX CATHEDRA | Low level concerns policy

Ex Cathedra Safeguarding

Introduction
Summary
What are Low-Level Concerns?
Storing and use of Low-Level Concerns and follow-up information
Process on reporting Low-Level Concerns
Key reference document
Low-level Concern Form

1. Introduction

Ex Cathedra is committed to the safeguarding and the care of children (up to age 18) and vulnerable adults for which it has responsibility and with which it comes in to contact as part of its work. Ex Cathedra recognises that all children, young people and vulnerable adults involved in its work have a right to be protected from harm.

Ex Cathedra will take every possible action to safeguard children and vulnerable adults, prevent abuse and deal with it, if it occurs, or any allegations, as promptly and effectively as possible. It will co-operate fully with any statutory agencies as required. This policy sets out the detail and processes for all in the Ex Cathedra staff and wider community, regarding low-level concerns they may have.

2. Summary

It may be possible that a member of Ex Cathedra acts in a way that does not cause risk to children or vulnerable adults, but is however inappropriate. Anyone who has a concern about another member of Ex Cathedra should inform the General Manager or Designated Safeguarding Lead (DSL) about their concern using a Low-Level Record of Concern Form. If the General Manager or DSL cannot be contacted, or if it is not appropriate to contact them, the Chair of Board of Trustees should be contacted instead.

3. What are Low-Level Concerns?

A low-level concern is any concern that an adult has acted in a way that:

is inconsistent with the staff code of conduct, including inappropriate conduct outside of work
doesn’t meet the threshold of harm or is not considered serious enough for the school or college to refer to the local authority.

Low-level concerns are part of a spectrum of behaviour. This includes:

inadvertent or thoughtless behaviour
behaviour that might be considered inappropriate depending on the circumstances
behaviour which is intended to enable abuse.

Examples of such behaviour could include:

being over friendly with children
having favourites
adults taking photographs of children on their mobile phone
engaging with a child on a one-to-one basis in a secluded area or behind a closed door
using inappropriate sexualised, intimidating or offensive language.

The following information helps us to distinguish between an allegation, a low-level concern and appropriate conduct:

Allegation

Behaviour which indicates that an adult who works with children/vulnerable adults has:

behaved in a way that has harmed a child/vulnerable adult, or may have harmed a child/vulnerable adult
possibly committed a criminal offence against or related to a child/vulnerable adult

behaved towards a child/vulnerable adult in a way that indicates they might pose a risk of harm

Low-Level Concern

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 Ex Cathedra’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.

Appropriate Conduct

Behaviour which is entirely consistent with Ex Cathedra’s Code of Conduct, and the law.

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

Low-Level Concerns forms and follow-up information will be stored securely within Ex Cathedra’s safeguarding systems, with access only by the Safeguarding and Management team. This will be stored in accordance with Ex Cathedra’s GDPR and data protection policies.

The person reporting the concern must keep the information confidential and not share the concern with others apart from the General Manager, DSL, DDSL or the named Board Member in this policy.

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 Ex Cathedra, 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.