Low-Level Concerns Policy

Policy Statement

Skywise Educational Guardianship UK Ltd is committed to maintaining the highest standards of professional behaviour and conduct. We aim to create a culture of openness, transparency, and trust in which all adults working with or on behalf of children understand the importance of recognising and reporting any low-level concerns.

A low-level concern is any behaviour by an adult that does not meet the threshold for a safeguarding allegation but may still be inconsistent with the organisation’s Code of Conduct and safeguarding expectations. All concerns, regardless of how minor they may seem, should be shared and acted upon appropriately to protect the welfare of children and the integrity of the adults who support them.

This policy is underpinned by Part Four, Section Two of Keeping Children Safe in Education (2024) and AEGIS guidance (Standard 6.5). It applies to all staff, volunteers, homestays, and contractors engaged by Skywise Educational Guardianship UK Ltd.

What Is a Low-Level Concern?

A low-level concern is any concern, no matter how small, that an adult working in or on behalf of Skywise Educational Guardianship UK Ltd may have acted in a way that is inconsistent with the organisation’s Code of Conduct, either in their professional or personal life.

This includes behaviour that may:

●      Be perceived as overly familiar or inappropriate

●      Involve unnecessary physical contact

●      Include comments or humour that could be viewed as suggestive or offensive

●      Take place in a private or unsupervised space without good reason

●      Breach professional boundaries, online or in person

Examples of low-level concerns might include being overly friendly with a student, favouritism, taking personal photographs of students, or using inappropriate language or tone.

Importance of Reporting

Reporting low-level concerns allows the organisation to identify and respond to potential patterns of behaviour and intervene before any harm occurs. It also supports a culture of continuous safeguarding awareness and provides protection for both students and staff by reducing the risk of misunderstandings or false allegations.

Skywise Educational Guardianship UK Ltd promotes a “telling culture” where all concerns, including those about one’s own conduct, are shared without fear of retribution. Self-reporting is encouraged and viewed as a demonstration of honesty, self-awareness, and commitment to safeguarding.

How to Report a Low-Level Concern

All concerns should be reported to the Designated Safeguarding Lead (DSL) as soon as possible, ideally within 24 hours of the incident or concern arising. Reports can be made verbally or in writing and will be handled in confidence.

The DSL will assess whether the concern meets the threshold for a safeguarding allegation. If not, it will be treated as a low-level concern and handled through the organisation’s internal procedures. If in doubt, advice may be sought from the Local Authority Designated Officer (LADO) on a no-names basis.

Responding to a Low-Level Concern

The DSL will speak with the person who raised the concern and, where appropriate, the individual about whom the concern has been raised. Other individuals may be interviewed if necessary. Each concern will be considered on its own merits, and a proportionate response will be taken.

This may include offering management advice, providing additional training, or initiating reflective supervision. If multiple low-level concerns are raised about the same individual, these will be reviewed collectively to determine if a pattern of behaviour exists which may meet the threshold for a safeguarding referral.

Recording and Confidentiality

All low-level concerns will be recorded in writing and stored securely in a central safeguarding file. The record will include:

●      A summary of the concern

●      The context in which it arose

●      Action taken, including any advice or training provided

●      The rationale for decision-making

Where the individual wishes to remain anonymous, this will be respected where reasonably possible. Records will not be kept on an individual’s personnel file unless the concern leads to formal disciplinary action or meets the threshold for a safeguarding allegation.

Records will be retained in line with the organisation’s Data Protection and Safeguarding Policies and will comply with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.

Code of Conduct and Expectations

All staff and homestays must behave responsibly and professionally in all interactions with students, and particularly with those for whom they hold a duty of care. Every member of staff and all homestay providers are expected to follow the procedures and principles set out in the Skywise Staff and Homestay Code of Conduct.

Staff and homestays should always avoid conduct that could be misinterpreted by others. Due to their knowledge, experience, position, or the authority associated with their role, all adults working with children and young people are considered to hold positions of trust. A relationship between a member of staff or a homestay and a student cannot be viewed as one between equals. There is an inherent risk of exploitation or harm, especially for vulnerable young people. Therefore, all staff and homestays must be mindful not to use their position of trust for personal gain, gratification, or inappropriate influence.

It is important to note that under UK law, it is a criminal offence for a person aged 18 or over, in a position of trust, to touch a child in a sexual way or to engage in a sexual relationship with a child, even where the relationship appears to be consensual. A position of trust may be deemed to exist even if the individual does not work directly with the child.

All staff and homestays have a collective and individual responsibility to act with integrity, uphold safeguarding standards, and maintain professional boundaries at all times. Breaches of the Code of Conduct, however minor they may appear, should be addressed through appropriate procedures to prevent escalation and ensure the safety and wellbeing of all students.

Further Information

For more detailed guidance on low-level concerns, staff are advised to refer to the following resources:

●      Keeping Children Safe in Education (2024) – Part Four, Section Two
https://www.gov.uk/government/publications/keeping-children-safe-in-education

●      NSPCC Low-Level Concerns Overview
https://learning.nspcc.org.uk/research-resources/briefings/low-level-concerns

●      AEGIS Safeguarding Standards (Standard 6.5)
https://aegisuk.net/inspection/standards

Contact Information

Designated Safeguarding Lead (DSL)
Ms Zhiying Zheng
Phone: 07792 766329
Email: tina.zheng@skywisegroup.com

Review

This policy will be reviewed annually or sooner if guidance changes or there is a safeguarding incident involving a low-level concern.

Last reviewed: 22 March 2025 by Mrs Katherine Lee
Next review due: 22 March 2026