A low-level concern in a school is any concern, however small, that an adult working in or on behalf of the school may have acted in a way that is inconsistent with the staff code of conduct, including outside work, but that does not meet the harm threshold for an allegation or is not serious enough to refer to the local authority designated officer (LADO). Keeping Children Safe in Education (KCSIE) 2026 says even a “nagging doubt” counts. Examples include being overfriendly with children, having favourites and taking photographs of children on their mobile phone, contrary to school policy.
At a glance: Nexis CPD offers a £9 CPD-accredited online Designated Safeguarding Lead (Children) course — 100% online, with an instantly emailed, employer-verifiable certificate. Any three courses cost £18, and teams of 5 or more pay £6 a course place.
General information, not legal advice — if a child is in immediate danger, call 999. If you think a colleague has harmed a child, that is an allegation: tell your headteacher or principal straight away. Always follow your setting’s policies and your local safeguarding partnership’s procedures. This guide covers England.
What is a low-level concern in a school?
Keeping Children Safe in Education 2026, the statutory guidance schools and colleges in England must have regard to, deals with low-level concerns in Part four, Section two, “Concerns or allegations that do not meet the harm threshold” (paragraphs 506 to 528). It was paragraphs 427 to 449 in 2025, with almost identical wording.
Paragraph 509 defines it:
“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.”
Three parts of that definition matter in practice:
- “Any concern”. You do not need evidence or certainty.
- “An adult working in or on behalf of the school”. This covers teachers, support staff, supply staff, volunteers and contractors. The 2026 edition also names trainee teachers throughout Part four.
- “Including inappropriate conduct outside of work”. Behaviour online or in the community counts.
The same paragraph opens with a warning: “The term ‘low-level’ concern does not mean that it is insignificant.” Paragraph 510 explains why. Such behaviour sits on a wide spectrum, “from the inadvertent or thoughtless”, through behaviour that looks inappropriate but might not be in the circumstances, “through to that which is ultimately intended to enable abuse”.
Paragraph 511 says concerns can come from suspicion, a complaint, a disclosure by a child, parent or other adult, or vetting checks.
Why do schools need a low-level concerns policy?
Paragraph 506 says governing bodies and proprietors “should have policies and processes” for concerns that do not meet the harm threshold. The point is culture. Paragraph 507 asks schools to “promote an open and transparent culture” in which all concerns about all adults “are dealt with promptly and appropriately”, and paragraph 508 says that, done well, this should:
- help schools “identify inappropriate, problematic or concerning behaviour early”,
- “minimise the risk of abuse”, and
- make sure adults are “clear about professional boundaries and act within these boundaries”.
That matters for two reasons. First, grooming rarely starts with an obvious act. It starts with small boundary crossings: special attention, gifts, private messages, time alone. Each looks harmless on its own; recorded together, they can show a pattern that no single incident would.
Second, the framework protects staff. Paragraph 512 says dealing with concerns 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”. A concern that is shared and resolved is better for everyone than an untested staffroom rumour.
What are examples of low-level concerns?
KCSIE 2026 paragraph 509 gives five examples, and says the list is not exhaustive:
- “being overfriendly 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.”
You may see older policies and training materials that list “using inappropriate sexualised, intimidating or offensive language” as an example. That is not in the KCSIE 2026 list, which uses “humiliating children” instead, so check your policy is quoting the current edition.
The table below gives illustrative examples of how schools commonly categorise situations. It is not taken from KCSIE, and context always matters: the same behaviour can be thoughtless once and worrying when repeated.
| Situation | Usually treated as | Why |
|---|---|---|
| A teacher repeatedly gives one pupil treats and extra attention | Low-level concern | “Having favourites” is a KCSIE example |
| A coach photographs pupils at a fixture on his own phone, against policy | Low-level concern | KCSIE example; may be innocent but breaks the code of conduct |
| A member of staff often meets a pupil alone in an empty room with the door shut | Low-level concern, at least | KCSIE example; look for other signs |
| A teacher mocks a pupil in front of the class | Low-level concern | “Humiliating children” is a KCSIE example |
| A member of staff messages a pupil privately on social media and asks to meet | May meet the harm threshold | Could indicate they may not be suitable to work with children; tell the headteacher now |
| A pupil says a member of staff hurt or touched them | Allegation | Harm, or possible harm, to a child; Part four, Section one applies |
| A teacher is often late handing in reports | Not a safeguarding concern | A performance matter for line management |
If you are unsure which column something belongs in, share it. Categorising it is not your job.
What is the difference between a low-level concern and an allegation?
The dividing line is the harm threshold, set out in Part four, Section one. Paragraph 437 says that section applies where it is alleged that anyone working in the school, including supply teachers, volunteers and contractors, has:
- “behaved in a way that has harmed a child, or may have harmed a child”,
- “possibly committed a criminal offence against or related to a child”,
- “behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children”, or
- “behaved or may have behaved in a way that indicates they may not be suitable to work with children”.
Paragraph 438 adds that this includes behaviour outside school, known as “transferable risk”.
If a concern meets any of those tests, it is an allegation. Paragraph 78 says it should go to the headteacher or principal, “who will consider whether an onward referral to the LADO is required”. If it does not, paragraph 79 says it “should be shared in accordance with the school or college’s low-level concerns policy”. Where the school is unsure, paragraph 518 is clear: “they should consult with their LADO”.
For the difference between a staff concern and a concern about how one child treats another, see our guide to child-on-child abuse.
What should staff do if they have a low-level concern?
Every member of staff should know the answer, because Part one of KCSIE, which all staff read, says at paragraph 11 that the staff behaviour policy “should amongst other things, include low-level concerns, allegations against staff and whistleblowing”. In practice:
- Share it promptly, with the right person. Paragraph 516 leaves it to each school to decide whether concerns go first to the designated safeguarding lead (DSL), “a nominated person such as a values champion”, or the headteacher or principal. Your policy will say which.
- Write down what you saw or heard. Date, time, place, who was there and what happened, in factual terms.
- Do not investigate. Questioning people is for the headteacher or their nominated deputy.
- Keep it confidential. Paragraph 516 asks for a procedure for “sharing confidentially such concerns”.
- Do not wait for a pattern. You will rarely know whether others have raised something similar.
What if the concern is about the headteacher? For concerns or allegations that may meet the harm threshold, paragraph 78 says a concern about the headteacher or principal “should be referred to the chair of governors, chair of the management committee or proprietor of an independent school”. Where the headteacher is also the sole proprietor, or there is a conflict of interest, it should go “directly to the LADO”. KCSIE’s low-level concerns section does not spell out who receives a low-level concern about the headteacher, so your policy should. Most follow the same route as paragraph 78.
Can I stay anonymous? Paragraph 520 says the name of the person sharing a concern should be noted, but “if the individual wishes to remain anonymous then that should be respected as far as reasonably possible”.
The Safeguarding Children (Advanced) Level 2 course covers recognising concerns, responding and recording for the wider staff team.
Can staff self-report a low-level concern?
Yes, and KCSIE wants them to. Paragraph 519 says schools should create an environment where staff “feel confident to self-refer”, for example where they have “found themselves in a situation which could be misinterpreted, might appear compromising to others”, or on reflection believe they have fallen below expected professional standards.
Typical self-reports include an unexpected friend request from a pupil, a lift home given in an emergency, or a moment of lost temper in class. Recording it early protects the member of staff if the situation is later described differently. A school that treats self-reports as disciplinary admissions will soon stop receiving them.
What does the headteacher or DSL do with a low-level concern?
Paragraph 516 makes the headteacher or principal “the ultimate decision maker in respect of all low-level concerns”. If concerns go first to the DSL, the DSL “should inform the headteacher/principal of all the low-level concerns and in a timely fashion”. The headteacher may consult the DSL and decide collaboratively.
Paragraph 525 says the policy should set out how the school responds. Where a concern has come from a third party, the headteacher or principal “(or a nominated deputy)” should collect as much evidence as possible by speaking to the person who raised it (unless anonymous), and to “the individual involved and any witnesses”. Paragraph 526 says the information helps them “categorise the type of behaviour” and decide what further action is needed, recorded “along with the rationale for their decisions and action taken”.
In practice, the response usually looks like this:
- Check the new concern against existing records for the same person.
- Decide whether it is really a low-level concern, an allegation, or not a safeguarding matter at all. If in doubt, consult the LADO.
- Speak to the individual and listen to their account.
- Agree what needs to change, often a reminder of the code of conduct or extra training: what paragraph 515 calls “supporting the individual to correct it at an early stage”.
- If a child may be at risk, the DSL’s normal child protection duties apply.
- Record the outcome and rationale.
Our Designated Safeguarding Lead (Children) course covers allegations against staff and the LADO. For the DSL’s wider role, see our guides to the designated safeguarding lead and the deputy DSL.
How should low-level concerns be recorded and how long should they be kept?
Paragraph 520 says “All low-level concerns should be recorded in writing.” The record should include:
- details of the concern,
- the context in which it arose,
- the action taken, and
- the name of the person who shared it, unless they asked to stay anonymous.
Paragraph 526 adds the rationale for decisions. Paragraph 521 leaves it to the school to decide where records are kept, but they “must be kept confidential, held securely and comply with data protection laws”. Many schools keep one central, restricted log so patterns can be reviewed in one place.
On retention, paragraph 523 says it is for schools to decide, “but it is recommended that it is retained at least until the individual leaves their employment”.
Should low-level concerns be included in references?
Generally, no. Paragraph 524 says schools “should only provide substantiated safeguarding concerns/allegations (including a group of low-level concerns about the same individual) that meet the harm threshold in references”. It goes on:
“Low-level concerns should not be included in references unless they relate to issues which would normally be included in a reference, for example, misconduct or poor performance. It follows that a low-level concern which relates exclusively to safeguarding (and not to misconduct or poor performance) should not be referred to in a reference.”
Paragraph 304 in Part three, on safer recruitment, says references should give “the facts (not opinions)” of substantiated concerns or allegations that meet the harm threshold, and should not include concerns that are “unsubstantiated, unfounded, false, or malicious”. Note the bracket in paragraph 524: a group of low-level concerns about the same person that together meet the harm threshold and are substantiated can be included. For the wider recruitment process, see our guide to safer recruitment.
When does a pattern of low-level concerns become an allegation?
Paragraph 522 says records “should be reviewed so that potential patterns of inappropriate, problematic or concerning behaviour can be identified”. Where a pattern is found, the school should decide a course of action: either its disciplinary procedures, or, “where a pattern of behaviour moves from a low-level concern to meeting the harm threshold”, a referral to the LADO under Part four, Section one.
KCSIE does not set a number. What matters is what the behaviour, taken together, suggests about risk to children.
Paragraph 522 also asks schools to consider “whether there are wider cultural issues” that enabled the behaviour. If several staff take photos on personal phones, the problem may be the school’s equipment and guidance. Build a review into the calendar, for example termly: a log nobody reads cannot find patterns.
How are low-level concerns about supply staff, contractors and volunteers handled?
The same way, with one addition. Paragraph 517 says low-level concerns about supply staff and contractors “should be notified to their employers, so that any potential patterns of inappropriate behaviour can be identified”. A supply teacher may work in several schools; only the agency can see the whole picture.
Volunteers and trainee teachers fall within “adults working in or on behalf of the school”, so concerns about them should be shared in the same way. KCSIE 2026 added trainee teachers throughout Part four, and paragraph 459 says teacher training providers are expected to follow the same procedures as supply agencies where concerns or allegations relate to a trainee.
How do low-level concerns fit with the code of conduct, safer recruitment and whistleblowing?
Code of conduct. A low-level concern is measured against the staff code of conduct, so the code has to be specific. Paragraph 123 says the staff behaviour policy should cover low-level concerns, allegations, whistleblowing, “acceptable use of technologies (including the use of mobile devices)”, and “staff/pupil relationships and communications including the use of social media”. Paragraph 513 says, as good practice, the low-level concerns policy should sit within the code of conduct and the child protection policy, and paragraph 527 calls a good policy “a reflection and extension” of the code.
Safer recruitment. Paragraph 422 says safer recruitment “is not just about carrying out the right DBS checks” and safeguarding “should not be limited to recruitment procedures”. Paragraph 423 asks for “continuous vigilance”. Low-level concerns are that vigilance after appointment. Our safer recruitment guide covers the checks before it.
Whistleblowing. Low-level concerns are about an individual. Whistleblowing (paragraphs 80 to 82) is about “poor or unsafe practice and potential failures” in the school’s safeguarding arrangements. If you feel unable to raise a concern internally, or think it is not being handled properly, paragraph 82 points to the NSPCC Whistleblowing Advice Line on 0800 028 0285. See our guide to whether whistleblowing is protected by law.
Do low-level concerns apply in colleges, nurseries and out-of-school settings?
Colleges. KCSIE’s definition of “college” includes further education and sixth-form colleges, 16 to 19 academies and independent training providers. The low-level concerns section applies in the same way, with the principal as decision maker, in relation to learners under 18.
Nurseries. KCSIE applies to maintained nursery schools and school-based nurseries. The EYFS statutory framework for group and school-based providers does not use the term “low-level concern”, but paragraph 3.6 requires safeguarding policies to cover “the action to be taken in the event of an allegation being made against a member of staff” and the use of mobile phones and cameras.
Clubs and tuition. The Department for Education’s safeguarding guidance for after-school clubs, community activities and tuition (February 2026) says “Providers should create a good low-level concerns policy” and should consult the LADO if in doubt.
What should a school’s low-level concerns policy include?
KCSIE paragraph 528 points to more detailed guidance, “Developing and implementing a low-level concerns policy”, published by Farrer & Co. At a minimum, check that your policy and practice cover the following:
- A clear definition that quotes KCSIE 2026, with examples relevant to your setting.
- Who receives concerns (DSL, values champion or headteacher), and that the headteacher is the decision maker.
- What happens when the concern is about the headteacher, the DSL or a governor.
- Confidential sharing, anonymity and self-referral.
- When to consult the LADO, with the local contact details.
- What is recorded, where it is kept, who can see it, and how long it is retained.
- A regular review of records for patterns, and who does it.
- Notifying agencies and employers about concerns relating to supply staff and contractors.
- The references rule in paragraph 524.
- Induction and training, so every adult, including volunteers, knows how to share a concern.
Our KCSIE explained guide covers how the five parts fit together, and safeguarding training requirements explains what training each role needs. For teachers recording their own learning, see CPD requirements for teachers.
Which courses help with low-level concerns?
Three Nexis CPD courses fit this guide. Designated Safeguarding Lead (Children) is for DSLs and deputies and covers thresholds, allegations against staff, the LADO and record keeping. Safeguarding Children (Advanced) Level 2 suits the wider staff team who need to recognise a concern and know how to respond. Safer Recruitment in Education covers references, ongoing vigilance, the LADO and the duty to refer to the DBS. Together they cost £18, because any three courses trigger the pay-for-2-get-3 offer.
These are awareness-level CPD courses. An online course does not make anyone a designated safeguarding lead; the governing body or proprietor appoints the DSL, and your local safeguarding partnership may expect its own training.
£9 per course. CPD accredited, 100% online, verifiable e-certificate. Pay for 2, get 3 — any 3 courses for £18. Start with Designated Safeguarding Lead (Children).
Training a team? From 5 staff, Nexis CPD course places cost £6 each. You pay once by card, then get your own portal to add staff, choose their courses and track who has finished. Fewer than five staff? Every course is £9, with any three for £18. See team pricing.
Frequently asked questions
What is a low-level concern?
Any concern, however small, that an adult working in or on behalf of a school or college may have acted inconsistently with the staff code of conduct, including outside work, but that does not meet the harm threshold or is not serious enough to refer to the LADO.
What are examples of low-level concerns in schools?
KCSIE 2026 gives five examples: being overfriendly with children, having favourites, taking photographs of children on a mobile phone contrary to school policy, engaging with a child one-to-one in a secluded area or behind a closed door, and humiliating children. The list is not exhaustive.
Who do I report a low-level concern to?
Follow your school’s low-level concerns policy. Each school decides whether concerns go first to the designated safeguarding lead, a nominated person such as a values champion, or the headteacher or principal. The headteacher or principal is the ultimate decision maker.
Are low-level concerns kept on file?
Yes. KCSIE 2026 says all low-level concerns should be recorded in writing, kept confidential and secure, and reviewed for patterns. It recommends keeping them at least until the individual leaves their employment.
Do low-level concerns go on a reference?
Not usually. KCSIE 2026 says low-level concerns should not be included in references unless they relate to issues that would normally be included, such as misconduct or poor performance.
Can a low-level concern become an allegation?
Yes. If a single concern or a pattern of concerns meets the harm threshold, it should be referred to the LADO under Part four, Section one of KCSIE. If the school is unsure whether a concern meets the threshold, it should consult the LADO.
This article is general information about low-level concerns in schools and colleges in England, not legal advice. It reflects Keeping Children Safe in Education 2026 (Part four, Section two, paragraphs 506 to 528), the EYFS statutory framework for group and school-based providers (September 2026) and the Department for Education’s safeguarding guidance for after-school clubs, community activities and tuition (February 2026) as we found them on 23 October 2026. Always follow your setting’s policies and your local safeguarding partnership’s procedures. If a child is in immediate danger, call 999. Nexis CPD courses are CPD-accredited awareness training, not regulated qualifications.