behaviour early, through setting clear professional boundaries to minimize risk. SCL use the term Lower Level not Low Level as ‘lower level’ concern does not mean that it is insignificant. A lower-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 a colleague working in, or on behalf of SCL may have acted in a way that: Is inconsistent with the colleague’s code of conduct, including inappropriate conduct outside of work. Does not meet the harm threshold or is otherwise not serious enough to consider a referral to the Local Authority Designated Officer (LADO). Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate, but might not be in specific circumstances, through to that which is ultimately intended to enable abuse. Lower-level concerns and poor practice may arise in several ways and from a number of sources. For example: Suspicion. Complaint. Disclosure made by a child, adult, parent/carer, or other adult within or outside of SCL, or because of compliance checks undertaken. It is crucial that all lower-level concerns are shared responsibly and can be dealt with through internal disciplinary procedures and or training/mentoring. In such cases, lower-level concerns, the concern should be escalated to a SDSL or DSL, who will consider the following options with the PD: 1. Use of the disciplinary procedure. 2. If the individual is within a probationary period of employment, consider the extension of this period with clear targets for improved conduct. 3. Use of the appropriate management oversight meeting to set out clearly: a. What behaviour is not acceptable. b. What improvements need to be seen. c. What indicators there would be of improvement. d. How change will be monitored. e. What the ramifications will be should improvement not be seen. Lower-level concerns are recorded and kept confidentially and securely and comply with Data Protection 2018 and the UK Genal Data Protection Regulation (UK GDPR). Please refer to Codes of Conduct Policy and see flowchart below on what to do if an allegation is made about a colleague’s behaviour, including a lower-level concern .
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