Low-level concerns policy for international schools

A low-level concerns policy deals with the space between nothing happened and a formal allegation. Keeping children safe in education 2026 places it in Part four, section two, and the definition is deliberately wide. 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 may have acted in a way that is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, and that does not meet the harm threshold or is otherwise not serious enough to consider a referral to the local authority designated officer.

The guidance is explicit that the term does not mean the concern is insignificant. The examples it gives are ordinary and recognisable: being overfriendly with children, having favourites, taking photographs of children on a personal phone contrary to school policy, engaging with a child one to one in a secluded area or behind a closed door, and humiliating children. Most experienced teachers have seen at least one of those and said nothing, because there was no obvious place to say it.

For an international school the definition transfers cleanly. The threshold language does not depend on English law, and the behaviours it describes happen on every campus in every country. What does not transfer is the referral route, and that is the part a school outside England has to design for itself.

The guidance describes adult behaviour as sitting on a wide spectrum, running from the inadvertent or thoughtless, through behaviour that looks inappropriate but might not be in the specific circumstances, to behaviour intended to enable abuse. A single incident at the low end of that spectrum tells a school very little on its own. Four notes written over two years by four people who never spoke to each other tell it a great deal, and the only way to have those four notes is to have asked for them.

Recording low-level concerns lets a school identify inappropriate or concerning behaviour early, address unprofessional conduct while it is still correctable, and see where its own arrangements made the behaviour possible. It also protects staff. A concern that is written down, dated and answered cannot resurface years later as an unresolved rumour, and the guidance makes the point directly: handling these concerns well protects adults working in or on behalf of the school from becoming the subject of false concerns and misunderstandings.

Schools also under-use the self-referral route. Keeping children safe in education asks schools to create an environment where staff feel confident to report themselves, where they have ended up in a situation that could be misread or that on reflection falls below the expected professional standards. A teacher who drove a distressed sixteen-year-old home at nine in the evening is in a far better position having recorded it that night than explaining it six months later.

The school chooses whether concerns are shared first with the Designated Safeguarding Lead, with a nominated person, or straight with the Head of School. Whichever route it picks, the head or principal is the ultimate decision maker on low-level concerns. Where concerns arrive with the DSL first, the DSL informs the head, in a timeframe that matches the nature of the concern. The guidance allows a more collaborative decision where the concern or the DSL's own position in the school makes that sensible.

Two details are easy to miss. Concerns shared about supply staff and contractors have to be notified to their employers, so that a pattern spread across several schools can be seen by the one organisation in a position to see it. And where the school cannot tell whether what it has heard is a low-level concern or something that meets the harm threshold, the guidance says consult rather than decide alone. In England that consultation goes to the local authority designated officer.

A concern about the Head of School is the case every policy should name, and many do not. The route has to run above the head, to the chair of governors, the board or the owner. Write the name and a direct contact into the policy, because a member of staff working that route out for the first time, under stress and possibly in a second language, will usually give up.

Recording is the part schools get wrong most often, usually by keeping the record in the head's notebook. Keeping children safe in education asks for all low-level concerns to be recorded in writing, kept confidential, held securely and handled in line with data protection law. Schools decide where the records live. They do not decide whether the records exist.

• The concern itself in factual terms, separating what was observed from what was inferred.
• The context in which it arose: date, time, place and who else was present.
• The name of the person who raised it, with a wish for anonymity respected as far as is reasonably possible.
• The action taken, including any conversation with the individual concerned, and the reasoning behind each decision.
• The outcome, and whether the concern is closed or the behaviour is being monitored.

Records are reviewed so that patterns of inappropriate, problematic or concerning behaviour can be identified. Where a pattern appears, the school decides on a course of action through its disciplinary procedures, or, where the behaviour has moved up to the harm threshold, treats it as an allegation. The guidance also asks the school to look at itself: whether wider cultural issues allowed the behaviour, and whether a policy needs revising or extra training delivering. Retention is a school decision, with a recommendation that records are kept at least until the individual leaves employment.

References follow a narrow rule that international schools should read carefully. Substantiated concerns that meet the harm threshold belong in a reference. A low-level concern relating only to safeguarding, and not to misconduct or poor performance, should not be referred to in a reference at all. That matters in a sector where a school may be the only previous employer a candidate has in the region, and where safer recruitment across borders already runs short of checks. The rule protects candidates from unsubstantiated claims following them between countries, which is why the recording and pattern review inside the school has to be strong enough to carry the weight instead.

The local authority designated officer is an English creation. There is no equivalent post in Kazakhstan, the United Arab Emirates, Turkey or most of the countries international schools operate in, and the two functions the LADO performs are worth separating before a school tries to replace it. The LADO gives a second opinion on whether a threshold has been crossed, and it puts an external check on a school that might otherwise be tempted to handle a problem quietly.

A school outside England can build both, with deliberate design. For the second opinion, name a person outside the reporting line of the individual concerned: a governor holding a safeguarding remit, a regional safeguarding lead in a school group, an external safeguarding adviser on a retainer, or the Designated Safeguarding Lead at a peer school under a written reciprocal arrangement. For the external check, name the local bodies the school does have, which usually means the children's rights or guardianship authority, the police unit handling offences against minors, and the education department, together with any reporting duty local law places on individuals.

Write the substitute into the policy by name and role, with a telephone number, and review it every year, because the people move. A policy telling staff to consult the LADO in a country that has no LADO reads to an evaluator as a document that was copied rather than written, and that line is among the first things a safeguarding policy audit picks up. What applies from Keeping children safe in education outside England is a conversation to have with the board before the redraft, not during it.

A policy can be technically correct and still fail, because reporting a colleague is socially expensive, and international staff rooms make it more so. In the schools I have worked in and evaluated, a large part of the staff are local hires on local contracts, working alongside expatriate teachers on packages, inside a hierarchy that everyone understands and nobody has written down. A teaching assistant on a one-year contract who has a nagging doubt about a senior teacher is weighing a rumour against a job.

Three things change that arithmetic. The first is naming more than one recipient, so the route never has to pass through the person the concern is about or their line manager. The second is language: a member of staff describing an uncomfortable observation about a colleague will do it in the language they think in, and a form that accepts only English filters out most of the site staff before they start. The third is visible response. The first person who reports something and watches nothing happen tells everyone else.

The staff code of conduct carries more weight here than the policy itself. Where staff are clear about what appropriate behaviour looks like on this campus, in specific terms, raising a low-level concern becomes a comment about an agreed standard rather than an accusation about a person. Why staff hesitate to report, and what changes it is worth reading alongside this if the concerns log has been empty for a year. A school receiving no low-level concerns is not a school where none arise.

A low-level concerns policy works only if staff know it exists and can recognise the threshold while they are standing in it. That is a training problem, and standard modules do not solve it, because the examples come from another country and the reporting route in the module is not the school's route.

SafeguardIS builds training from the school's own safeguarding and child protection policies, including the code of conduct and the low-level concerns section, so what staff learn is what that school actually does. The Designated Safeguarding Lead reviews and approves every module before staff see it; publishing requires a named reviewer's declaration, and the content is hashed and logged. Staff can ask the AI policy assistant questions that are answered from the school's own policies, which is often where a first tentative question about a colleague's behaviour begins. The DSL keeps every safeguarding decision, and no child's details belong in a chat window. Training ships in English, Russian and Kazakh today. If your staff work in a language the platform does not ship yet, I build that language in for your school as part of the pilot.

Miras International School in Astana is the pilot school. To see how the low-level concerns section of your own code of conduct turns into a scenario staff work through in their own language, book a 20-minute walkthrough.