The definition
Keeping children safe in education (KCSIE) 2026, in force since 1 September 2026, splits concerns about adults into two levels (paragraph 435):
- Concerns or allegations that may meet the harm threshold. These go to the local authority designated officer (LADO).
- Concerns or allegations that do not meet the harm threshold. KCSIE calls these “low-level concerns”.
Paragraph 509 defines a low-level concern as 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 work, and
- does not meet the harm threshold or is otherwise not serious enough to consider a referral to the LADO.
“Low-level” does not mean insignificant. The definition covers everyone working in or on behalf of the school, including supply teachers, trainee teachers, volunteers and contractors.
Examples
KCSIE gives these examples, and says the list is not complete:
- being overfriendly with children,
- having favourites,
- taking photographs of children on their 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.
Behaviour like this sits on a wide spectrum, from the thoughtless or inadvertent through to behaviour intended to enable abuse (paragraph 510). Concerns can come from suspicion, a complaint, a disclosure by a child, parent or other adult, or vetting checks (paragraph 511).
Why it matters
KCSIE asks schools to build an open culture where all concerns about adults are shared, recorded and dealt with properly. Done well, this helps you spot inappropriate or concerning behaviour early, reduces the risk of abuse, and keeps everyone clear about professional boundaries (paragraph 508). It also protects staff from false concerns and misunderstandings (paragraph 512).
Your low-level concerns policy should be set out in your staff code of conduct and your safeguarding and child protection policies, as good practice (paragraph 513).
How concerns should be shared
Your policy should include a clear, confidential way to share concerns (paragraph 516). The school decides whether concerns go first to:
- the designated safeguarding lead (or a nominated person, such as a values champion), or
- the headteacher.
If they go to the DSL, the DSL should tell the headteacher about all of them in good time. The headteacher is the ultimate decision maker on low-level concerns, though they may decide together with the DSL.
Low-level concerns about supply staff and contractors should be passed to their employers, so patterns can be spotted (paragraph 517).
Staff should feel able to self-refer, for example if they’ve been in a situation that could be misinterpreted (paragraph 519).
How to record them
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 raised it. If they want to stay anonymous, respect that as far as reasonably possible.
You decide where records are kept, but they must be confidential, held securely and comply with data protection law (paragraph 521). KCSIE recommends keeping them at least until the person leaves your employment (paragraph 523).
How to respond
If the concern came through a third party, the headteacher (or a nominated deputy) should collect as much evidence as possible by speaking to the person who raised it (unless it was anonymous), the adult involved and any witnesses (paragraph 525). The decision and the reasons for it should be recorded in writing (paragraph 526).
Responses can include addressing the behaviour and supporting the person to correct it early (paragraph 515).
When a concern becomes an allegation
A concern meets the harm threshold, and becomes an allegation under Part four section one, when it is alleged that the adult has (paragraph 437):
- 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 they 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. This includes behaviour outside school, known as transferable risk.
Allegations go to the headteacher, or to the chair of governors if the allegation is about the headteacher, and they consider referral to the LADO (paragraph 78). Where a child has been harmed, may be at immediate risk, or it’s an emergency, contact children’s social care and, as appropriate, the police straight away (paragraph 441).
If in doubt, ask the LADO. If you are unsure whether a low-level concern in fact meets the harm threshold, KCSIE says you should consult your LADO (paragraph 518).
Look for patterns. Records should be reviewed so patterns can be spotted. Where a pattern of behaviour moves from low-level to meeting the harm threshold, it should be referred to the LADO. Otherwise, the school decides on a course of action, which may be through its disciplinary procedures. You should also ask whether something in the school’s culture allowed the behaviour, and whether policies or training need to change (paragraph 522).
KCSIE does not say how often to review records or how many concerns make a pattern. That is for your policy and your judgement.