The Keeping Children Safe in Education (KCSIE) statutory guidance for schools and colleges 2022 (p.7 pt.13) urges that all staff should be made aware of systems within their school or college that support safeguarding and that these should be explained as part of staff induction.
This should include:
- A staff behaviour policy (sometimes called a Code of Conduct), which should cover, amongst other things, low-level concerns, allegations against staff and whistleblowing.
There is no specific mention of this in Keeping Learners Safe 2020, however, I would advise schools in Wales to always aim for best practice, and identifying and managing low-level concerns is key.
KCSIE states that a low-level concern is any concern, no matter how small, even if it is no more than a sense of unease or a ‘nagging doubt’. Examples could include an adult working in or on behalf of the school or college who 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 allegations threshold or is otherwise not considered serious enough to consider a referral to the Local Authority Designated Officer (LADO).
Examples of such behaviour could include, but are not limited to:
- Being overly friendly with children
- Having favourites
- Taking photographs of children on their mobile phones, contrary to school policy
- Engaging with a child on a one-to-one basis in a secluded area or behind a closed door
- Humiliating pupils
I attended a conference with independent law firm Farrer & Co a few years ago, where I first heard about the significance of low-level concerns. They have produced guidance (updated with reference to KCSIE) sharing findings from 15 cases of child sexual abuse in organisational settings, including what colleagues had noted. The guidance features the cases of Vanessa George, Jeremy Forrest, Robert Stringer and Laurie Elizabeth Softley.
Some of the key points mentioned:
- A liberal ethos in the school had developed from its early days, deterring people from reporting concerns when rules were broken.
- Concerns were expressed by non-teaching staff who could see that Mr Thomson-Glover’s behaviour differed from other staff. Complaints were diluted, lost or disbelieved as they went up the management chain.
- Mr Vahey quickly normalised behaviours such as being alone with children and manipulating staff ratios on trips.
- Some staff were uneasy about Mr Vahey’s behaviour but put it down to his ‘informal style’.
- Popular with parents and pupils – Mr Vahey came second in teacher popularity ratings.
- The pupil (whom Mr Forrest subsequently abducted) was regarded as the problem.
- There was an adult-focused culture where pupils’ voices were not heard.
- Parents petitioned for Mr Stringer to return to the school when he was suspended.
Independent safeguarding consultant Marcus Erooga and colleagues found that grooming behaviours included the direct use of authority to offend, using material or practical benefits for victims, providing support for isolated children, favouring particular children and using alcohol, videos or sexual imagery, as examples. The abuse commenced with the erosion of boundaries, a slow progression to abuse, use of trust and authority, meeting the child’s needs (including physical and emotional) and developing relationships with the child’s family.
Erooga elaborates on the concept of a ‘slippery slope’ of boundary violations towards abuse and explains that there are many stages heading towards the breach of a boundary within a relationship. Sometimes initial infringements are part of a grooming process, but other times they are made innocently and with good intention. However, once boundaries are breached, restoring the relationship to one in which proper boundaries are respected becomes more difficult.
Furthermore, Erooga urges organisations to not only concern themselves with safeguarding boundaries. His research indicates that organisations where boundaries are adhered to, and staff perform their roles conscientiously, are likely to be the safest environments for children.
The slippery slope of pushing boundaries and seeing how much control they have over others are features of Step 6, as referred to in the blog on grooming. Will anyone pull the perpetrators up on their behaviour or just let them continue? If they let the perpetrators carry on, they are also implicit in the behaviour.
In light of this, schools should have a thorough and meticulous safeguarding culture and ethos that is understood by all staff to adequately safeguard children as well as staff.
For more information, please read my blog post, Creating a Safeguarding Culture.