Written June 2025

To be reviewed June 2026

 

Introduction 

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Bettws Lifeline is committed to providing the highest level of care for both its pupils and its staff. It is extremely important that any allegations of abuse against a teacher or any other member of staff in our provision are dealt with thoroughly and efficiently, maintaining the highest level of protection for the child whilst also giving support to the person who is the subject of the allegation.

 

Our policy is in line with statutory guidance from the Keeping Children Safe in Education 2022: handling allegations of abuse against teachers and other staff and is in line with statutory guidance from the Department for Education. 

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This policy is designed to ensure that all staff, pupils and parents or carers are aware of the procedure for the investigation of allegations of abuse in order that all complaints are dealt with consistently and efficiently as possible. 

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We hope that having a clear policy outlined will help pupils to feel comfortable that they can voice concerns about any member of staff. Allegations will be reported to the Manager immediately or to the chair of Directors where the Manager is the subject of an allegation. All allegations will be taken seriously and investigated immediately.

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 The term 'Bettws Lifeline’ refers to the company subsidiary and  acknowledges that staff are part of the larger umbrella company,  Bettws Lifehouse Ltd. 

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This policy is in two parts. The first part deals with allegations made against teachers, any other members of staff, including supply staff, contractors or volunteers. The second part of the policy deals with low level concerns raised in relation to teachers, any other members of staff, including supply staff, contractors or volunteers.

 

 PART ONE: Allegations against staff, supply staff, contractors and volunteers 

 

Purpose

 The procedure for dealing with allegations against staff depends on the situation and circumstances surrounding the allegation.

 

This policy must be followed when dealing with allegations but may be adapted to each case. This policy will be used alongside the provision’s complaints policy and child protection and safeguarding policy. 

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This policy will be used in any case where it is suspected or alleged that a member of staff or a volunteer at the provision has:

 • behaved in a way that has harmed a child or may have harmed a child (our child protection policy outlines what it means to harm a child); 

• possibly committed a criminal offence against or related to a child; or

 • behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children. 

The  bullet points above includes behaviour that may have happened outside of provision that might make an individual unsuitable to work with children. This is known as transferable risk. 

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Timescale 

It is imperative that allegations against staff are dealt with as quickly as possible to: 

• minimise the risk to the child 

• minimise the impact on the child’s academic progress 

• minimise stress to the employee concerned 

• ensure a fair and thorough investigation for all parties.

 To enable this to happen, all staff, parents, and students should be aware of the procedures set out in this policy.

 

Procedure

Reporting an allegation 

All allegations made against staff should be reported immediately to the Manager. Complaints about the Manager should be reported to the Chair of Directors or Chair of Independent Panel who will then contact the designated officer at the local authority. 

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Staff who are concerned about the conduct of a colleague towards a pupil are undoubtedly placed in a very difficult situation.

 

They may worry that they have misunderstood the situation and they will wonder whether a report could jeopardise their colleague’s career.

 

All staff must remember that the welfare of the child is paramount and must report their concerns immediately. 

 

When an allegation is made, the Manager and/or the Chair of Directors will consider two aspects: 

• looking after the welfare of the child; and 

• investigating and supporting the person subject to the allegation.

 In each case, they will: 

• apply common sense and judgement; 

• deal with allegations quickly, fairly and consistently; and 

• provide effective protection for the child and support the person subject to the allegation. 

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Before contacting the LADO, the Manager or Director will conduct basic enquiries to establish the facts to help determine whether there is any foundation to the allegation. Statements from any witnesses will be obtained and recorded and kept securely.

 

A decision will be taken at this point as to whether a referral to the LADO is required.  If a decision to NOT refer is taken then a robust statement outlining WHY this has not been necessary will be recorded on our reporting software ( CPOMS).

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The Manager or director will contact the designated officer at the local authority and a discussion will take place to decide whether: 

• more information is required; or

 • no further actions are needed; or 

• a strategy discussion should take place; or

 • there should be immediate involvement of the police or social care. 

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The provision will share available information with the LADO about the allegation, the child, and the person against whom the allegation has been made and consider whether a police investigation or a strategy discussion is needed.

 

Representatives from other agencies may be invited to the discussion and could include representatives from health, social care and police.

 

Investigation 

An investigation into the allegation is normally carried out by children’s social services or by the provision. This will be agreed at the initial evaluation stage. Where the provision is not conducting the investigation, it will cooperate with investigative agencies. 

Internal investigations must be second to any safeguarding investigation and may need to be delayed until the external investigation is complete. 

The following definitions should be used when determining the outcome of the investigation: 

• Substantiated: there is sufficient evidence to prove the allegation 

• Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive 

• False: there is sufficient evidence to disprove the allegation 

• Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation. The term, therefore, does not imply guilt or innocence.

 • Unfounded: to reflect cases where there is no evidence or proper basis which supports the allegation being made 

 

Supporting those involved 

The person(s) who makes the allegation and their parents/carers 

Parents and carers will be notified if their child makes or is involved in an allegation against staff if they do not already know, when it is determined that this allegation is not totally unfounded in the first instant.

 

However, if the police or social services are to be involved, they will be contacted first and will advise as to what information may or may not be disclosed to the parents.

 

There will be a staff member designated to the role of liaising with the parents and child about the case and ensuring that they are fully informed as far as is possible.

 

Parents and carers will be made aware of any progress in the investigation, and where there is no criminal prosecution, the outcome will be explained to them as far as is legally possible, however protection of all parties must be considered and discussed to ensure no breach of expected professional confidentiality.

 

There may be a disciplinary outcome. During a disciplinary hearing the deliberations and information used for making a decision are usually confidential.

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 Social services and the police may be involved and will provide the provision with advice on what type of additional support the child may need. 

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The provision’s whistleblowing code enables staff to raise concerns or allegations against their colleagues in confidence and for a sensitive enquiry to take place. 

 

The employee 

Bettws Lifeline has a duty of care to its employees and will take steps to minimise the stress of any allegation and the investigation process. 

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The person who is the subject of the investigation will be informed as soon as possible and usually after the initial discussion with the designated officer. The employee will then be advised on what the next course of action will be.

 

However, if the police or social services are to be involved, they will be contacted before the employee, and will advise as to what information may be disclosed to the person under investigation. 

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A nominated and agreed staff representative will keep the employee informed of the progress of the case and any other work related issues. 

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The employee may need additional support and the provision will consider what might be appropriate to best accommodate this. If it is a criminal investigation and the police are involved, they may provide this additional support. 

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Confidentiality 

The provision will make every effort to guard the privacy of all parties during and after an investigation into an allegation. It is in everyone’s best interest to maintain this confidentiality to ensure a fair investigation with minimum impact for all parties.

 

The Education Act 2002 introduced reporting restrictions preventing the publication of any material that may lead to the identification of a teacher in a provision who has been accused by, or on behalf of, a pupil from the same provision. This applies to parents and carers as well as the press.

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A breach of confidentiality will be taken seriously and may warrant its own investigation. 

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Suspensions 

The provision will not suspend a member of staff without serious consideration and will not do it automatically once an allegation has been made.

 

Depending on the nature of the case, it may be possible that alternative arrangements are made so that the individual can continue working. 

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The Directors hold the power to suspend an employee but will listen to the views of the police and or social care regarding suspension. In the case of suspension, the employee will receive written confirmation within one working day and will be informed of the reason for the suspension. 

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The provision will not prevent social contact with work colleagues and friends unless there is evidence to suggest this may prejudice the gathering of evidence. 

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Resignations 

If an employee resigns when the allegation is made against them or during an investigation, the investigation will continue until an outcome has been reached, with or without the employee’s cooperation.

 

They will be given full opportunity to answer the allegation.

 

Record keeping 

Where an allegation is found to be malicious, it will be removed from the record of the employee concerned. 

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For all other allegations, records of investigations and outcomes will be kept in the employee’s personal file and they will be given a copy.

 

The record will be kept, including for people who leave the organisation, at least until the person reaches normal retirement age or for 10 years if that will be longer, from the date of the allegation.

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Details of any allegation made by a pupil will be kept in the confidential section of their record. 

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Action on conclusion of the case 

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If the allegation is substantiated and the employee is dismissed or resigns, or we cease to use the volunteer’s services, the provision will consider whether a referral must be made to the DBS and/or to the TRA as appropriate.

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If it is decided that the employee may return to provision after a suspension, then provisions will be put in place by the provision to ensure that the transition is as smooth as possible.

 

This may involve a phased return for a trial period or the use of another member of staff as a support system in the short term. If the child who made the allegation is still at the provision, the provision will consider what needs to be done to manage the contact between employee and child. 

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Where an allegation is made against a member of supply staff or a contractor, the outcome of the investigation will be shared with the supply agency and the LADO. 

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Action in the case of false or malicious allegations 

Where an allegation is proved to be false, the Manager and chair of directors may refer to social services to determine whether the child needs support or has been abused by someone else. If the claim has been made by a person who is not a pupil, the provision may pass the information to the police who may take further action against that person. 

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After the case

 No matter what the outcome is of an allegation of abuse against staff, the provision will review the case to see if there are any improvements that can be made in its practice or policy that may help to deal with cases in the future.

 

Non recent allegations 

Where an adult makes an allegation to Bettws Lifeline that they were abused as a child, within the setting, then that adult will be advised to report the allegation to the police. 

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Non recent allegations made by a child will be reported to the LADO in line with the local authority’s procedures for dealing with non-recent allegations.

 

 PART TWO: Low level concerns 

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Purpose 

The procedure for dealing with low level concerns raised in relation to teachers, any other members of staff, including agency staff, contractors or volunteers depend on the situation and circumstances surrounding the concern. 

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This policy must be followed when dealing with low level concerns but may be adapted to each case. This part of the policy will be used alongside the provision’s complaints policy, child protection and safeguarding policy and Staff discipline, conduct and grievance policy. 

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Bettws Lifeline promotes an open and transparent culture in which all concerns about all adults working in or on behalf of the provision (including commissioned professionals, volunteers and contractors) are dealt with promptly and appropriately. 

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This policy is designed to: 

• promote and maintain a culture of openness, trust and transparency where staff are clear about the behaviours expected of themselves and their colleagues 

• ensure staff feel comfortable to raise low-level concerns; and 

• provide for efficient and proportionate handling of those concerns when raised. 

Recognising low level concerns 

This policy will be used to manage ‘low-level’ concerns, defined 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 provision 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 allegations threshold or is otherwise not considered serious enough to consider a referral to the Local Authority Designated Officer (LADO). 

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Examples of such behaviour could include, but are not limited to:

 • being over friendly with children; 

• having favourites; 

• misuse of their mobile phone; 

• engaging with a child on a one-to-one basis in a secluded area or behind a closed door when not necessary; or, 

• using inappropriate sexualised, intimidating or offensive language. 

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The importance of sharing low level concerns 

For our culture of openness, trust and transparency to prevail, all staff should share any low level concerns they have.

 

Serious case reviews and safeguarding practice reviews have all too often evidenced how low level concerns felt and/or expressed by staff relating to individuals who were later found to have sexually abused children at a provision were not recorded.

 

When they are not recorded, they cannot be reviewed or studied for patterns of behaviour. 

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To minimise and hopefully eradicate the risk of those opportunities being missed, it is critical that staff understand their role in identifying and reporting low level concerns. 

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How to share low level concerns 

All staff are encouraged to report low level safeguarding concerns regarding colleagues so that the identified behaviours can be investigated and managed appropriately.

 

The welfare of the child is paramount and so staff must report their concerns immediately.

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All low level concerns in relation to staff, supply staff, contractors and volunteers should be reported immediately to the Manager. Concerns about the Manager should be reported to the Directors. 

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The procedure for reporting low level concerns is deliberately the same as that for reporting allegations of abuse as set out in part one of this policy.

 

Therefore, staff do not need to concern themselves with whether their concern meets the threshold set out in part one of this policy or is a low level concern.

 

The Manager or Directors (as appropriate) will make this determination once the staff member has reported the issue. 

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Responding to low-level concerns

 The Manager or Director(as appropriate) will review the concern to confirm that it is not a more serious issue that should be dealt with under part one of this policy.

 

An issue reported as a low level concern would be dealt under part one of this policy where it meets the threshold set out in part one or there is a pattern of low level concerns expressed about the individual or staff practices generally.

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 If necessary, the Manager or chair (as appropriate) will discuss the concern with the LADO to determine whether it should be dealt with under part one of this policy. 

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The Manager or chair (as appropriate) will discuss the concern with the individual who raised it and will investigate it as appropriate. 

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Most low-level concerns are likely to be minor and will be dealt with by means of management support or additional training.

 

Where necessary, action may be taken in accordance with the provision’s staff discipline, conduct and grievance policy. If the concern has been raised via a third party, the Manager will collect as much evidence as possible by speaking directly to the person who raised the concern (unless it has been raised anonymously), to the individual involved and any witnesses.

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 Where a low level concern is raised about a member of supply staff or a contractor, the concern will be shared with supply agency so they can take appropriate steps in accordance with their own policies and statutory guidance. 

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Recording low-level concerns 

All low-level concerns will be recorded in writing and will include details of the concern, the context and action taken.

 

The records will be kept confidential and held securely in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation. 

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Records of low-level concerns will be reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified.

 

If such patterns are identified, the provision will decide on an appropriate course of action and will refer the matter to the LADO where the behaviour moves from a concern to meeting the harms threshold set out in the first part of this policy. 

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The record of the low-level concern will be kept at least until the person leaves our provision. 

 

References

 

Low level safeguarding concerns will not be included in references except where they have met the threshold for referral to LADO and found to be substantiated.