It can be difficult to be objective when thinking about the expectations of behaviour within your particular Religious Life Group.  Of course, we all want to believe that we have engendered a positive culture and that all our members feel they can identify and talk openly about any concerns they might have.  However,  can we truly say that this is definitely the case with all members and in all areas of the RLG and in all aspects of safeguarding? 

Creating a culture where all concerns about adults (in particular those which do not meet the harm threshold) are shared responsibly forms the basis of Low Level Concern reporting.

Dealing appropriately with all concerns will, encourage an open and transparent culture; enable organisations to identify concerning, problematic or inappropriate behaviour early; minimise the risk of abuse; and ensure that adults working in or on behalf of the organisation are clear about professional boundaries and act within them, in accordance with the ethos and values of the organisation.

Farrer and Co. (2020)

Farrer and Co. worked closely with Marcus Erooga, Hugh Davies QC, and Jane Foster to produce a highly effective document endorsed by the Department for Education in their publication ‘Keeping Children Safe in Schools’. This document, ‘Developing and implementing a low-level concerns policy: A guide for organisations which work with children’ is the source of the guidance outlined below.

Behaviour inconsistent with that which is expected within an RLG and does not meet the standards and values set out in the organisation’s code of conduct needs to be addressed. A mindset needs encouraging and nurturing so that it becomes ‘normal’ practice that is part of the everyday culture and not questioned, to alert designated people within your RLG about ‘nagging doubts’, concerning, problematic or inappropriate behaviour early in order to minimise the risk of abuse. Such behaviour can exist on a wide spectrum – from the inadvertent or thoughtless, through to that which is ultimately intended to enable abuse.

Case Studies

Jonathon Thomson-Glover – Clifton College

Organisational culture…

• A liberal ethos in the school had developed from its early days and this deterred people from reporting concerns when rules were broken.
• Favouritism was part of the school culture.
• There was a culture of “informally socialising.”
• There was a culture of “pranks” in the school.
• There was a lack of curiosity or consideration that “it could happen here.”

Jonathan Lord – YMCA, New South Wales (Australia)

Organisational culture…

• During the period of Mr. Lord’s employment, YMCA NSW had over 80 policies in place, and many referred to child sexual abuse and maltreatment. However, the policies were too complex, and sometimes inconsistent and inadequately communicated to staff and parents. Overall, the Commission concluded that…there was a serious breakdown in the application of YMCA NSW’s child protection policies at YMCA Caringbah.
• The extent of the policy breaches identified suggests a breakdown in communication between management and staff. Although YMCA NSW did have a reporting system, it was ineffective. Some junior staff stated that they felt uncomfortable speaking to their managers, or worried that nothing would be done about their concerns.

Allegations, Concerns and the Harm Threshold

In everyday safeguarding practice, the words ‘allegation’ and ‘concern’ are used interchangeably. Crucially, whatever the language used, the behaviour referred to may, on the
one hand, be capable of meeting the harm threshold (and hence be referrable), or, on the other, it does not meet the harm threshold (in which case it should be treated as a low level concern). So, the focus should not be on the language used by the person disclosing it; the focus should, instead, be on the behaviour being described.

A Useful Reminder… Allegation that may meet the harm threshold
The term ‘allegation’ means that it is alleged that a person who works with children has:
Behaved in a way that has harmed a child, or may have harmed a child; and/or
Possibly committed a criminal offence against or related to a child; and/or
Behaved towards a child or children in a way that indicates they may pose a risk of harm
to children; and/or
Behaved or may have behaved in a way that indicates they may not be suitable to work
with children

Boundaries

There are many stages on the slippery slope towards the breach of a boundary within a relationship. Sometimes these initial infringements are part of a grooming process, but at other times they are made innocently and with good intention.
However, once boundaries are breached it then becomes more difficult to restore a relationship in which the proper boundaries are respected.

Erooga emphasises that organisations should not simply concern themselves with safeguarding boundaries. His research indicates that organisations in which boundaries are adhered to in every respect in which staff perform their role are likely to be the safest environments for children, young people and vulnerable adults.

Tabachnick and Baker’s research describes a widely held but erroneous perception that individuals can accurately judge people, or profile a sex offender, and emphasises the need to understand that there is no one profile to describe everyone who abuses a child and the importance, therefore, of a focus instead on specific behaviours.

Focusing on behaviours is a vital way forward in which organisations can encourage the reporting of low level concerns as it takes away the need to focus on who a person is reporting. It encourages members of the organisation to look beyond the hierarchical systems or power dynamics and promotes the concept that any person might be capable of any type of behaviour, intended or not, regardless of their position of authority. It removes the question of ‘Should I say anything as they are my close colleague/my boss/a member of the board’ and replaces this with ‘That behaviour is making me uncomfortable/breaches our code of conduct/is inappropriate and I have to report it’.

If we educate adults to be informed about, and to identify, concerning, problematic or inappropriate behaviour, rather than think they can recognise dangerous people, they can be prepared to act when they observe behaviour which violates a staff code of conduct.