bt’ - that an adult working in or on behalf of the school 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 harm threshold or is otherwise not serious enough to consider a referral to the LADO. Examples of such behaviour could include, but are not limited to: • being over friendly with children • having favourites • taking photographs of children on their mobile phone, contrary to school policy • engaging with a child on a one-to-one basis in a secluded area or behind a closed door, or • humiliating children. 431. Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate, but might not be in specific circumstances, through to that which is ultimately intended to enable abuse. 432. Low-level concerns may arise in several ways and from a number of sources. For example: suspicion; complaint; or disclosure made by a child, parent 109 or other adult within or outside of the organisation; or as a result of vetting checks undertaken. 433. It is crucial that all low-level concerns are shared responsibly with the right person and recorded and dealt with appropriately. Ensuring they are dealt with effectively should also protect those working in or on behalf of schools and colleges from becoming the subject of potential false low-level concerns or misunderstandings. Staff code of conduct and safeguarding policies 434. As good practice governing bodies and proprietors should set out their low- level concerns policy within their staff code of conduct and safeguarding and child protection policies as set out in Part two of this guidance. They should make it clear what a low-level concern is and the im