 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 he or she may pose a risk of harm to children, and/or 128 The harm test is explained in the Disclosure and Barring service Guidance: Making barring referrals to the DBS and Section 31(9) of the Children Act 1989 as amended by the Adoption and Children Act 2002 94 • behaved or may have behaved in a way that indicates they may not be suitable to work with children. 360. The last bullet point above includes behaviour that may have happened outside of school or college, that might make an individual unsuitable to work with children, this is known as transferable risk. 361. Where appropriate, an assessment of transferable risk to children with whom the person works should be undertaken. If in doubt seek advice from the local authority designated officer (LADO). 362. It is important that policies and procedures make clear to whom allegations should be reported (as set out at paragraph 72-74) and that this should be done without delay. A “case manager” will lead any investigation. This will be either the headteacher or principal, or, where the headteacher is the subject of an allegation, the chair of governors or chair of the management committee and in an independent school it will be the proprietor. The initial response to an allegation 363. Where the school or college identifies that a child has been harmed, that there may be an immediate risk of harm to a child or if the situation is an emergency, they should contact local authority children’s social care and as appropriate the police immediately as per the processes explained in Part one of this guidance. 364. There are two aspects to consider when a