se can be reported no matter how long ago it happened. Section two: Concerns or allegations that do not meet the harm threshold 427. Governing bodies and proprietors should have policies and processes to deal with any concerns or allegations which do not meet the harm threshold, referred to in this guidance as ‘low-level’ concerns. It is important that schools and colleges have appropriate policies and processes in place to manage and record any such concerns and take appropriate action to safeguard children. Low-level concerns 428. As part of their whole school or college approach to safeguarding, schools and colleges should ensure that they promote an open and transparent culture in which all concerns about all adults working in or on behalf of the school or college 108 (including supply teachers, volunteers and contractors) are dealt with promptly and appropriately. 429. Creating a culture in which all concerns about adults are shared responsibly and with the right person, recorded and dealt with appropriately, is critical. If implemented correctly, this should: • enable schools and colleges to identify inappropriate, problematic or concerning behaviour early • minimise the risk of abuse, and • ensure that adults working in or on behalf of the school or college are clear about professional boundaries and act within these boundaries, and in accordance with the ethos and values of the institution. What a low-level concern is 430. The term ‘low-level’ concern does not mean that it is insignificant. A low-level concern is 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 school or college may have acted in a way that: • is inconsistent with the staff code of conduct, i