Same as a lot of others, I use it to describe the actions - never her. It might be a small distinction but to me it's important, and I remember being labelled as a kid, I hated it.

I will not say to her 'YOU are naughty' but I might say 'don't scribble on the table, that is naughty'. If I thought about it I would prefer to use more specific words, but sometimes words fail me.