Best Start in Life – English for Speakers of Other Languages (ESOL) Programme for Pregnant Refugee, Migrant Women as Learners privacy notice
We keep this privacy notice under regular review and was last updated on 22 September 2026.
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Who we are
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.
This programme will deliver English for Speakers of Other Languages (ESOL) to pregnant refugee and migrant women as learners.
Through group learning sessions, learners will improve their language skills and build confidence in speaking with midwives, doctors and other health professionals to prepare for the birth of their baby.
The programme is targeted to pregnant refugee, migrant women who would usually require an interpreter when engaging with maternity services. The programme provides a foundation for improving pregnant refugee and migrant women’s English skills, to:
- reduce the long-term need for interpreters in health services
- help pregnant and migrant women to navigate systems
- improve communication which decreases language barriers that can lead to poorer health outcomes.
The purpose of the programme is to make available two 6-week ESOL group sessions in pregnancy to support pregnant refugee and migrant women through their pregnancy journey to equip them with the necessary English language skills to communicate effectively:
- with healthcare staff
- to prepare for the birth of their baby
- to make informed decisions about their care and the care of their baby.
The sessions will also provide opportunities for mutual support around pregnancy and birth topics and support the development of social networks with other expectant mothers.
The first course will run from 8 October to 19 November 2026. The second course will run from 1 November 2026 to 20 January 2027.
The personal information we collect and use
Beyond the Page will collect and handle your personal data on behalf of us.
In the course of delivering the ESOL programme, the following personal information will be collected when you provide it to Beyond the Page:
- name
- age range
- contact details (email address, phone number)
- main language spoken
- emergency contact details.
The following personal data will also be collected, which is special category data, more sensitive and is treated with extra care and protection:
- Racial/ethnic origin
- Information on health and safety concerns and accessibility that may be relevant to attend the sessions/class.
Within group conversations, you may disclose other information that is considered special category data and therefore this will be treated with extra care and protection.
How we use your personal information
Your personal information will be used to:
- maintain contact with you throughout the 6-week delivery of the course
- emergency contact name and details will be used only for class attendance
- support your learning
- monitor and report on your progress
- provide information, advice and guidance and to promote further learning opportunities
- evaluate and quality assure the services we provide
- use your images, quotes or coursework for good news information stories or promotional material if you have consented for us to do so.
All data will be stored securely on encrypted, password-protected systems, accessible only to authorised Beyond the Page staff.
A WhatsApp group will be established, with participant consent and due diligence protocols in place, to share session materials, reminders, and additional learning resources. Learners will also be guided toward reliable home study resources and online tools to consolidate English language skills between sessions. The Programme Manager and Peer and Engagement Manager will both have access to the WhatsApp groups as administrators, using only work phones which are pin protected.
Learners will be able to access session materials to catch up, or to support their learning at their own pace for up to 3 days following a session but can request a copy to be resent for up to 122 days.
Personal data will not be used in session slides or learning resources. Information will be provided at the start of the programme explaining how session content will be used. Only enrolled learners will have access to materials and resources.
Anonymisation procedures will ensure that when reporting or producing materials for wider sharing, individual learners cannot be identified. This includes removing names, contact details, and any unique identifiers from reports and presentations.
The programme’s model is to build trust with open and transparent conversations with learners, allowing choice and control over how you engage.
At the end of the programme, a report will be produced summarising key points from the programme. This will include collated and anonymised data of learners including your ethnicity, age range and location.
The report will include details and appendices such as:
- written case studies, impact stories, photos of sessions or class
- learners’ self-reported satisfaction scores
- wider learning from the programme which can be shared with us
- intended next steps for the learners
- engagement with and working with maternity services and key stakeholders
- pre/post measure of language confidence, knowledge or proficiency measures, decrease in feeling isolated.
The report and associated information will be shared with our Public Health consultant and specialists and colleagues who lead the Perinatal Mental Health Best Start in Life programme in Kent.
When referred in or self-referring, you will be provided with clear and concise information which will include asking you to freely opt-in to a specific statement of consent for personal data to be captured, processed and shared. This will include your right to withdraw consent at any time.
You will receive a copy of this privacy notice, and a Plain English guide explaining what data is collected, why it is collected, how it will be used, and your right to withdraw consent at any time.
Session facilitators will verbally explain data collection at the first session attended and provide additional guidance on data use throughout the programme.
Your consent will be obtained in writing or via recorded verbal agreement, with reminders before any case studies, photographs, or impact stories are collected.
Reasons we can collect and use your personal information
When your personal information is collected, we rely on the following legal bases:
- Article 6(1)(a) - you have given consent to the processing of your personal data for one or more specific purposes.
- Article 6(1)(e) - processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
When your 'special categories of personal data' (such as any health information) are collected, we rely on the following legal bases:
- Article 9(2)(a) - you have given explicit consent to the processing of your personal data for one or more specified purposes.
- Article 9(2)(g) - processing is necessary for reasons of substantial public interest.
We rely on the ‘safeguarding of children and individuals at risk’ and ‘equality of opportunity or treatment’ conditions from Schedule 1 of the Data Protection Act 2018 when relying on Article 9(2)(g) to process your special category data.
We take the following appropriate safeguards in respect of your special category data when relying on the conditions above:
- We have an Adult Social Care and Health Appropriate Policy Document in place when using your special category data. This policy is retained throughout the time we use your data and for 6 months after we cease to use it
- We maintain a record of our processing in our ‘Record of Processing Activities’ and record for any reasons deviating from the periods in our retention schedule.
How long your personal data will be kept
Beyond the Page will hold your personal data securely and retain it for the duration of the programme, until 31 March 2027, as this is necessary to deliver, verify and report the programme findings. Beyond the Page will then delete your personal data and provide evidence of deletion to us at the end of the programme.
We may keep anonymised data, which cannot identify you, up to 31 March 2028 where we have a specific use for it, such as learning for future programmes, or providing examples for educational purposes.
Who we share your personal information with
We will share personal information with law enforcement or other authorities if required by applicable law or in connection with legal proceedings.
We will share personal information with our legal and professional advisers in the event of a dispute, complaint or claim. We rely on Article 9(2)(f) where the processing of special category data is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
Your rights
Under the UK GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (subject access request)
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioner's Office.
Depending on our reason for using your information you may also be entitled to:
- object to how we are using your information
- ask us to delete information we hold about you
- have your information transferred electronically to you or to another organisation
- object to decisions being made that significantly affect you
- stop us using your information in certain ways.
We will always seek to comply with your request. However, we may be required to hold or use your information to comply with legal duties. Your request may delay or prevent us delivering a service to you.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the United Kingdom General Data Protection Regulation.
If you would like to exercise a right, contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk.
Your right to withdraw your consent
Where we rely on your consent to process your personal information, you can withdraw your consent to our use of your data at any time.
To do this email Beyond the Page at admin@beyondthepage.org.uk . Beyond the Page will notify us if you have withdrawn your consent.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Who to contact
Contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk.
UK GDPR also gives you right to lodge a complaint with Information Commissioner, who may be contacted via the Information Commissioner's website or call 03031 231113.
Read our corporate privacy statement.