Privacy Policy

1Who we are

First Bell ("we", "us", "our") operates the First Bell platform at firstbell.ie and through the First Bell mobile application. First Bell is a platform that connects Irish primary and post-primary schools with verified substitute teachers for emergency and planned cover.

First Bell EdTech Limited is the data controller for all personal data processed through the platform. We are operated and run from Marine Court Centre, Malahide, Co. Dublin, K36VK53, Ireland.

We are committed to protecting your privacy and ensuring full compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Irish Data Protection Act 2018, and the ePrivacy Regulations (S.I. No. 336 of 2011).

If you have any questions about how we handle your data, you can contact us at any time:

2What personal data we collect

2.1 For substitute teachers

When you register as a substitute teacher on First Bell, we collect the following information:

• Full name, email address, and mobile phone number
• Teaching Council registration number and registration status
• Garda vetting reference number and status
• Where you choose to upload it, supporting documentation such as Garda vetting evidence and/or teaching qualification documents
• Qualifications, teaching subjects, and class levels you can teach
• School level preference (primary, post-primary, or both)
• Location (county and approximate geographic coordinates for distance-based matching)
• Availability preferences and schedule
• A profile photograph is required as part of substitute registration and is used to help schools identify substitutes using First Bell.
• Booking history and cover request responses
• Device tokens for push notifications

2.2 For school administrators

• Full name, email address, and phone number of the school contact(s)
• School name, address, Eircode, and roll number
• School type (primary or post-primary)
• Cover request history (dates, levels and/or subjects, notes)
• Favourite substitute teacher preferences

2.3 For waitlist registrants

• Name, email address, role (school or substitute), and county (optional)

2.4 Data collected automatically

• Limited device, operating-system and app information may be processed by service providers when their in-app features are used, including for payment functionality and fraud prevention.
• Push notification tokens (for delivering cover alerts)
• Timestamps of logins, requests, and actions within the platform
• IP address (logged by our hosting infrastructure for security purposes)

3How we use your data

4Who we share your data with

4.1 Schools and substitute teachers

When a cover request is matched and accepted, we share limited information between the parties to facilitate the booking. Schools receive the substitute teacher's name, Teaching Council registration number, phone number, and qualifications. Substitute teachers receive the school name, address, Eircode, subject needed, and any notes provided by the school.

This sharing is limited to what is necessary to fulfil the booking. Schools are responsible for independently verifying credentials in accordance with Department of Education requirements — see our Terms of Service for details.

4.2 Service providers

We use trusted third-party services to operate the platform. We have appropriate contractual and data-protection arrangements in place with these providers, including Data Processing Agreements where applicable:

4.3 Legal and regulatory authorities

We may disclose personal data where required by Irish or EU law, or in response to a valid legal request from a law enforcement authority or regulatory body such as the Data Protection Commission (DPC).

4.4 We never sell your data

4.5 Data Processing Agreements with schools

When schools use First Bell, they share personal data about their staff and substitute teachers with us. Under GDPR Article 28, First Bell acts as a data processor on behalf of the school for certain processing activities. We will provide a Data Processing Agreement to any school that requests one. Contact us at dataprotection@firstbell.ie to request a DPA.

5International data transfers

Two of our service providers process limited data outside the EU/EEA as part of their global operations:

• Firebase (Google) provides account authentication, push notification delivery, and — where used — app data functionality via Cloud Firestore. Depending on the specific function, this may involve account identifiers (e.g. email), device push tokens, and notification content (e.g. "New cover request — St. Marnock's, 9am Monday") necessary to sign you in and deliver alerts to your phone. Core cover request, matching, school, and substitute profile data is stored in Supabase, not Firebase.
• Stripe processes billing and payment data connected to school subscriptions, including payment details entered directly through Stripe's secure interface. First Bell does not store raw card details.

Where transfers to non-EU/EEA countries occur (Firebase, Stripe), we use appropriate safeguards, specifically:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• The EU-US Data Privacy Framework, where the provider is certified

We regularly review the transfer mechanisms used by our providers and will update this policy if circumstances change.

6Account deletion and how long we keep your data

6.1 Deleting your account

Both substitute teachers and school administrators can delete their account directly from the Profile screen in the First Bell app. This requires you to re-enter your password and confirm an explicit acknowledgement before deletion proceeds.

Deletion may be temporarily unavailable where there is a legitimate outstanding obligation attached to your account:

• School accounts: deletion is blocked while there is a pending cover request, an accepted cover request for today or a future date, or an active subscription that can still renew
• Substitute accounts: deletion is blocked while there is an upcoming accepted cover booking

What happens when you delete your account

Deleting your account does not mean all associated data is deleted — some records are retained for the reasons set out below. Specifically:

For substitute teachers:

• Your login (Firebase) account is deleted
• Your substitute profile is deleted
• Uploaded profile documents and photos are deleted
• Personal identifying account information is removed
• Historical cover records may remain for the relevant school's operational and business history, with your personal identifiers removed or pseudonymised as appropriate

For school administrators:

• Your admin login is deleted
• Your personal contact details are removed from the school's record
• The school's organisational record is retained
• Historical school, cover, and business records are retained as part of the school's operational history — this reflects business record-keeping needs, not a claim that every retained record is legally mandatory

You can still contact dataprotection@firstbell.ie for data-protection queries, to request a copy of your data, or for help with deletion — but in-app deletion is the primary route and email is no longer required to delete your account.

6.2 How long we keep your data

You can delete your account directly in the app (see 6.1 above), or contact us at dataprotection@firstbell.ie for any other data-protection request.

7How we protect your data

We take data security seriously and implement the following technical and organisational measures:

• All data in transit is encrypted using TLS 1.2 or higher
• All data at rest is encrypted using AES-256 encryption (provided by Supabase/AWS)
• Authentication uses securely hashed passwords — we never store passwords in plain text
• Row-Level Security (RLS) policies ensure users can only access data they are authorised to see
• Administrative access to the database is restricted, authenticated, and logged
• We conduct regular reviews of our security practices and access controls

8Cookies and tracking

The First Bell website (firstbell.ie) uses minimal cookies:

• Essential cookies: Required for the waitlist sign-up form to function (Supabase session handling). These do not require consent under the ePrivacy Regulations.
• Analytics: We do not currently use any third-party analytics or tracking tools on our website. If we introduce analytics in the future, we will update this policy and implement a cookie consent mechanism before doing so.

The First Bell mobile app does not use cookies. It stores authentication tokens locally on your device to keep you logged in securely.

9Your rights under GDPR

Under the General Data Protection Regulation, you have the following rights in relation to your personal data. Registered users can delete their own account directly in the app (see section 6.1). To exercise any other right below, email us at dataprotection@firstbell.ie — we will respond within 30 days.

If your request is complex, we may extend our response by a further 60 days and will inform you within the initial 30-day period. You will not be charged a fee for exercising your rights unless your request is manifestly unfounded or excessive.

10Children's data

First Bell is a platform for schools and qualified teachers. We do not knowingly collect personal data from children (anyone under the age of 18). Our registered users are school administrators, school staff, and qualified substitute teachers — all of whom are adults.

If we become aware that we have inadvertently collected personal data from a child, we will delete it immediately and notify you if you are the relevant account holder. Schools must not include individual pupil names or identifiable pupil data in cover request notes. First Bell is not responsible for any such data entered by school administrators.

11Automated decision-making

Our platform uses automated matching to connect substitute teachers with cover requests based on factors including subject qualifications, location proximity, availability, and school preferences (such as favourites lists). This matching is automated but does not constitute solely automated decision-making with legal or similarly significant effects under GDPR Article 22, because:

• The matching process facilitates a booking that both parties must actively accept — no booking is confirmed without a substitute teacher choosing to accept it
• Schools can always contact First Bell to raise any concerns about the matching process
• Schools retain full discretion over which substitute teachers they designate as favourites

You can contact us at dataprotection@firstbell.ie if you have concerns about how the matching algorithm works or believe it has produced an unfair outcome.

12Changes to this policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make significant changes, we will:

• Update the "Last updated" date at the top of this page
• Notify registered users by email or in-app notification
• Where required by law, seek fresh consent for any new data processing activities

We encourage you to review this page periodically.

13How to make a complaint

If you are unhappy with how we have handled your personal data, we would appreciate the opportunity to resolve the matter directly. Please contact us first at dataprotection@firstbell.ie — we aim to respond within 5 working days.

If you are not satisfied with our response, you have the right to lodge a complaint with the Irish Data Protection Commission:

14Contact us

For any privacy-related queries, requests, or concerns: