Privacy Policy
How we handle your information on The First Steps platform
Who we are
The First Steps is a private digital platform operated by the funeral director, a member practice of My Farewell Wishes (MFW).
For the purposes of data protection law, the funeral director is the data controller for information collected through this platform.
Contact: the funeral director
What information we collect
When you access The First Steps, we collect:
- Your email address — entered at the gateway screen
- Your visitor type — whether you are a family member or a funeral director
- Your confirmation that you have read this Privacy Policy — recorded as a timestamp
- Technical data — browser type and approximate access time (for security and audit purposes)
When you submit a funeral notice through the platform, we also collect:
- The name of the deceased
- Contact details you provide (name, email, phone number)
- The content of the funeral notice
- Any photo you upload
Why we collect it — our lawful basis
We process your personal data under the following legal bases under GDPR (EU 2016/679) and the Irish Data Protection Acts 2018:
- Legitimate interests — understanding who uses this platform (funeral directors vs. families) so we can provide the most relevant guidance, and maintaining basic security logs.
- Contractual necessity — when you submit a funeral notice, processing your contact details and the notice content is necessary for us to arrange and deliver funeral services.
We do not rely on your consent to process this data — reading and confirming this Privacy Policy is simply how we make sure you are aware of how your information is used before you proceed.
What we do not do
Who we share data with
Your data may be accessed by the following trusted parties, solely to operate this platform:
- Supabase Inc. — our database provider, used to securely store gateway records and form submissions (servers located in the EU).
- EmailJS — used to deliver funeral notice content to the funeral director's team by email.
- The funeral director's staff — who may view submissions in the course of arranging funeral services.
These processors operate under appropriate data processing agreements. No data is shared with any advertising, marketing, or analytics platforms.
How long we keep your data
Gateway access records (email, visitor type, access time) are retained for up to 12 months for security and operational review purposes, then deleted.
Funeral notice submissions are retained for as long as necessary to complete the funeral arrangement and fulfil any legal obligations (typically up to 7 years under Irish record-keeping requirements), after which they are securely deleted.
Your rights
Under GDPR and Irish data protection law, you have the right to:
- Access — request a copy of the personal data we hold about you
- Rectification — ask us to correct inaccurate data
- Erasure — ask us to delete your data (subject to legal retention obligations)
- Restriction — ask us to limit how we process your data
- Objection — object to processing based on legitimate interests
- Portability — receive your data in a structured, machine-readable format
To exercise any of these rights, please contact us at the funeral director. We will respond within 30 days.
Complaints
If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Irish supervisory authority:
Data Protection Commission (DPC)
21 Fitzwilliam Square South, Dublin 2, D02 RD28
www.dataprotection.ie
Tel: +353 (0)1 765 0100
Changes to this policy
We may update this policy from time to time. The current version will always be available at this address. Significant changes will be communicated at the gateway screen.
Last updated: June 2026.