This analysis describes what 23andMe's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The clause operationalizes a distinction between sample retention and data retention: while physical samples are subject to removal upon request, research data derived from prior research participation remains available for use under the original research consent, independent of subsequent sample deletion requests.
The updated privacy statement no longer explicitly directs users to a separate Medical Record Privacy Notice for telehealth services or explains that medical information collected through telehealth is governed by different privacy rules. Previously, the policy stated that users choosing telehealth services coordinated through 23andMe would find healthcare privacy protections described in a separate notice. That reference is now absent from the main privacy statement. Users seeking privacy information specific to telehealth services will need to determine independently whether a separate notice exists or contact 23andMe directly using the provided contact information.
View change record →The updated privacy statement no longer explicitly discloses a separate Medical Record Privacy Notice that previously described how medical information is used, disclosed, and maintained for telehealth services. Users who receive telehealth services coordinated through 23andMe may now lack clear notice of which privacy framework governs their medical records, since the reference to that parallel notice has been removed. The organizational scope change from '23andMe Research Institute' to '23andMe' narrows the explicitly named entities responsible for the policy, though operational impact depends on how these entities actually function.
View change record →Users who request sample discarding or account deletion may have their genetic information and self-reported data continue to be used for ongoing or future research if they previously opted into 23andMe Research. The provision requires users to understand that research participation consent operates separately from sample retention decisions.
How other platforms handle this
We retain personal data for as long as necessary to provide our services, fulfill the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. The specific retention period for each category of personal data depends on the purpose fo...
We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. We may also retain and use your information to comply with our legal obligations, resolve disputes, and enforce our ...
Please note there are situations where Spotify is unable to delete your data, for example when: it's still necessary to process the data for the purpose we collected it for; we have an overriding interest in continuing to process the data, for example where we need the data to protect our services f...
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"If you have previously provided a saliva sample but request that we discard it, we will discard the sample within 30 days of receiving your request. Please be aware that if you have consented to participating in 23andMe Research, some research using your Genetic Information and/or Self-Reported Information may have already been performed or may still be in progress, and your data may still be used for these purposes, even if you have requested your sample be discarded or your account deleted.— Excerpt from 23andMe's 23andMe Privacy Statement
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The clause operationalizes a distinction between sample retention and data retention: while physical samples are subject to removal upon request, research data derived from prior research participation remains available for use under the original research consent, independent of subsequent sample deletion requests.
Users who request sample discarding or account deletion may have their genetic information and self-reported data continue to be used for ongoing or future research if they previously opted into 23andMe Research. The provision requires users to understand that research participation consent operates separately from sample retention decisions.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.