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
Users relying solely on the main Privacy Statement may not be aware that their medical information from Telehealth Services is governed by a distinct, separate notice with potentially different terms.
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 →If the reader opts into Telehealth Services coordinated through 23andMe, a separate Medical Record Privacy Notice — beyond this Privacy Statement — applies to their medical information.
How other platforms handle this
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to notify the Disclosing Party promptly and in writing of the circumstances surrounding any suspected possession, use or knowledge of the Confidential Information
Recipient may disclose Discloser's Confidential Information: (i) to the extent that such disclosure is required by applicable law or by the order of a court...provided that...the Recipient promptly notifies the Discloser in writing of such required disclosure...
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"Should you choose to receive Telehealth Services coordinated through 23andMe...there is a separate Medical Record Privacy Notice that describes how your medical information is used, disclosed, and maintained.— Excerpt from 23andMe's 23andMe Privacy Statement
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Users relying solely on the main Privacy Statement may not be aware that their medical information from Telehealth Services is governed by a distinct, separate notice with potentially different terms.
If the reader opts into Telehealth Services coordinated through 23andMe, a separate Medical Record Privacy Notice — beyond this Privacy Statement — applies to their medical information.
ConductAtlas has identified this type of provision across 276 platforms. See the full comparison.
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