Provision record
23andMe · 23andMe Privacy Statement · View original document ↗

Research Participation and Genetic Data Pooling

High severity Medium confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

The agreement states that users who opt into research participation have their deidentified genetic data combined with data from other research participants, and that opt-out from this program is available at any time.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes the mechanism by which genetic information, once deidentified by 23andMe's processes, is aggregated into research datasets. The adequacy of the deidentification standard applied and the identity of downstream research partners are not detailed in this excerpt, which are material considerations under GDPR, HIPAA, and California GIPA transparency requirements.

Interpretive note: The document does not specify the deidentification methodology applied, the identity of research partners, or the scope of permissible downstream research use, which affects assessment of compliance with GDPR, HIPAA, and California GIPA requirements.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, users who opt into the research program have their deidentified genetic data pooled with other participants' data for research purposes. The agreement states opt-out is available at any time through account settings.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Log in to your 23andMe account, navigate to account settings, and locate the Research participation section to opt out of research data pooling at any time.

Cross-platform context

See how other platforms handle Research Participation and Genetic Data Pooling and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
If you choose to participate in research, your deidentified data will be pooled with data from other participants. You can opt out at any time.

Excerpt from 23andMe's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision implicates GDPR Article 9 (special category genetic data), the California Genetic Information Privacy Act, HIPAA deidentification standards under 45 CFR 164.514, and CCPA/CPRA disclosure requirements for data sharing.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • Department Of Health & Human Services, Office For Civil Rights (hhs Ocr)
    Enforces HIPAA Privacy and Security Rules, which protect health information held by healthcare providers, health plans, and their business associates.
    Who can file: Anyone whose HIPAA rights may have been violated by a covered entity (healthcare provider, health plan, or healthcare clearinghouse)
    What you need: Name of the entity, description of the violation, date of the incident, and your contact information. Must file within 180 days of the violation.
    What to expect: HHS OCR investigates and may require the entity to take corrective action. Does not provide individual compensation. Serious violations can result in civil monetary penalties.
    File a complaint →

Provision details

Document information
Document
23andMe Privacy Statement
Entity
23andMe
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015186
Document ID
CA-D-00148
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
84a7d427df1aaecf20068443719f4fe644ec63786924fac774f611468fc0435b
Analysis generated
July 9, 2026 07:23 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: 23andMe
Document: 23andMe Privacy Statement
Record ID: CA-P-015186
Captured: 2026-07-09 07:23:55 UTC
SHA-256: 84a7d427df1aaecf…
URL: https://conductatlas.com/platform/23andme/23andme-privacy-statement/provision/CA-P-015186/research-participation-and-genetic-data-pooling/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does 23andMe's Research Participation and Genetic Data Pooling clause do?

This provision establishes the mechanism by which genetic information, once deidentified by 23andMe's processes, is aggregated into research datasets. The adequacy of the deidentification standard applied and the identity of downstream research partners are not detailed in this excerpt, which are material considerations under GDPR, HIPAA, and California GIPA transparency requirements.

How does this clause affect you?

Under this provision, users who opt into the research program have their deidentified genetic data pooled with other participants' data for research purposes. The agreement states opt-out is available at any time through account settings.

Is ConductAtlas affiliated with 23andMe?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.