Participation in features like DNA Relatives, which connects you with genetic relatives identified in the 23andMe database, is optional and user-controlled.
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
Participating in DNA Relatives discloses your genetic relationship to other users and may reveal family information to people you did not previously know, including information about relatives who have not themselves consented to be identified.
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 …
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 teleheal…
The terms authorize users to opt into features that share genetic relationship data with other matched users, which may surface family connections, including unexpected ones such as previously unknown relatives or donor-conceived relationships, and this sharing is within user control but affects individuals beyond the consenting user.
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"You decide whether you want to participate in our sharing features, like DNA Relatives and Your Connections.— Excerpt from 23andMe's 23andMe Privacy Statement
REGULATORY LANDSCAPE: DNA Relatives and similar features involve sharing genetic relationship information with third-party users, which engages state genetic privacy laws and GDPR provisions on the rights of data subjects who are identified as a result of another user's data, a category sometimes called third-party data subjects in genetic privacy literature. The FTC has issued guidance on sensitive genetic data sharing. GOVERNANCE EXPOSURE: Medium. The privacy implications of DNA Relatives extend to individuals who have not consented to be identified by 23andMe, specifically genetic relatives who are matched in the database as a consequence of a consenting user's participation. The policy places the consent and control obligation on the active user rather than addressing rights of the identified relatives. JURISDICTION FLAGS: EU and UK users participating in DNA Relatives create data processing implications for matched relatives who may be in different jurisdictions. The GDPR rights of individuals identified as genetic relatives without their own active consent is an area of regulatory complexity. CONTRACT AND VENDOR IMPLICATIONS: No significant contract or vendor implications from this specific feature; the sharing is user-to-user within the 23andMe platform. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the consent framework for DNA Relatives adequately addresses the rights of third-party relatives who are identified as a result of another user's data, and whether the feature's disclosure mechanisms meet GDPR transparency requirements for all potentially affected data subjects.
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Participating in DNA Relatives discloses your genetic relationship to other users and may reveal family information to people you did not previously know, including information about relatives who have not themselves consented to be identified.
The terms authorize users to opt into features that share genetic relationship data with other matched users, which may surface family connections, including unexpected ones such as previously unknown relatives or donor-conceived relationships, and this sharing is within user control but affects individuals beyond the consenting user.
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