Provision record
23andMe · 23andMe Terms of Service · View original document ↗

Minor Account and Sample Submission by Legal Guardian

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 352 platforms
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Document Record

What it is

The terms permit parents or legal guardians to submit genetic samples on behalf of minors, and legally authorized representatives to submit on behalf of other individuals, as a condition of service eligibility.

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 authorizes the collection and processing of genetic information from minors through parental or guardian consent, establishing the contractual basis for 23andMe to hold and process a child's genetic data. This mechanism engages both COPPA for online services directed at or knowingly collecting data from minors and state genetic privacy statutes that may impose separate consent or data retention requirements for minors' genetic information.

Interpretive note: The specific data rights, research participation scope, and deletion procedures applicable to minors' genetic data are not fully detailed in the provided document section.

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users who are parents or legal guardians may submit genetic samples on behalf of minors, binding both themselves and the minor to the terms of service including data use and research authorization provisions. The specific data rights and deletion procedures available for minors' genetic data are not detailed in the provided document section.

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.
  • Delete Your Data
    Parents or legal guardians managing a minor's account may request deletion of the minor's genetic data and close the associated account through Account Settings or by contacting 23andMe customer support.

Cross-platform context

See how other platforms handle Minor Account and Sample Submission by Legal Guardian and similar clauses.

Compare across platforms →

Monitoring

23andMe has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
Any sample you provide to 23andMe is either your own, or the sample of a minor for whom you are a parent or legal guardian, or the sample of a person for whom you are a legally authorized representative;

Excerpt from 23andMe's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: COPPA applies to the online collection of personal information from children under 13, and may apply to 23andMe's collection of genetic data from minors if the online account creation or results delivery involves a covered child. State genetic privacy statutes in California and other jurisdictions may impose specific consent and data retention requirements for minors' genetic information that differ from those applicable to adults. GDPR and UK GDPR impose separate requirements for processing children's data if EU or UK minors are involved. (2) GOVERNANCE EXPOSURE: High. The collection of genetic information from minors through parental consent creates significant and long-duration data exposure, given the immutability of genetic data and the extended period over which it may be retained. The adequacy of parental consent as a basis for research participation involving minors' genetic data requires specific evaluation against applicable law. (3) JURISDICTION FLAGS: California's Genetic Information Privacy Act and the California Consumer Privacy Act provide specific rights regarding minors' personal information. Illinois and other states with biometric or genetic privacy statutes may impose independent consent or deletion rights for minors. EU and UK users are directed to separate regional terms. (4) CONTRACT AND VENDOR IMPLICATIONS: The extension of research and Product Development authorization to minors' de-identified genetic data, if applicable, requires careful assessment against COPPA, state minor privacy statutes, and IRB consent requirements for research involving minors as human subjects. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that the IRB-approved research consent process includes specific provisions for minors' participation and that parental consent is documented separately from the base Terms acceptance. Data mapping should identify minors' genetic data as a distinct category with heightened retention, deletion, and access rights.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Applicable agencies

  • FTC
    The FTC enforces COPPA, which governs online collection of personal information from children under 13, potentially including genetic data collected through parental account creation
    File a complaint →
  • State AG
    State attorneys general may have jurisdiction over genetic privacy and minor data protection requirements under state-specific statutes
    File a complaint →

Provision details

Document information
Document
23andMe Terms of Service
Entity
23andMe
Document last updated
May 5, 2026
Tracking information
First tracked
May 11, 2026
Last verified
July 9, 2026
Record ID
CA-P-016452
Document ID
CA-D-00147
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
bddb92bc01773d87e5f6157d525fe0a08abb0e48becacc33725f316880d9f25e
Analysis generated
May 11, 2026 23:34 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: 23andMe
Document: 23andMe Terms of Service
Record ID: CA-P-016452
Captured: 2026-05-11 23:34:45 UTC
SHA-256: bddb92bc01773d87…
URL: https://conductatlas.com/platform/23andme/23andme-terms-of-service/provision/CA-P-016452/minor-account-and-sample-submission-by-legal-guardian/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Governance intelligence across arbitration, AI governance, data rights, indemnification, and retention

Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.

Frequently Asked Questions

What does 23andMe's Minor Account and Sample Submission by Legal Guardian clause do?

This provision authorizes the collection and processing of genetic information from minors through parental or guardian consent, establishing the contractual basis for 23andMe to hold and process a child's genetic data. This mechanism engages both COPPA for online services directed at or knowingly collecting data from minors and state genetic privacy statutes that may impose separate consent or data retention …

How does this clause affect you?

Under this clause, users who are parents or legal guardians may submit genetic samples on behalf of minors, binding both themselves and the minor to the terms of service including data use and research authorization provisions. The specific data rights and deletion procedures available for minors' genetic data are not detailed in the provided document section.

Is ConductAtlas affiliated with 23andMe?

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