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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
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.
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.
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"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
(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.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
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 …
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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.