Privacy Policy
Last update: 31 Aug, 2026

PRIVACY POLICY

Last updated: 31 August 2026


1. WHO WE ARE


Universal Genomics Ltd ("Universal Genomics", "we", "us" or "our") is committed to protecting the privacy, confidentiality and security of personal, health and genomic information.

Universal Genomics Ltd is incorporated in England and Wales.

Company number: 17289512
Registered office: 13 Whitchurch Lane, Edgware, England, HA8 6JZ

For the purposes of applicable data protection legislation, Universal Genomics Ltd may act as a data controller where it determines the purposes and means of processing personal information. In certain circumstances, including particular clinical, laboratory, research or collaborative arrangements, our role may differ and further information may be provided to you.

If you have questions about this Privacy Policy or how we process personal information, please contact:

Email: privacy@universalgenomics.org

2. OUR APPROACH TO GENOMIC PRIVACY


We recognise that genomic information is particularly sensitive.

Genetic and genomic information may reveal information about an individual's health, inherited characteristics and, in some circumstances, biological relationships. It may also have potential relevance to biological relatives.

For this reason, Universal Genomics is committed to applying appropriate safeguards when handling genomic and health information, including measures designed to support confidentiality, security, data minimisation and responsible scientific research.

We distinguish carefully between:

  • Identifiable personal data, which can identify or reasonably be linked to an individual;

  • Pseudonymised data, where direct identifiers have been replaced or separated but re-identification remains possible using additional information; and

  • Anonymised data, which has been processed so that an individual is not, or is no longer, identifiable by reasonably available means.

Pseudonymised data remains personal data and continues to be protected by applicable data protection law.

3. USE OF DATA FOR SCIENTIFIC RESEARCH AND DEVELOPMENT


Genomic science develops continuously. Information generated today may contribute to improved understanding of cancer, hereditary conditions, rare diseases and other areas of human health in the future.

Universal Genomics may therefore use appropriately anonymised data derived from the provision of our services for legitimate scientific, research, development, quality-improvement and innovation purposes.

These activities may include:

  • Improving genomic analysis and interpretation;

  • Improving the identification and classification of genetic variants;

  • Developing and validating bioinformatics and computational methods;

  • Developing artificial intelligence and other analytical technologies;

  • Improving understanding of cancer genomics;

  • Improving liquid-biopsy and circulating DNA analysis;

  • Improving the understanding of hereditary and rare diseases;

  • Evaluating analytical performance and quality;

  • Developing future genomic technologies and services;

  • Producing aggregated scientific and statistical findings.

Anonymised Data


Where information has been genuinely anonymised so that an individual is no longer identifiable, Universal Genomics may use that anonymised information for research, scientific development, quality improvement and innovation without seeking additional consent for each individual research project.

By using our services, you acknowledge that appropriately anonymised information derived from your data may be retained and used by Universal Genomics for these purposes.

Universal Genomics will take reasonable steps to ensure that information described as anonymised has been processed in a manner intended to prevent identification of individuals by reasonably available means.

Where genuinely anonymised data is used, it will not contain direct identifiers such as your name, contact details or other direct identifying information.

Pseudonymised or Identifiable Data Used for Research


Universal Genomics recognises that pseudonymisation is not the same as anonymisation.

Where data remains identifiable, directly or indirectly, it will continue to be treated as personal information and, where applicable, special-category data.

If Universal Genomics wishes to use identifiable or pseudonymised health or genomic information for scientific research, we will do so only where we have an appropriate lawful basis and meet the additional legal requirements applicable to genetic and health information.

Depending on the nature of the research and applicable law, this may include:

  • Explicit consent;

  • Scientific research provisions;

  • Another lawful basis or condition permitted under applicable data protection law;

  • Appropriate ethical or research governance approval where required.

Where consent is required for a particular research activity, we will seek it in an appropriate and transparent manner.

We will not treat a general acceptance of our website terms or a routine request for a clinical service as automatically authorising every possible use of identifiable genomic information for unrelated research purposes.

4. DATA SHARING FOR RESEARCH


Universal Genomics may undertake research internally or collaborate with universities, healthcare organisations, research institutions, laboratories or other scientific partners.

Where appropriate, we may share:

  • Aggregated information;

  • Statistical information;

  • Appropriately anonymised information; or

  • Other information where sharing is permitted by law and subject to appropriate safeguards.

Where personal information is shared with a research collaborator, Universal Genomics will seek to ensure that appropriate legal, technical and organisational safeguards are in place.

Such safeguards may include:

  • Data-sharing agreements;

  • Research agreements;

  • Confidentiality obligations;

  • Data minimisation;

  • Pseudonymisation or anonymisation where appropriate;

  • Restricted access;

  • Security requirements;

  • Limitations on further disclosure.

Universal Genomics will not sell identifiable personal, clinical or genomic information as a commercial product.

5. DISCLOSURE TO LAW ENFORCEMENT AND GOVERNMENT AUTHORITIES


Universal Genomics recognises that health and genomic information is highly sensitive.

We do not routinely provide identifiable personal, clinical or genomic information to law enforcement agencies, immigration authorities, government bodies or other external authorities.

We will not disclose such information merely because it has been requested informally.

However, there may be exceptional circumstances in which Universal Genomics is legally required or permitted to disclose information.

These circumstances may include:

  • A valid court order;

  • A statutory or other legal obligation;

  • A legally binding regulatory requirement;

  • A request that we are required by law to comply with;

  • Circumstances in which disclosure is necessary and proportionate to prevent or detect serious unlawful activity;

  • Circumstances involving substantial public interest where permitted by law;

  • The establishment, exercise or defence of legal claims;

  • Other exceptional circumstances permitted or required by applicable law.

Any request for identifiable personal, health or genomic information from a law enforcement or government authority will be assessed carefully and, where appropriate, by senior management and/or legal advisers.

Where disclosure is legally required or permitted, Universal Genomics will seek to:

  1. Verify the identity and authority of the requesting organisation;

  2. Assess the legal basis for the requested disclosure;

  3. Ensure that disclosure is necessary and proportionate;

  4. Consider whether the request specifically requires disclosure of special-category information;

  5. Limit disclosure to the minimum information reasonably necessary;

  6. Maintain appropriate records of the request and our response, where legally permissible.

We will not disclose identifiable genomic information to external authorities simply for convenience, commercial purposes or general investigative interest.

Nothing in this Privacy Policy prevents Universal Genomics from complying with a valid legal obligation, court order or other lawful requirement.

6. INSURERS, EMPLOYERS AND COMMERCIAL THIRD PARTIES


Universal Genomics will not sell or provide identifiable genomic, genetic or health information to:

  • Insurance companies;

  • Employers;

  • Marketing companies;

  • Data brokers; or

  • Other commercial organisations for their independent commercial use,

unless the disclosure is:

  • Requested or authorised by the individual;

  • Required by law;

  • Necessary to provide a service specifically requested by the individual; or

  • Otherwise supported by an appropriate lawful basis and applicable safeguards.

We believe that an individual's genomic information should not become a commodity for unrestricted commercial exploitation.

7. INTERNATIONAL RESEARCH COLLABORATIONS


Scientific research is frequently international.

Universal Genomics may collaborate with research institutions, laboratories, universities or technology providers located outside the United Kingdom.

Where personal information is transferred internationally, we will take steps required by applicable law to ensure that appropriate safeguards are applied.

Where possible and appropriate, Universal Genomics will seek to use aggregated or anonymised information for international research collaborations.

Where identifiable or pseudonymised information must be transferred, we will consider and implement appropriate safeguards, which may include:

  • Legally recognised adequacy arrangements;

  • Approved contractual safeguards;

  • International data transfer agreements;

  • Data transfer assessments;

  • Encryption;

  • Pseudonymisation;

  • Access restrictions; and

  • Other appropriate technical and organisational measures.

8. ARTIFICIAL INTELLIGENCE AND GENOMIC RESEARCH


Universal Genomics may use advanced computational methods, bioinformatics, machine learning and artificial intelligence technologies in connection with research, development and genomic analysis.

Where data is used to develop or improve these technologies, Universal Genomics will seek to apply appropriate safeguards.

Where possible, research and development will use:

  • Anonymised data;

  • Aggregated information;

  • Pseudonymised information with appropriate controls; or

  • Other data processed under an appropriate legal basis and governance framework.

Universal Genomics does not sell identifiable patient genomic data for the purpose of unrestricted third-party artificial intelligence development.

9. YOUR RIGHT TO OBJECT OR ASK QUESTIONS


If you have questions about how Universal Genomics uses information for research or scientific development, you may contact us at:

privacy@universalgenomics.org

Where applicable law provides you with the right to object to particular processing activities or withdraw consent, you may exercise those rights by contacting us.

Please note that a request relating to identifiable personal information may not affect information that has already been genuinely anonymised, because anonymised information can no longer reasonably be linked back to an individual.

10. OUR COMMITMENT


At Universal Genomics, we believe that the extraordinary potential of genomic medicine must be accompanied by an equally strong commitment to privacy.

We aim to use genomic information responsibly to advance science and improve understanding of disease while protecting the confidentiality, dignity and trust of the individuals whose information makes that progress possible.

Universal Genomics Ltd
The Whole Genome. The Bigger Picture.