Beyond Individual Privacy: A Layered Diagnostic Model for Analyzing Genetic Data Governance

Human genetic data are simultaneously deeply personal, familial, and strategically valuable, raising regulatory challenges that individual-centered privacy frameworks only partially address. This is highlighted by the recent high-profile bankruptcy filing by 23andMe, which triggered widespread public concerns extending beyond consumer privacy interests to potential national security risks. To address this, this paper proposes a three-layer diagnostic model for more comprehensive analysis of genetic data governance: (1) individual privacy as sensitive personal data; (2) relational and group (privacy) interests reflecting genetic data's shared nature; and (3) the state or strategic layer treating genetic information as a national asset relevant to public health and security. Drawing on comparative examination of select jurisdictions and critical review of scholarship, this integrated framework offers researchers, policymakers, and private actors a practicable pathway to navigate the complex governance challenges posed by genetic data.