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Term of the Day

Natural history study

A natural history study is a preplanned observational study intended to track the course of a disease over time, identifying demographic, genetic, environmental and other variables that correlate with its development and outcomes in the absence of intervention, or under standard of care. Designs may be retrospective (chart review of existing records) or prospective (longitudinal follow-up of a cohort or registry).

Natural history data is particularly important in rare and paediatric diseases, where randomised placebo-controlled trials may be infeasible or unethical. The FDA (guidance on rare disease natural history studies, 2019) and the EMA accept well-designed natural history studies to define endpoints and biomarkers, identify patient subgroups, estimate sample sizes and, in some cases, serve as external or historical control arms for single-arm trials supporting orphan products.

Because they are non-interventional, natural history studies fall outside the CTR and are governed by national law (for example France's MR-003 or MR-004 reference methodologies) and by the GDPR. They typically involve secondary use of medical records, long-term follow-up, genetic data and small populations in which anonymisation is rarely achievable, so pseudonymisation, a DPIA and a robust research legal basis under Art. 9(2)(j) are essential. Registries maintained by patient organisations or academic consortia raise additional questions of joint controllership and data access governance.

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Accountability

Accountability is the principle in Art. 5(2) GDPR under which the controller is responsible for, and must be able to demonstrate, compliance with all data protection principles. It shifts the burden of proof onto the organisation: it is not enough to be compliant, you must be able to show it to a supervisory authority, an auditor or a business partner.

In practice, accountability is evidenced through documentation and governance: a record of processing activities, DPIAs for high-risk processing, data processing agreements with vendors, a breach register, policies, staff training records and, where required, the appointment of a Data Protection Officer (Art. 24, 30, 35 and 37 GDPR).

For life sciences organisations, accountability also intersects with ICH GCP requirements on documentation and audit trails. A sponsor that cannot produce its DPIA, its transfer assessments or its processor contracts during a due diligence or a regulatory inspection is, by definition, non-compliant even if no breach has occurred.