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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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Ad hoc services

Ad hoc services are one-off, clearly scoped data protection engagements delivered for a specific need, as opposed to a recurring mandate such as an outsourced Data Protection Officer or Data Protection Representative.

Typical ad hoc engagements in life sciences include a DPIA for a new clinical trial or platform, a gap analysis before a financing round or acquisition, the review of an informed consent form or clinical trial agreement, a transfer impact assessment for a new vendor, or a due diligence audit of a target company.

Ad hoc work is usually priced on a fixed-fee or time-and-materials basis and delivers a defined output (report, redlined document, register). It is the right model when the need is bounded; where processing is ongoing, high-risk or large-scale, Art. 37 GDPR may in any case require a permanent DPO. See iliomad's compliance services.

When is an ad hoc compliance engagement more useful than an ongoing mandate?

An ad hoc engagement fits a defined task with a clear deliverable, such as reviewing a notice or assessing a particular data flow. Agree the scope, inputs, exclusions and handover before work starts. It does not replace an ongoing role or duty that applies to the organisation, including a required DPO appointment.