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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.

A

Adverse event

An adverse event (AE) is any untoward medical occurrence in a subject to whom a medicinal product is administered, which does not necessarily have a causal relationship with the treatment (Art. 2(2)(32) EU Clinical Trials Regulation 536/2014; ICH E6 GCP 1.2). An AE can be any unfavourable sign, symptom, laboratory finding or disease temporally associated with the use of the investigational medicinal product.

AEs are distinguished from adverse reactions (where a causal relationship is at least a reasonable possibility) and graded by seriousness: a serious adverse event results in death, is life-threatening, requires hospitalisation or causes significant disability. Suspected unexpected serious adverse reactions (SUSARs) trigger expedited reporting to authorities through EudraVigilance.

From a data protection perspective, AE reports are data concerning health and therefore special category data. Their collection and reporting rest on legal obligation and public interest in public health (Art. 6(1)(c) and 9(2)(i) GDPR), not on consent, and they cannot be erased at the subject's request during the mandatory retention period. See also pharmacovigilance.

Must an adverse event be caused by the study medicine to be recorded as an AE?

No. An adverse event can occur without an established causal relationship to the investigational product. Causality is a separate assessment. Follow the protocol’s collection and reporting rules, recording the event accurately rather than excluding it merely because another explanation appears more likely.