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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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Appropriate safeguards

Appropriate safeguards are the transfer mechanisms listed in Art. 46 GDPR that allow personal data to be transferred to a third country in the absence of an adequacy decision, provided enforceable data subject rights and effective remedies are available.

The main instruments are standard contractual clauses adopted by the European Commission, binding corporate rules for intra-group transfers, approved codes of conduct and certification mechanisms, and, for public bodies, legally binding administrative arrangements. Since the Schrems II judgment (C-311/18), each safeguard must be accompanied by a transfer impact assessment and, where necessary, supplementary measures such as encryption or pseudonymisation with keys held in the EEA.

The GDPR also uses the phrase in other contexts: Art. 89 requires appropriate safeguards for processing for scientific research purposes, and Art. 9(2)(j) requires them for special category data processed for research. For a global clinical trial, the same data flow to a US sponsor may therefore need transfer safeguards under Art. 46 and research safeguards under Art. 89 at the same time.

Are research safeguards the same as international-transfer safeguards?

No. Research safeguards protect people in the conduct of research, while transfer safeguards address disclosure to recipients outside the EEA. A multinational study may need both. For example, coding participant records does not itself establish an Article 46 transfer mechanism, and signed transfer clauses do not replace appropriate controls within the study.