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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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Article 29 Working Party (WP29)

The Article 29 Working Party (WP29) was the independent advisory body established by Art. 29 of Directive 95/46/EC, composed of representatives of the national data protection authorities, the European Data Protection Supervisor and the European Commission. It issued opinions and working documents interpreting EU data protection law between 1996 and May 2018.

On 25 May 2018 the WP29 was replaced by the European Data Protection Board (EDPB) under Art. 68 GDPR. The EDPB formally endorsed a number of WP29 documents, which remain authoritative references. For life sciences organisations, the most frequently cited are Opinion 05/2014 on anonymisation techniques, Opinion 15/2011 and the 2018 guidelines on consent, the guidelines on DPIAs (WP248), on Data Protection Officers (WP243) and on the lead supervisory authority (WP244).

When a WP29 document is cited in a DPIA or policy today, it is good practice to state whether the EDPB has endorsed or superseded it, since several topics (for example transfers and consent in clinical trials) have since been addressed in newer EDPB guidance.