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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.

B

Binding corporate rules (BCR)

Binding corporate rules (BCRs) are personal data protection policies adhered to by a controller or processor established in the EU for transfers of personal data to entities of the same group of undertakings, or group of enterprises engaged in a joint economic activity, located in third countries (Art. 4(20) and Art. 47 GDPR). Once approved by the competent supervisory authority after an EDPB opinion, they constitute appropriate safeguards under Art. 46(2)(b).

BCRs must be legally binding on every group member and employee, confer enforceable rights on data subjects, and cover the elements listed in Art. 47(2): structure of the group, data flows, application of the principles, complaint procedures, audit, cooperation with authorities and liability of the EU entity. Controller BCRs (BCR-C) and processor BCRs (BCR-P) are approved separately, and the EDPB updated its referential in 2023.

For global pharmaceutical and CRO groups, BCRs replace hundreds of intra-group standard contractual clauses and simplify the transfer impact assessment process. They do not cover transfers to external vendors or investigator sites, which still require SCCs or another mechanism, and the approval process typically takes 18 months or more.

Do binding corporate rules automatically cover every overseas vendor?

No. BCRs provide safeguards for transfers within the relevant approved group arrangement, not blanket permission to disclose data to any external provider. Check the covered entities, processing and data flows. If the recipient falls outside that scope, assess an appropriate separate transfer route rather than assuming the group’s BCR approval extends to it.