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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.

C

Clinical research

Clinical research is research in which people, or data or biological samples derived from people, are studied to understand health and disease, to test the safety and efficacy of interventions, or to improve care. It spans interventional clinical trials regulated under EU CTR 536/2014, clinical investigations of medical devices under the MDR, observational and natural history studies, registries, and secondary use of existing health data and samples.

Under the GDPR, clinical research typically relies on Art. 6(1)(e) or (f) for the lawfulness of processing and on Art. 9(2)(j) (scientific research with appropriate safeguards under Art. 89) for health data, rather than on consent in the GDPR sense. The EDPB (Opinion 3/2019) distinguishes informed consent to participate in research, which is an ethical and CTR requirement, from consent as a data protection legal basis, which is rarely appropriate given the imbalance of power and the need for data integrity.

National rules add a further layer: France's MR-001 to MR-008 reference methodologies, Germany's state hospital laws, and specific research exemptions in the UK and Switzerland. See iliomad's clinical research compliance services.