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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 study

A clinical study is any investigation in relation to humans intended to discover or verify the clinical, pharmacological or other pharmacodynamic effects of one or more medicinal products, to identify any adverse reactions to them, or to study their absorption, distribution, metabolism and excretion, with the objective of ascertaining their safety and efficacy (Art. 2(2)(1) EU Clinical Trials Regulation 536/2014).

The Regulation uses "clinical study" as the umbrella term. A clinical trial is a clinical study in which the assignment to a therapeutic strategy is decided in advance and is not normal clinical practice, or in which the investigational products are prescribed together with the decision to include the subject, or in which additional diagnostic or monitoring procedures are applied. A clinical study that is not a clinical trial is a non-interventional study, which falls outside the CTR and is governed by national law and pharmacovigilance rules.

The distinction matters operationally: only clinical trials require CTIS submission, a sponsor with an EU legal representative, insurance and the CTR safety reporting regime. From a data protection angle, both categories process health data and require a DPIA, but the applicable national frameworks (for example France's MR-001 versus MR-003 or MR-004) differ.