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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 trial site

A clinical trial site (investigational or investigator site) is the physical location, such as a hospital department, clinic, research centre, general practice or, increasingly, the participant's home in decentralised trials, where trial-related activities are performed under the responsibility of a principal investigator. Sites recruit and treat subjects, collect source data, report adverse events and maintain the investigator site file.

The relationship between the sponsor and the site is governed by a clinical trial agreement, which allocates responsibilities, budget, insurance and data protection roles. Site selection, initiation, monitoring and close-out visits are conducted by the sponsor or its CRO in line with GCP.

Under the GDPR the site is generally a controller in its own right for the medical care and for the directly identifying source data it holds, while the sponsor is controller for the pseudonymised trial dataset; some jurisdictions and the EDPB have also considered joint controllership for certain activities. The site holds the key linking subject codes to identities, which is why the sponsor's data is pseudonymised rather than anonymous. Site staff personal data (CVs, training records, financial disclosures) is also processed by the sponsor and requires its own information notice.