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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

Consent

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her (Art. 4(11) GDPR). It is one of six legal bases under Art. 6(1) and, in its explicit form, one of the exceptions allowing processing of special category data under Art. 9(2)(a).

Art. 7 sets the conditions: the controller must be able to demonstrate consent; a request must be clearly distinguishable from other matters; consent must be as easy to withdraw as to give; and it is presumed not freely given where there is a clear imbalance of power or where performance of a service is made conditional on consent that is not necessary. Pre-ticked boxes and silence do not qualify (Planet49, C-673/17).

In clinical research, consent to participate in a trial (an ethical and CTR requirement, see informed consent) should not be confused with consent as a data protection legal basis. The EDPB (Opinion 3/2019) considers GDPR consent generally inappropriate for trial data because of the power imbalance and because withdrawal would compromise data integrity; sponsors typically rely on Art. 6(1)(e)/(f) and Art. 9(2)(i)/(j) instead. Consent remains relevant for optional sub-studies, future research and marketing communications.