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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

Controller

A controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (Art. 4(7) GDPR). The controller carries the primary obligations: lawfulness, transparency, data subject rights, security, accountability, breach notification and, where applicable, the DPIA and the appointment of a DPO and of an EU representative.

Controllership is a question of fact, not of contract: the EDPB Guidelines 07/2020 explain that whoever decides "why" and the essential "how" of processing is the controller, even if the contract says otherwise. Where two or more entities jointly determine purposes and means, they are joint controllers under Art. 26. A body processing only on instructions is a processor.

In clinical trials, the sponsor is controller for the trial dataset because it defines the protocol, and the site is controller for medical care and source documents. A CRO is normally a processor, unless it takes independent decisions on purposes. A HealthTech company offering an app to patients is controller for the app data, and becomes a processor when it deploys the same technology on behalf of a hospital. Getting this allocation right drives every downstream obligation and should be documented in a DPA or joint-controller arrangement.