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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.

D

Data concerning health

Data concerning health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status (Art. 4(15) GDPR). Recital 35 clarifies that it covers information on past, current and future health, including disease, disability, disease risk, medical history, clinical treatment, and any number, symbol or identifier assigned to a person to uniquely identify them for health purposes.

Health data is a special category of personal data: processing is prohibited under Art. 9(1) unless one of the exceptions in Art. 9(2) applies, most commonly explicit consent (a), health care and management of health systems (h), public health including pharmacovigilance (i), or scientific research with appropriate safeguards (j), each of which may be subject to further national conditions.

The definition is interpreted broadly. The Court of Justice has held that data from which health status can be inferred, such as an order for medication (Lindenapotheke, C-21/23) or the fact of attending a clinic, counts as health data. Wearable step counts, app usage on a mental-health platform, trial recruitment enquiries and even the metadata of a telemedicine call can therefore qualify. Organisations processing health data at scale must carry out a DPIA and, in most cases, appoint a DPO.